Split (1)

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THE SEVENOAKS DISTRICT COUNCIL (OFF-STREET PARKING PLACES) (AMENDMENT 3) ORDER 2010 The District Council of Sevenoaks in exercise of the powers conferred upon them by sections 32, 35 and 124 and Schedule 9 to the Road Traffic Regulation Act 1984 and of all other powers them enabling in that behalf, and with the consent of the County Council of Kent, and after all consultation with the Chief Officer of Police, HEREBY MAKE THE FOLLOWING ORDER: (1) The Sevenoaks District Council (Off-Street Parking Places) Order 2010, as amended, shall have effect as though the Schedule hereto were substituted for the Schedule thereto in its entirety; (2) The Interpretation Act 1978 shall apply for the interpretation of this Order as it applies for the interpretation of an Act of Parliament; (3) The Order shall come into operation on 1st April 2014 and may be cited as the Sevenoaks District Council (Off-Street Parking Places) (Amendment 3) Order 2010. Given under the Common Seal of the District Council of Sevenoaks this 27th day of March 2014. THE COMMON SEAL of the DISTRICT COUNCIL OF SEVENOAKS was hereto affixed In the presence of Authorised Signatory Authorised Signatory \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|-------------------------------------\|-----------------------------------\|----------------------------------------\|----------------------------------------\|-------------------------------\|--------------------------\| \| Edenbridge: Edenbridge Leisure Centre car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| No charge \| \| Eynsford: High Street car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| No charge \| \| Kemsing: High Street car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| No charge \| \| Sevenoaks: Blights car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| Up to 30 minutes: 70p 30 minutes to 1 hour: £1.30 1 to 2 hours: £2.70 2 to 3 hours: £4.50 \| Up to 3 hours: £1.00 \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait (Day Ticket Area) Wholly within an a bay where so defined \| 3 Class of vehicle permitted to park Motorcars, motor cycles and combinations; and invalid carriages \| 4 Hours when parking place is available All hours \| 5 Hours of operation of parking charges 3.00 pm to 6.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 6 Maximum period Vehicles may wait 10 hours between 3.00 pm and 1.00 am the following day \| 7 Scale of parking charges Up to 3 hours and 30 minutes: £1.50 \| \|---\|---\|---\|---\|---\|---\|---\| \| Sevenoaks: Bradbourne car park (continued) \| \| \| \| \| \| \| \| Sevenoaks: Buckhurst 1 car park \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 4 hours (during the charging hours) No return within 2 hours \| Up to 1 hour: £1.00 1 to 2 hours: £1.80 2 to 3 hours: £2.50 3 to 4 hours: £3.50 \| \| \| \| \| \| 6.30 pm to 9.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 6½ hours between 6.30 pm and 1.00 am the following day \| Up to 3 hours: £1.00 \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|-------------------------------------\|-----------------------------------\|----------------------------------------\|--------------------------------------\|-------------------------------\|---------------------------\| \| Sevenoaks: Buckhurst No. 2 car park \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays (but excluding Bank Holidays) \| 24 hours \| Up to 1 hour: £1.00 1 to 2 hours: £1.80 2 to 3 hours: £2.50 3 to 4 hours: £3.50 All day: £4.40 \| \| \| \| \| \| 8.30 am to 6.30 pm Saturdays only \| 24 hours \| No return within 2 hours \| \| \| \| \| \| 6.30 pm to 9.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 6½ hours from 6.30 pm to 1.00 am the following day \| Up to 3 hours: £1.00 \| \| \| \| \| \| Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 24 hours \| Season tickets (spaces are not reserved): 1 year: £839 3 months: £219.75 \| \| \| \| \| \| \| \| Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250. \| \| Location and name of parking place \| Position in which vehicle may wait \| Class of vehicle permitted to park \| Hours when parking place is available \| Hours of operation of parking charges \| Maximum period vehicles may wait \| Scale of parking charges \| \|-----------------------------------\|----------------------------------\|----------------------------------\|--------------------------------------\|-------------------------------------\|-------------------------------\|--------------------------\| \| Sevenoaks: Council Offices Gordon Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| 8.30 am to 6.30 pm Saturdays \| Not applicable \| 10 hours \| No charge \| \| Sevenoaks: Holmestadale Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| No charge \| \| Sevenoaks: Pembroke Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| Up to 1 hour: £1.00 1 to 2 hours: £1.80 2 to 3 hours: £2.50 3 to 4 hours: £3.50 \| All day: £4.40 \| \| Sevenoaks: St James Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 6.30 pm to 9.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| Up to 3 hours: £1.00 \| Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250. \| \| \| \| \| \| 6½ hours from 6.30 pm to 1.00 am the following day \| Up to 30 minutes: 20p 30 minutes to 1 hour: 40p 1 to 2 hours: 60p 2 to 4 hours: £1.00 \| All day: £3.10 \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|-------------------------------------\|-----------------------------------\|----------------------------------------\|--------------------------------------\|-------------------------------\|---------------------------\| \| Sevenoaks: St. Johns Hill car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 2 hours \| Up to 30 minutes: 20p 30 minutes to 1 hour: 40p 1 to 2 hours: 60p \| \| Sevenoaks: Sennocke car park \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| All hours \| 10.00 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 24 hours \| Residents’ annual permits: first permit £25, second permit £10, third permit £125, fourth permit £250. \| \| \| \| \| \| 10.00 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 24 hours \| Season tickets (spaces are reserved from 1.00 am until 10.00 am only): 1 year: £1,130 3 months: £292.50 \| \| \| \| \| \| 3.00 pm to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 15 hours between 10.00 am and 1.00 am the following day \| Up to 2 hours: £1.00 All day: £6.80 \| \| \| \| \| \| 8.30 am to 1.00 am the following day \| 10 hours between 3.00 pm and 1.00 am the following day \| Up to 3 hours and 30 minutes: £1.50 \| \| \| \| \| \| 8.30 am to 6.30 pm Saturdays \| 15 hours between 10.00 am and 1.00 am the following day \| Up to 2 hours: £1.00 All day: £6.80 \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|------------------------------------\|-----------------------------------\|----------------------------------------\|--------------------------------------\|-------------------------------\|---------------------------\| \| Sevenoaks: Sennocke car park (continued) \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| 8.30 am to 1.00 am the following day \| 10 hours between 3.00 pm and 1.00 am the following day \| Up to 3 hours and 30 minutes: £1.50 \| Up to 1 hour: £1.00 1 to 2 hours: £1.80 2 to 3 hours: £2.50 3 to 4 hours: £3.50 \| \| Sevenoaks: South Park car park (including the Stag theatre parking area) \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| All hours \| 4 hours (during the charging hours) No return within 2 hours \| Season tickets (spaces are not reserved); 1 year: £839 3 months: £219.75 Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250. \| Up to 1 hour: £1.00 Up to 3 hours: £1.00 \| \| Sevenoaks: Suffolk Way car park \| Wholly within a parking bay where so defined \| Motorcars, motor cycles and combinations; and invalid carriages \| All hours \| 6½ hours from 6.30 pm to 1.00 am the following day \| Up to 1 hour: £1.00 1 to 2 hours: £1.80 2 to 3 hours: £2.50 3 to 4 hours: £3.50 \| Up to 1 hour: £1.00 Up to 3 hours: £1.00 \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|-------------------------------------\|-----------------------------------\|----------------------------------------\|--------------------------------------\|-------------------------------\|---------------------------\| \| Shoreham: Filton Lane car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| No charge \| \| Swainley: Bevan Place car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 2 hours No return within 1 hour \| Up to 30 minutes: 20p 30 minutes to 1 hour: 40p 1 to 2 hours: 60p \| \| Swainley: Park Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 2 hours No return within 1 hour \| All day: £3.90 \| \| \| \| \| \| \| 2 to 4 hours: £1.00 \| \| \| \| \| \| \| \| Reserved bay: 1 year: £396 3 months: £109 Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250. \| \| \| 1 Location and name of parking place \| 2 Position in which vehicle may wait \| 3 Class of vehicle permitted to park \| 4 Hours when parking place is available \| 5 Hours of operation of parking charges \| 6 Maximum period vehicles may wait \| 7 Scale of parking charges \| \|-------------------------------------\|-------------------------------------\|-----------------------------------\|----------------------------------------\|--------------------------------------\|-------------------------------\|--------------------------\| \| Swaneley: Park Road car park (continued) \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Mondays to Fridays \| 24 hours \| Residents' annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250 \| \| Swaneley: Station Road car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 2 hours \| Up to 30 minutes: 20p 30 minutes to 1 hour: 40p 1 to 2 hours: 60p \| \| Swaneley: White Oak Indoor Bowls Centre car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 1.00 am the following day \| 4 hours \| No return within 1 hour \| \| Swaneley: White Oak Leisure Centre car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| Not applicable \| 24 hours \| All day: £3.90 \| \| Westerham: Darent car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Fridays inclusive (but excluding Bank Holidays) \| 4 hours \| No return within 2 hours \| \| \| \| \| \| \| \| Up to 3 hours: no charge 3 to 4 hours: £1.20 \| \| Location and name of parking place \| Position in which vehicle may wait \| Class of vehicle permitted to park \| Hours when parking place is available \| Hours of operation of parking charges \| Maximum period vehicles may wait \| Scale of parking charges \| \|-----------------------------------\|----------------------------------\|----------------------------------\|--------------------------------------\|-------------------------------------\|-------------------------------\|--------------------------\| \| Westerham: Darent car park (continued) \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8.30 am to 6.30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 16½ hours \| All day: £3.10 Season tickets: 1 year: £50 3 months: £12.50 Residents annual "joint use" permit for The Green, Westerham and this car park: 1 year: £50 3 months: £12.50 No charge for motorcycles, combinations and invalid carriages Residents' annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250. \| \| \| Wholly within a parking bay where specifically defined for that class of vehicle \| Scheduled local service bus \| All hours \| Not applicable \| 2 hours \| No charge \| \| \| \| Coach \| All Hours \| Not applicable \| 16½ hours \| No charge \| \| Location and name of parking place \| Position in which vehicle may wait \| Class of vehicle permitted to park \| Hours when parking place is available \| Hours of operation of parking charges \| Maximum period vehicles may wait \| Scale of parking charges \| \|-----------------------------------\|----------------------------------\|----------------------------------\|--------------------------------------\|-------------------------------------\|-------------------------------\|--------------------------\| \| Westerham: Quebec Avenue car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8:30 am to 6:30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 16½ hours No return within 2 hours \| Up to 15 minutes: 10p 15 minutes to 30 minutes: 20p 30 minutes to 1 hour: 50p 1 to 2 hours: 70p 2 to 4 hours: £1.20 All day: £3.10 Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250 \| \| Westerham: Vicarage Hill car park \| Wholly within a parking bay where so defined \| Motorcars; motor cycles and combinations; and invalid carriages \| All hours \| 8:30 am to 6:30 pm Mondays to Saturdays inclusive (but excluding Bank Holidays) \| 2 hours No return within 1 hour \| Up to 15 minutes: 10p 15 minutes to 30 minutes: 20p 30 minutes to 1 hour: 60p 1 to 2 hours: £1.50 Residents’ annual permits: first permit £35, second permit £70, third permit £125, fourth permit £250 \|	<urn:uuid:231feddd-6126-4d2d-9b6e-809d9a69d1da>	CC-MAIN-2020-45	https://tro.trafficpenaltytribunal.gov.uk/TRO/Sevenoaks/SV42.pdf	2020-10-20T11:14:05+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-45/subset=warc/part-00129-6409130e-6e9b-44d1-90ec-9f9d0ade2504.c000.gz.parquet	589,047,098	4,311	eng_Latn	eng_Latn	0.986605	eng_Latn	0.994212	[ "eng_Latn", "unknown", "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "unknown", "unknown", "eng_Latn", "unknown" ]	false	docling	[ 1180, 2674, 3896, 5305, 7143, 9625, 11371, 13374, 15327, 16676, 18174 ]
Browns of BRITTANY In the mood for a family trip to France where you can catch pretty wild browns like this? Peter Gathercole explains all... » Brittany has long been known as a popular destination for holidaying Brits. But perhaps less well known is that it’s an ideal place to mix a family break with some very enjoyable trout fishing, especially if your thing is casting a fly rod and catching brown trout from clear streams. The advantage being that when family duties call, the stunning Brittany coast is only a short drive away. There are a number of rivers and streams in Brittany that support excellent populations of wild brown trout, including one I fish last summer. The river in question, the Elorn, is noted as one of the best wild trout rivers in western France, both for the size of its fish and their number. Trout over 10 inches (40cm) are not uncommon anywhere than anywhere else in Brittany and you can hone your angling skills with fish up to 20 inches (50cm). The river not only supports a healthy population of wild brown trout but also enjoys runs of Atlantic salmon. While the numbers of salmon aren’t huge they’re substantial enough to make the chance of catching one a possibility, especially during the spring and then again from late summer into the autumn. The Elorn is a gentle, easy-going kind of river – no big rocks to trip the unwary though it still requires a reasonable level of skill to gain full enjoyment from it and certainly requires that the visiting angler already has some understanding of how to fish running water. My guide for the trip My host and fishing companion for my visit was the ever-helpful Philippe Delivet. Philippe has been guiding in France, Ireland and latterly in the UK for almost 30 years. At one time, he was editor of French angling magazine Plaisir de la Peche, but since the title’s demise he’s been working full time as a guide and instructor, teaching a steady flow of anglers how to fish for trout and saltwater bass. As on any small stream, a combination of a stealthy approach and short accurate casts is the key to success here. Philippe quickly lets me know how to do this on any stream, especially when trying to catch the bigger fish. If you’re thinking of fishing the Elorn, remember to take a pair of waders. It’s an intimate little river, in parts heavily tree-lined – its grassy banks dotted with ferns and foxgloves. In the flow swirling through the trees there’s always some to prolific insect life, forming channels where the trout hold in the current picking off a steady stream of hatching insects. It’s shallow and easy to wade. Light lines and tippets are required and an accurate cast, too, as the fish are often found tucked into small pockets in the weed or under the shadow of overhanging branches. Chosen flies Dry fly fishing is the most successful method, especially during the height of summer where profuse beds of stewart and ranunculus make fishing a weighted fly tricky. On the Elorn, small flies are a must and during the height of summer – 16s, 18s and even the odd 20 are the most effective sizes, the flies themselves tied to represent the Elorn’s insect life. Olives, stoneflies and sedges provide the bulk of the trout’s food and this is reflected in the patterns that Philippe uses regularly. These include a small CdC Olive Dun with a V-shaped wing usually tied on a size 18 or 20 hook. When the fish are taking small caddis pupae, a simple Florian Drag Cannelle Cinnamon Caddis is very effective while another Florian Stephan-inspired pattern – the Olive Emerger – works extremely well when trout are taking something tiny right on the surface. About the Elorn The river feeds the Lac du Drennée, a 270-acre expanse of water stocked with rainbow trout and offers some great flyfishing opportunities. The river doesn’t end there though, for the Elorn re-emerges at the dam on the lake’s western shore. From there it flows towards the town of Sizun and then on to the estuary at Brest. Perhaps due to the reason that the Elorn’s middle section has the advantage of being kept at a stable temperature so that, even during the height of summer the water remains cool and clear when other similar-sized rivers are struggling. This makes it an ideal location for any angler wanting to mix a family summer holiday with a spot of fishing. During my visit, we concentrate on the middle section, the more overgrown part. The lower river is 16km in length meandering its way between the towns of Landivisiau and Landerneau. It’s more than than the stretch we fish and is where he normally takes anglers he’s guiding or teaching. Interestingly it’s only possible to fish the Elorn on certain days of the week – these are Saturday, Sunday, Monday and Wednesday. The logic behind this restriction is simply to give the river and its trout a chance to recover after anglers begin to help conserve its stocks. For the visitor, this shouldn’t be an issue for there are a number of other rivers that can be fished along with the Elorn and Lake. Carefully working our way upstream we often spot a nice trout sitting in a tricky place confidently sipping down small olives. Getting the fly to drift drag-free through the current before the trout is caught on an overhanging branch, is easier said than done; however, the satisfaction achieved when the fly lands delicately in just the right position and is taken with confidence as it drifts over the fish more than makes up for all the frustration. The Elorn’s wild browns In the main they’re handsome, chunky little fish, golden-flanked with... numerous large spots – some black, some red ringed with white. They also fight well above their weight. While most of the trout on the Elorn are around 8-10 inches there’s no shortage of fish of something pushing 18 inches or so – if you have the skill and a bit of luck on your side. Past glories Philippe tells me that in Brittany there’s the often-used saying that goes something like, “big weather, big fish.” Indeed, when trying to catch fish on the Elorn, nothing beats typical ‘Breton’ weather with cloudy skies, a light drizzle and moderate temperatures. Even plain old rain is acceptable as long as there’s not enough to cause the river to rise and colour up. He remembers one particularly successful day last year, very cold but humid when the better Elorn trout fed. As Philippe put it: “A day when you wouldn’t want your dog to venture outside – but nevertheless I managed to tempt close to a dozen very pretty fish, the best measuring just shy of 16 inches.” He recalled that: “The river seemed asleep except for some better noises poking through the surface film, sucking in tiny grey mayflies. I spent the better part of the day fishing seven or eight trout lies, ones that I was confident would hold good fish. I made about 25 casts in all, less than 20 casts that day but each was with the utmost stealth and care and as close as possible to the fish, optimising both presentation and hooking.” Philippe is almost evangelical about this stealthy approach. As he points out, when trying to catch the bigger fish, wading too aggressively can often induce a fish-scaring wave. Even if that’s not the case, it’s still easy to scare smaller fish, which will retreat upstream and in turn spook the larger trout that simply melt away under cover. The importance of stealth His advice is that if you do manage to get within casting range of a good fish, don’t cast straight away. Instead take a moment to assess the situation. For example, you’ll need to know if the fish is holding station or working across the current and how often it’s rising. What’s also important is judging what the fish is likely to do if hooked. With any small, blind river there’s plenty of submerged roots by which a trout can make its escape. Even a medium-sized Elorn can be hazardous and having a plan of attack skews the odds of landing a bigger fish more in your favour. So, dry your fly, check the leader then watch what’s happening. Do you have a clear view of the fish? Are you close enough to get perfect presentation? Take my word for it, if you’re ever lucky enough to fish the Elorn, especially along the lovely camped middle section and come across one of its bigger wily trout then you’ll do well to heed this advice. --- FACTFILE The River Elorn For guiding and boats for all local waters – Philippe Dolivet, Brittany Fly Fishing. CONTACT: +33(0)642039366 WEB: www.brittanyflyfishing.com EMAIL: [email protected] Accommodation: David & Ben Kergudon Gites, www.kergudongites.com Tel.: +33(0)298241888 Email: [email protected]	<urn:uuid:6fe500d4-0209-4823-98f5-50b450c095a4>	CC-MAIN-2019-04	http://www.brittanyflyfishing.com/wp-content/uploads/2017/12/brittany.pdf	2019-01-17T23:14:48Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-04/segments/1547583659417.14/warc/CC-MAIN-20190117224929-20190118010929-00631.warc.gz	267,819,812	1,911	eng_Latn	eng_Latn	0.998664	eng_Latn	0.998367	[ "eng_Latn", "eng_Latn", "eng_Latn" ]	true	docling	[ 144, 5624, 8717 ]
THE ETHICS OF WILLIAM PALEY Charles Trentham, B.A., Th. M., Th. D. May, 1952 A Dissertation Submitted to the University of Edinburgh in Candidacy for the Degree of Doctor of Philosophy To My Mother, My First Teacher in Christian Ethics # TABLE OF CONTENTS \| Chapter \| Page \| \|------------------------------------------------------------------------\|------\| \| Preface \| 1 \| \| Chapter \| \| \| I. The Life of William Paley \| 1 \| \| II. The Theological and Philosophical Environment of Paley \| 30 \| \| 1. The Religious Conditions in Eighteenth Century England \| 30 \| \| (1) Rationalism \| 30 \| \| (2) Naturalism \| 33 \| \| (3) Scepticism \| 35 \| \| 2. Paley's Theology \| 40 \| \| (1) His Doctrine of God \| 40 \| \| (2) His Cosmology \| 41 \| \| (3) His Doctrine of Man \| 53 \| \| (4) His View of Miracles \| 62 \| \| (5) His Doctrine of Rewards and Punishments \| 68 \| \| (6) His Defense of Historical Christianity \| 70 \| 3. The Philosophy of Eighteenth Century England 78 (1) The New Freedom 80 i. The Contribution of Francis Bacon 80 ii. The Contribution of Thomas Hobbes 81 iii. The Contribution of Ralph Cudworth 83 iv. The Contribution of Richard Cumberland 83 v. The Contribution of John Locke 85 vi. The Contribution of Samuel Clarke 88 vii. The Contribution of the Deists 89 viii. The Contribution of Lord Shaftesbury 94 (2) The General Moral Conditions Before Paley 98 III. An Exposition of the Principles of Paley's Ethics 100 1. How the Moral Duty is Known 103 (1) Hobbes' View 104 (2) Shaftesbury's View 112 (3) Bishop Butler's View 114 (4) Paley's View 119 i. The Inadequacy of the Law of Honor 120 ii. The Inadequacy of the Law of the Land 121 iii. The Inadequacy of the Scripture 123 iv. The Inadequacy of Moral Sense 128 2. The Theological Sanction . . . . . . . . 149 3. The Motive Behind Moral Behavior . . . . 155 (1) Paley's Definition of Happiness . . . . 157 (2) Objections to the Principle of Hedonism . 166 4. The Principle of Moral Obligation . . . . 173 (1) The Meaning of Obligation . . . . . . 175 (2) Objections to this Definition . . . . . 178 5. How May We Ascertain the Will of God? . . . 181 (1) The Declarations of Scripture . . . . . 181 (2) The Light of Nature . . . . . . . . . 182 IV. The Application of Paley's Ethics . . . . . 192 1. The Relative Duties . . . . . . . . . . 194 (1) Determinate Duties . . . . . . . . . 194 i. The Use of Property . . . . . . . 194 ii. Oaths . . . . . . . . . . . . . . 196 iii. Subscription to the Articles of Religion . . . . . . . . . 197 (2) Indeterminate Duties . . . . . . . . 206 i. Slavery . . . . . . . . . . . . . . 206 (3) Duties Which Result from the Constitution of the Sexes . . . . . . . . . 211 i. Marriage . . . . . . . . . . . . . 211 ii. Fornication . . . . . . . . . . . 213 \| Section \| Page \| \|------------------------------------------------------------------------\|------\| \| iii. Seduction \| 213 \| \| iv. Adultery \| 214 \| \| v. Divorce \| 215 \| \| 2. Duties to Ourselves \| 216 \| \| (1) Self-defense \| 217 \| \| (2) Temperance \| 217 \| \| (3) Suicide \| 219 \| \| 3. Duties Towards God \| 221 \| \| (1) Prayer \| 221 \| \| (2) Sabbath Observance \| 225 \| \| (3) Reverencing the Deity \| 229 \| \| V. An Evaluation of Paley's Ethics in Contrast With Current Christian Ethics \| 230 \| \| 1. An Evaluation of Paley's Principles \| 230 \| \| (1) The Utilitarian Principle \| 230 \| \| (2) Hedonism \| 234 \| \| 2. The Theological Aspects of Paley's Ethics \| 238 \| \| (1) The Relation of Religion to Ethics \| 239 \| \| (2) The Place of Revelation in Ethics \| 254 \| \| (3) The Place of Reason in Ethics \| 261 \| \| (4) The Place of Eschatology in Ethics \| 273 \| \| Bibliography \| 287 \| During the period when the eighteenth century was merging into the nineteenth, William Paley was regarded as the outstanding apologist of the Christian religion in England. So conclusive was his work considered to be that one reviewer could write the following: We regard Dr. Paley's writings on the "Evidences of Christianity" as of so signally decisive a character that we could be content to let them stand as the essence, and the close of the great argument, on the part of its believers; and should feel no despondency or chagrin, if we could be prophetically certain that such an efficient Christian reasoner would never henceforward arise. The above was written in the year 1809. Since then Paley has been largely forgotten. The average student knows about him only this: that he was called "Pigeon" Paley and that he used some sort of analogy about a watch. To the writer it appeared that a rediscovery of Paley might offer to the modern reader some values that were greatly admired in the eighteenth century. --- 1 Eclectic Review. Vol. V, part 1, p. 1. Even Paley's arch-foe, Professor Adam Sedgwick, admitted that "Paley did more for revealed truth than any writer of his country."¹ Paley is best known as an apologist of the Christian religion; however, he was also highly honored in his day as a moralist. The historian, W.E.H. Lecky, commenting on Paley's Moral and Political Philosophy, writes: It has been, I think, the fortune of this work to be of late years very unduly depreciated, partly because in consequence of the singular charm and lucidity of its style, it has been so widely read, studied, and criticized that all its weak-points have been fully disclosed and partly because the particular type of its utilitarian theory of ethics which it teaches has been generally abandoned. It is, however, both in form and substance one of the masterpieces of the eighteenth century.² W. R. Sorley has observed that "probably no English writer has ever excelled Paley in the power of marshalling argument or in clearness of reasoning."³ Ueberweg refers to the almost undisputed sway which was held by Paley's Moral Philosophy for nearly fifty years.⁴ This work was for many years the text --- ¹ A Discourse on the Studies of the University of Cambridge, p. 56. ² A History of England in the Eighteenth Century, Vol. V, p. 171. ³ A History of English Philosophy, p. 201. ⁴ History of Philosophy, Vol. II, p. 391. book at Cambridge University. Twenty-one editions were printed, and it was translated into German by Garve in 1787. At the University of Cambridge the public examination in the senate house for the B.A. degree was based on one of the four Gospels or the Acts of the Apostles in the original Greek, Paley's Evidences of Christianity, one of the Greek and one of the Latin Classics.$^1$ Leslie Stephen offers it as his opinion that Paley is unsurpassed as a writer of text books.$^2$ When Cardinal Manning was over seventy, he wrote concerning his youthful study of Paley's Evidences, "I took in the whole argument and I thank God nothing has ever shaken it."$^3$ Several instances of Paley's repute as a moralist in his own generation appear on the pages of history. For example, when Lord Erskine was pleading before Lord Ellenborough and a special jury in the Court of Kings Bench, December the twenty-third, 1803, he stated: --- $^1$ The Works of William Paley, D.D. (Edmund Paley, editor), Vol. I, p. CLXXI. $^2$ Dictionary of National Biography, Vol. XLIII, p. 105. $^3$ Strachey, Lytton, Emminent Victorians, p. 6. That he should advise every one wishing to become wiser and better to read a work lately published by Dr. Paley, in which the elegant writer, and excellent man, made the whole creation raise one general chorus to the God of Heaven and earth. While asserting the claims of the Roman Catholics of Ireland to a full and complete toleration, Mr. Fox referred several times to Paley's Moral and Political Philosophy and stated that Paley's authority: Would have great weight, not only in the House, but with all thinking men in the country, whose opinions no man who valued genius, no man who valued learning, no man who valued moderation could hear without deference and respect. The works of Paley were important enough to attract the attention of King George III. A letter written to Paley from a friend describes the King's concern over having lost his copy of Paley and his determination to send for another immediately. The letter states that "he (the King) thinks it a very useful, valuable publication." --- 1 Meadley, G. W. Memoirs of William Paley, D.D., p. 208. 2 Ibid., pp. 250, 251. 3 Paley, Edmund. The Life of Dr. Paley, pp. CCLVIII, CCLIX. The period in which Paley wrote is more noted for its moral philosophy than for its religion. Paley's importance in this field is reflected in the fact that he was the leading exponent of the ethical theory known as Theological Utilitarianism. This theory sets forth much that was typical in eighteenth century English ethics. Not only did this theory make a strong contribution to the moral and religious philosophy of the eighteenth century but the writer believes that it is still at work in a vast segment of American Christianity today. It is the purpose of this thesis first to discover the source of Paley's ethics. An attempt will then be made to isolate Paley's philosophy from the general stream of eighteenth century thought in order that his own unique contribution might be determined. Following this an exposition of Paley's ethical system will be given and the final chapter will be devoted to a critical evaluation of his ethics. In the biographical section of the thesis a brief sketch of Paley's life along with those incidents in his life that are germane to his ethics will be offered. It will be observed also that in spite of the fact that ethics and political philosophy were often combined in Paley's day, it does not lie within the scope of this thesis to treat his views on politics except as they affect his ethics. In common with his generation, Paley shared an aversion to metaphysics. He views ethics primarily as an actual working force in life. Little attention, therefore, will be given to metaphysics in this thesis. It is generally acknowledged that eighteenth century English thought was very largely free from continental influences. Sidgwick reminds us that "for the century and a half that intervenes between Hobbes and Bentham the development of English ethics proceeds without receiving any material influence from foreign sources."¹ This result in English thought appears only in the field of ethics. Descartes had been much studied in England by students of physics and psychology. His metaphysical system was the most important antecedent of Locke's. However, Descartes hardly touched ethics proper. It should be remembered also that Clarke's controversy with Spinoza and Leibnitz was purely in the realm of metaphysics and will not be mentioned here. American spelling is used throughout the work except when an author's own words are quoted. ¹ Sidgwick, Henry. Outlines of the History of Ethics for English Readers, p. XXIII. Words of warmest appreciation are due and gratefully given to Professor W. S. Tindal of the Department of Ethics in New College and Professor John Macmurray of the Department of Moral Philosophy in the University of Edinburgh for their invaluable assistance to the writer; to President E. D. Head and to my colleagues of the Faculty of Southwestern Baptist Theological Seminary, who have cooperated in granting me a leave of absence from my teaching responsibilities that I might pursue this study. CHAPTER I BIOGRAPHY OF WILLIAM PALEY William Paley was born at Peterborough in Yorkshire, England, in July of 1743. He was the descendent of a long line of sturdy North country yeomen. His father, William Paley, was believed to be one of the oldest incumbents on one and the same vicarage in the diocese and perhaps in England, having served for fifty-six years as vicar of Helpstone. He was chiefly known, however, as a school-master, teaching until he was eighty-three years of age, and was considered a very good classical scholar. The senior Paley was appointed Headmaster of Giggleswick School to which he moved his family in 1745. As young Paley grew up, he was educated under his father's care. He manifested something of his ambition as well as his quickness of wit in his childhood when on being scolded by his mother, who finished with "God give thee grace," he replied, "Ay, mother, Grace o' God and Grace o' Canterbury will do for me."¹ ¹ Paley, Edmund. Life of Dr. Paley, p. XXVI. In November, 1758, Paley was admitted as a sizar of Christ's College at Cambridge. In 1759, at the age of sixteen years, he became a resident member of Christ's College. On the evening after taking leave of his son, the elder Paley remarked to a pupil, "My son is now gone to college,—he'll turn out a great man—very great indeed,—I'm certain of it, for he has by far the clearest head I ever met with in my life."¹ Because of his vast knowledge of mathematics, young Paley was excused from attending the lectures of the tutor in mathematics. At Christ's College he attended Mr. Backhouse's lectures in logic, metaphysics and moral philosophy, in which the doctrines of Locke, Clarke and Hutcheson were principally discussed. While conversing with a friend at Cambridge on the early part of his academical life, Paley related the following: I spent the first two years of my undergraduateship happily, but unprofitably. I was constantly in society, where we were not immoral, but idle and rather expensive ¹ Meadley, George W., Memoirs of William Paley, p. 9 At the commencement of my third year, however, after having left the usual party at rather a late hour in the evening, I was awakened at five in the morning by one of my companions, who stood at my bedside and said, 'Paley, I have been thinking what a d____d fool you are. I could do nothing probably were I to try, and can afford the life I lead: you could do everything, and cannot afford it. I have had no sleep during the entire night on account of these reflections, and am now come solemnly to inform you that if you persist in your indolence, I must renounce your society.' I was so struck, Dr. Paley continued, with the visit and the visitor, that I lay in bed a great part of the day and formed my plan. I ordered my bed-maker to prepare my fire every evening, in order that it might be lighted by myself. I arose at five; read during the whole of the day, except during such hours as Chapel and hall required, allotting to each portion of time its peculiar branch of study; and just before the closing of the gates (nine o'clock) I went to a neighbouring coffee-house, where I constantly regaled upon a mutton chop and a dose of milk punch. And thus on taking my bachelor's degree I became a senior wrangler. Paley became senior wrangler in the year 1763. In preparing him for this honor his course of reading was sketched out for him by Mr. Thorp, fellow of Peterhouse, the senior wrangler in 1758; Mr. Wilson, a bachelor of the same College; and Dr. --- 1 Paley, William. The Works of William Paley, D.D. p. XXIII. Waring, fellow of Magdalen College and Lucasian professor of mathematics. Besides metaphysics, morals, the four branches of natural philosophy and Newton's Principia, the course extended to the most abstruse parts of algebra and fluxions. Paley's mind was so formed that in his reading he could rapidly select the kernel and throw away the husk. "In the estimation of Dr. Waring and Mr. Thorp, he was superior, not only to every man of his year, but even to several of his examiners."¹ On June 24th, 1766, Mr. Paley was elected a fellow on the foundation of Christ's College, and at the ensuing commencement completed his degree of Master of Arts. In the University Mr. Paley was held in high esteem as a lecturer. His method was to open the period by questioning some of his pupils on every point of the preceding lecture. After such preliminaries he would proceed to discuss some subject in Locke or Clarke, or in moral philosophy, revealing by his manner his sincere delight in such employment. ¹ Ibid. At the beginning of the students' first year Paley gave his lectures on Locke which included a brief sketch of logic and the rules to be observed in disputation using Locke's Essay on Human Understanding as a text book. This would be followed by discussions of Clarke On the Being and Attributes of God. Paley's method was first to present Clarke's argument, then to correct his errors and finally to enforce his argument by more conclusive reasoning of his own. These lectures anticipated much of what afterwards was advanced in his Natural Theology on the wisdom, power and goodness of the Deity and were concluded with a summary of all the arguments that can be urged on the probability of a future state from the light of nature alone. For the students' third year Paley offered his moral lectures which were later expanded into his Moral and Political Philosophy. He lectured to all the undergraduates on the Greek New Testament. His method was to explain Scripture by Scripture. His model seems to have been Locke On the Reasonableness of Christianity and On the Epistles. The chief points insisted upon by Mr. Paley to his pupils were that they should listen to God, and not to man; that they should free themselves, as much as possible, from all prejudices of birth, education and country; and that they should not call any one their master in religion, but Christ. His Greek New Testament from which he lectured, was filled with critical and explanatory notes. These explanations apparently came from Bowyer's Conjectures on the New Testament. The notes are consistent with the design which appears on the first page of his lecture book which is as follows: "Points to be explained—Heb. phraseology—ways of reasoning—accomodation of prophecies—proverbs—explanation of customs." To his pupils who had taken their first degree, Paley offered a course of lectures in divinity which contained the substance of what he afterwards gave to the world in his Evidences on Christianity, and the germ of the still greater argument on the same subject, developed in his Horae Paulinae. For supplementary reading in this course he suggested Collyer's Sacred Interpreter, especially the former part of the second volume; Harwood's Introduction, volume I; the Dissertations --- 1 Universal Magazine, Nov., 1805, N.S. Vol. IV, p. 416. prefixed to Macknight's Harmony; Godwin's Jewish Antiquities, or rather Jenning's Lectures upon the work; and Law's Reflections on the Life and Character of Christ. For commentaries he suggested that students supply themselves with Hammond by Le Clerc; Lightfoot's Works upon the Respective Gospels, especially his Horae Hebraicae; Bowyer's Conjectures on the New Testament; Jebb's, or any other Harmony; Wetstein's edition of the Greek Testament, 12 mo., 1711; Parkhurst's Lexicon and Clarke's Paraphrase. Benson's History of the Christian Religion, Schmidius' Concordance for the New Testament and Trommius' for the Septuagint, the folio edition of Wetstein for quotation from profane authors, the English Concordance of Cruden, Conant's Sermons, Limbarch's De Religione Christiana, Enfield's Preachers' Directory, Rutherford's Institutes of Natural Law, Doddridge's Family Expositor and Search's Light of Nature Pursued. Paley possessed very little physical vigor. On being told of the death of a school fellow, he said he did not much wonder, for he was the only boy in the school he ever did or ever could thrash. Yet for all his lack of physical stamina, Paley was possessed of a strong personality which made him a delightful member of many circles: He was the incarnation of strong common sense, full of genial good humour, and always disposed to take life pleasantly. As a Lawyer, the profession for which he thought himself suited, he would probably have rivalled the younger Law, who became Lord Ellenborough. He had no romance, poetic sensibility or enthusiasm but was thoroughly genial and manly. He was a very affectionate father and husband and fond, like Sydney Smith, of gaining knowledge from every one who would talk to him. The phrases about his conscience—he said on one occasion that he couldn't afford to keep a conscience$^1$—and others, often quoted to prove his cynicism, seem rather to show the humorist's tendency to claim motives lower than the true ones.$^2$ He was utterly frank and free from deceit. When asked on one occasion why he quit his position at Dalston, he answered: Why, Sir, I had two or three reasons for taking Stanwix in exchange; first, it saved me double housekeeping, as Stanwix was within a twenty minutes walk of my house in Carlisle; --- $^1$ Universal Magazine, December, 1805, N.S. vol. iv, p. 511. $^2$ Stephen, Leslie. Dictionary of National Biography, Vol. XLIII, p. 105. secondly, it was fifty pounds a year more in value; and thirdly, I began to find my stock of sermons coming over again too fast. Remarks like the above may have been responsible for the charges that were brought against Paley's character. One writer contrasts Paley's character with such Puritan divines as Baxter, Howe, and Philip Henry, observing that he fails to find in Paley their deep devotion to Christ, their zeal for the promotion of Christianity, and their indifference to emoluments. Paley's love for the theater and games was well known. His critics held that it was not becoming to a Christian pastor to be pushing into theaters and whist parties, insisting that it was an unpardonable inconsistency to be so convinced of the truth of Christianity and yet to share so little of the spirit of its Founder. It is true that if a man looks for something of the characteristics of the Apostles in Paley, he will be disappointed and must be content to find a good respectable man of the world. Yet it should not be forgotten that he was enough of a crusader to sacrifice his chance of an ecclesiastical promotion by crusading --- 1 The Works of William Paley, D.D., p. XVIII. 2 Clarkson, Thomas. History of the Abolition, Vol. I, p. 465. for religious liberty$^1$, and that he was a strong leader against slavery.$^2$ It is also true that one of Paley's greatest sermons was written as an appeal to clergymen to care for their reputation, to strengthen their character and deepen their own devotional lives. This sermon was preached before the University of Cambridge in completion of his exercises for his Doctor's Degree. The charge that Paley was too much interested in material emoluments is diminished in the face of the fact that when he was provided with one of the best parsonage houses in the kingdom, he granted his parishioners a lease of the titles that were rightfully his for his life. In his Moral Philosophy he had represented titles as injurious to cultivation and improvement; and he now acted, as far as circumstances would permit, in conformity to his opinions.$^3$ As the produce of the land was considerably augmented in price soon after this period, --- $^1$ Paley, William. Sermons on Public Occasions, p. 603. $^2$ Paley, William. The Works of William Paley, D.D., p. XIX. $^3$ Ibid. p. 12. and the value of the landed property in general was tremendously advanced, Dr. Paley's tenants became very prosperous. Their prosperity was a source of abiding satisfaction to Dr. Paley, nor did he give evidence of disappointment over the opportunities of gain which he had given away. In one of his jovial moods Paley once said that "a man who is not sometimes a fool, is always one."¹ This sentiment was probably taken from Locke who was of the opinion that in order to employ one part of life in serious and important occupations, it is necessary to spend another in mere amusements. Paley's very careless manner of dress gave rise to a proverbial remark, long traditional in the College, "You may be a sloven, but don't think you are a Paley." Paley did not pursue either mathematical or metaphysical learning any farther than suited his office of tutor for he viewed these subjects as being of value only insofar as they opened and prepared the mind for more useful studies. ¹ Meadley, G. W. Memoirs of William Paley, D.D., p. 12. His love for disputation caused him on several occasions to choose a less favored side that he might make it appear more favorable. He often succeeded in showing his love for an independent way of thinking. In 1765, Paley received the Bachelor's prize, which was given annually at Cambridge for the best essay in Latin prose. His essay was on the subject, "Utrium civitati perniciosior sit Epicuri an Zenonis philosophia" in which he championed the cause of the Epicureans against the Stoics. Desiring in this essay to expose what he considered as hypocrisy in Stoicism he called them "those Pharisees in Philosophy." He accounted for the popularity of Zeno by contending that he was a politician who preached the all-sufficiency of virtue to complete human happiness which, according to Paley, had always been a note that ministered to the pride of men. He speaks against Zeno's condemnation of public worship, condemns his cynical language, and his promiscuous concubinage. He contends that Epicurus gave sanction to no vicious indulgence, while the disciples of Zeno, though affecting an elevation of virtue inconsistent with human nature, too often, in their practice, descended to the most flagrant of crimes. His independence of thought is seen as he argues against Zeno's lofty ideals and contends that: There is not perhaps a more effectual way of injuring the cause of virtue than by straining its duties too high. The bulk of mankind will easily persuade themselves that virtue, this ideal virtue, was never designed for ordinary practice, but to be confined to a few more elevated natures and sublimer views. Paley devoted much more of his essay to exposing the errors of Stoicism than he did to expounding the virtues of Epicurus. It cannot, therefore, as some have contended, be conclusively argued that Paley was greatly influenced by the ethics of Epicurus. At the end of his essay Paley added a note declaring: The intent of this inquiry is not so much to defend the principles of either sect, as to prove the insufficiency of both. For neither the welfare of the public is promoted, nor the happiness of the individual secured by either. Their apprehensions of the nature of God, and of the ends of virtue, are both erroneous, and their errors are both attended with pernicious consequences. Zeno fell into the most fantastic superstitions, which whilst Epicurus corrected he well nigh endangered religion. The virtue of the one was visionary and ideal, that of the other sordid and selfish. It was reserved for one greater than Zeno to exalt --- 1 Paley, Edmund. The Life of Dr. Paley, p. XLVIII. the dignity of virtue with its utility, and by super-inducing a future state to support the paradox of the Stoic on Epicurean principles.\textsuperscript{1} Concerning Paley's mind it is said, "He never forgot the use of his understanding, nor was solicitous to show what he knew more than what he thought. He never reasoned from memory or spoke from quotation."\textsuperscript{2} In his moral philosophy he brings his argument to the level of common sense. He grasps his subject and turns it in every way, in order to bring it into more ordinary use and application. He does not examine any doubts, encounter any errors or discuss any obscurities, save those which he had himself found actually to exist. Among those doubts, errors and obscurities he labored until he was able to bring his subject into focus for the most ordinary reader. He was not a deep classical scholar yet his love for the classics is revealed in the fact that in a time when he could have had no other purpose for such books save his own amusement, Horace, Virgil and Cicero were even to the latest of his life his table books. \textsuperscript{1} \textit{Ibid.}, p. XLVII. \textsuperscript{2} \textit{Edinburgh Review}, No. 70, P. CXXXI. In 1771, Mr. Paley was appointed one of the Whitehall preachers. In the register of the Royal Chapel there his name appears first April 21, 1771. In his preaching Paley was all solemnity and earnestness. He carried all his powers of intellect and all his heart into the pulpit. He entered immediately into the very heart of his subject with such facility, and such powers of enlarging upon it that "he made his hearers acquainted with more in a short time than might have been given to them on ordinary occasions by a hundred sermons."¹ His hearers soon forgot his awkwardness as they became absorbed in the matter of his sermon. He was capable of carrying the attention of the hearer from himself to his message. He was a friend of short sermons and once said to a friend, "Let one impression be but made, and send it home with your congregation, and you do more for them than giving them twenty comments."² ¹ Paley, Edmund. The Life of Dr. Paley, p. LXXXIX. ² Ibid. He rarely appealed to the emotions of his congregation for he felt that whatever merely moved the emotions was as perishable as the emotions. On the other hand, he felt that whatever made an impression on the understanding, or wrought conviction by the force of reason, would be more enduring. He observed "that it is one thing to edify (the common people) in Christian knowledge, and another to gratify their taste for vehement, impassioned oratory."¹ He observes that to deal too strongly with the emotions is to place Christianity on wrong foundations, citing the fact that Quakers and Moravians refer you for the proof of Christianity to the motion and witness of the Spirit in your own breast. He contends that a man who hears this, and can feel no such motion, has no alternative save to turn infidel. Counseling preachers on avoiding party transactions and political disputes, he asserts that "The Christian preacher has no other province than that of religion and morality."² ¹ Paley, Edmund. The Life of Dr. Paley, p. LXXXIX. ² Meadley, G. W. Memoirs of William Paley, D.D. p. 157. In his care to avoid the moving of man's feelings it has been observed that his sermons are more like moral essays. However true this charge may be, it was not according to his desire, for in 1790, not long after the publication of his Moral Philosophy, he preached a sermon on the importance of preaching the necessity of faith. In this sermon he deplored the fact that: We are setting up a kind of philosophical morality, detached from religion, and independent of its influence, which may be cultivated, it is said, as well without Christianity as with it, and which, if cultivated, renders religion and religious institutions superfluous. A mode of thought so contrary to truth, and so derogatory from the value of revelation, cannot escape the vigilance of the Christian ministry. We are entitled to ask upon what foundation this morality rests. If it refers to the divine will, (and without that, where will it find its sanctions, or how support its authority?) there cannot be a conduct of the understanding more irrational than to appeal to those intimations of the Deity's character, which the light and order of nature afford as to the rule and measure of our duty, yet to disregard and affect to overlook the declarations of His pleasure which Christianity communicates. It is impossible to distinguish between the authority of natural and revealed religion. We are bound to receive the precepts of revelation for the same reason that we comply with the dictates of nature. He who despises a command which proceeds from His Maker, no matter by what means or through what medium, instead of advancing, as he pretends to do, the dominion of reason, and the authority of natural religion disobeys the final injunction of both. --- 1 Paley's Sermons, Vol. VI, Charge vii, pp, 50-51. In his homiletical method, rather than preparing a sermon for a text, he frequently chose his text after he had completed his sermon for it was his habit to consider primarily, in his sermons, the needs of his congregation rather than the exegesis of a passage of Scripture. In the making of sermons Paley's models were Sherlock, Clarke and Hoadley. He follows these men not only in the rationality of their style and sentiment and their freedom from any improper display of learning or feeling, but also in the choice and treatment of many of their subjects. In the autumn of 1775, Paley met Miss Jane Hewitt. In the following spring they were married in the Church of St. Mary's in Carlisle, where his friend, Mr. Law, performed the ceremony. Mrs. Paley was of a quiet, retiring disposition. Being inactive from ill health she readily joined in Mr. Paley's desire to become a country clergyman. After a long illness Mrs. Paley died in May, 1791. Their family, consisting of four sons and four daughters, were cared for during this period, with tenderness by Mr. Paley. On December 2, 1776, Paley was inducted into the vicarage of Dalston in Cumberland. On June 17, 1780, he accepted the fourth prebendal stall in the cathedral church of Carlisle, thus becoming the coadjutor of a very warm personal friend, Mr. Law. When Mr. Law was promoted to an Irish Bishopric, Mr. Paley received an appointment as archdeacon of Carlisle in which he was installed on August 5, 1782. When Dr. Beadon was promoted to the see of Gloucester, the mastership of Jesus College, Cambridge was offered by Dr. Yorke, the Bishop of Ely, to Mr. Paley. Fixed as he then was in a certain line of engagements and unwilling at the time to enter into a different society, he declined the offer. In his View of the Evidences of Christianity, Paley offers in his dedication to the Bishop of Ely his genuine gratitude for the kind and disinterested offer of the mastership of Jesus College. On August 5, 1782, he was installed as Archdeacon of Carlisle. When in 1792, Mr. Paley was being considered for promotion to the vacant deanery of Carlisle, several things stood in the way of such promotion: namely, his attack on the economic system which deprives the many for the sake of the few, his liberal construction of the oath of allegiance to the King, assertion that government may be too secure, his judicious limitation of the duty of civil obedience, his argument that the obligation of subjects and sovereigns is reciprocal, his enlightened views of religious establishments and toleration, and his just and striking remark, that the divine right of Kings is like the divine right of Constables: The divine right of Kings is, like the divine right of Constables,—the law of the land, or even actual and quiet possession of their office;—a right ratified, we humbly presume, by the divine approbation, so long as obedience to their authority appears to be necessary or conducive to the common welfare. These views were much too bold to be honored by the predominant party of his day. 1 Moral and Political Philosophy, Bk. III, Ch. 1, pp. 68, 69. 2 Ibid., Bk. III, Ch. 18, p. 129. 3 Ibid., Bk. VI, Ch. 11, p. 315. 4 Ibid., Bk. III, Part 1, Ch. 3, p. 316. 5 Moral and Political Philosophy, Bk. III., Ch. 3, p. 323. 6 Ibid., Bk. VI, Ch. 4, p. 337. On January 24, 1795, Mr. Paley was installed as sub-dean in the Cathedral Church of Lincoln. From here he proceeded to Cambridge to take his degree of Doctor of Divinity. Inasmuch as he had received his Master of Arts degree twelve years earlier, he was permitted to forego the Bachelor of Divinity degree and the only exercise required of him by the laws of the University, were a Concio ad Clerum and an English sermon. In February, he preached his Clerum and before leaving Cambridge a letter from Dr. Barrington, Bishop of Durham, arrived, offering him the rectory of Bishop—Wearmouth, a position valued at one thousand, two hundred pounds a year, where he was inducted by Mr. Farrer, the rector of Sunderland, on March 13. Paley was highly pleased with his new position for among other advantages it afforded one of the best parsonages in the kingdom. In June, Paley returned to Cambridge and completed his Doctors degree. Returning to Bishop—Wearmouth, he resided there until his death in 1805. Paley's work as a moralist was not confined to the writing of books for the University. In periods of economic and political crisis while alarmists were circulating declamatory nonsense, Paley often came forth with calm and reasonable expositions which served as oil on troubled waters. In the period of political ferment, which led to the interference of Great Britain in the war of the French Revolution, he published a short tract entitled, Reasons for Contentment, addressed to the laboring classes. He also published, as a separate Essay, the chapter on the British Constitution from his Principles of Moral and Political Philosophy. His Reasons for Contentment, which was a copy of a sermon, the original of which is marked as having been preached at Dalston in 1790, and on which Paley wrote with his own hand "the best thing I ever wrote", was designed to remind the lower classes in Britain of the advantages which were theirs and to indicate the impossibility of any change conducive to their real happiness which might arise from political convulsions: The change and the only change, he observes, to be desired is that gradual and progressive improvement in our circumstances, which is the natural result of successful industry, when each year is something better than the last. This may be looked forward to, and is practicable by great numbers, and in a state of public order and quiet; it is absolutely impossible in any other. In his prefatory advertisement to his Essay on the British Constitution, Paley lists the motives which prompted his republishing of this work. He calls attention to the unrest among the people as they were re-examining the constitution of their government brought about by the recent revolution in France and by the fact that some recent writers had attempted to excite the passions of the people. He reminds his readers that the body of the British people were satisfied with their condition, intent upon their various employments, and tasting the sweets of industry and order, in the increased and increasing gains of almost every occupation; a state of the country, which he deemed a strong security for its internal peace. The view which he championed was unpopular among those who were stirred for the first time in their lives to give thought to politics, but among those who had long pondered the problem it was well received. --- 1 The Works of William Paley, D.D., p. 571. Paley not only urged the contentment of the masses but he reminded those in more elevated stations of their responsibilities. In a sermon dedicated to the Bishop of Durham, he vehemently attacked the idea so familiar to the higher ranks from their infancy, that they are placed above work. He called it a pernicious maxim, the direct tendency of which is to produce idleness in one portion of Mankind, and envy in the other; asserting, on the contrary, that "every man has his work", he powerfully emphasizes the peculiar obligations which belong to wealth and station. Paley is considered as one of the most important writers by whom the public interest has been aroused in the favor of the abolition of slavery. In 1788, he wrote a letter to the committee for effecting the abolition of their slave trade commending and offering his services to them. --- 1 Paley, William. Sermons and Tracts, p. 127-151. 2 Clarkson, Thomas. History of the Abolition, Vol. 1, p. 465. Before this, he had exposed the cruelty and injustice of slavery and the futility of any attempt to justify it on the basis of the silence of the Christian Scriptures.$^1$ He pointed out that the slave trade served to increase hostilities among the Africans and to promote mutual wars among the tribes in order that the victor might sell his captives to the British. He held that slavery was incompatible with the natural rights of man and contrary to the principles of religion and morality. His utilitarianism stands out in his argument that inasmuch as Africa abounds in many valuable and rich productions such as cotton, indigo and sugar cane, that Britain and other nations could carry on a much more profitable trade with her in these items than in the trade of slaves. He answered those who defended slavery on the grounds that slavery existed in Africa before the English or any other European nation visited that part of the world to purchase slaves by contending that it would be just as reasonable to argue that the practice of scalping should be continued in America since it was the practice among the Indians long before the British made settlements in America. $^1$ Moral and Political Philosophy, Book III, Part II, Ch. 3. In the year 1792, the residents of Carlisle met for the purpose of petitioning Parliament for the abolition of the slave trade. Mr. Paley had been made acquainted with the cruelties involved in this pernicious traffic by a relation who had made a fortune in the West Indies as a planter. He now found that neither his humanitarian feelings nor his common sense of morality would allow him to remain silent on the subject. In April, 1789, the newspapers carried a short treatise by Mr. Paley entitled "Arguments against the unjust pretensions of slave dealers and holders, to be indemnified by pecuniary allowances, at the public expense, in case the slave trade should be abolished," which had been sent to the committee on abolishing slavery. This was designed to reach them for use in the first great discussion in the House of Commons on the abolition of the slave trade. The resolutions drawn up at Carlisle became the basis of the petition afterwards presented to the House of Commons, which presented a clear and comprehensive view of the leading arguments which eventually led to the abolition of slavery. It is much to Mr. Paley's honor that he suggested a plan for promoting the civilization of Africa, and for making some restitution to that devastated continent, for the malicious injustice and oppression which it had so long suffered. His proposition was that from the United States of America several little colonies of free negroes should be exported and allowed to settle in different parts of Africa that they might serve as patterns of a more civilized life to the natives in these localities. Mr. Paley was an ardent crusader against the intemperance of his day. Believing that habits of intemperance were encouraged by the unnecessary accumulation of taverns, public houses and dram-shops, he attempted to diminish the magnitude of the evil by advocating a greater discrimination in his own community in granting licenses. On one occasion while serving as a magistrate he addressed the Grand Jury on this subject. Failing to receive the support of the other justices, his efforts were ineffectual. One of the chief works of Paley was The Principles of Moral and Political Philosophy which appeared in 1785, and subsequently through twenty-one editions. Much of the material for this work was borrowed from numerous sources. He acknowledges this in his preface. Especially does he own his indebtedness to Abraham Tucker for The Light of Nature Pursued. Concerning Tucker he writes: I have found in this writer more original thinking and observation upon the subject that he has in hand, than in any other, not to say, than in all others put together. In the Moral and Political Philosophy, Paley adopted the plan which he had used in his lectures at Cambridge and enlarged it to its present form. Inasmuch as this work is to furnish the primary source of this thesis, further discussion of it will be postponed until Chapter III. In 1790, he published the most original of his works, Horae Paulinae. This is a treatment of the truth of the Scriptural History of St. Paul evinced by a comparison of the Epistles which bear his name with the Acts of the Apostles and with one another. A sixth edition of this work appeared in 1809. A German translation was published in 1797. --- 1 The Principles of Moral and Political Philosophy, pp. XVI, XVII. The most popular of his works was A View of the Evidences of Christianity, which appeared in 1794. A fifteenth edition of this work appeared in 1811. This work is a compendium of a whole library of argument produced by the orthodox opponents of the deists during the eighteenth century. This work was translated into German under the following title, W. Paley's Uebersicht und Prufung der Beweise und Zeugnisse fur das Christenthum, nach der dritten Englischen Aufgabe. 2 Bande, gr. 8 vo. Leipzig, 1797. Meadley speaks of Paley's Natural Theology which was published in 1802, as "altogether the very best manual of Theism hitherto produced."¹ This work is an admirable account of the aposteriori argument for the existence of God. A twentieth edition appeared in 1820. An Italian translation appeared in 1808, and a Spanish in 1825. In addition to the above, fifteen other items were published from Paley's pen to which references shall be made further on. Notes from his lectures are now in the British Museum. --- ¹ Memoirs of William Paley, D.D., p. 209. CHAPTER II THE THEOLOGICAL AND PHILOSOPHICAL ENVIRONMENT OF WILLIAM PALEY William Paley belongs to the school of moral philosophy now designated as Theological Utilitarianism. The term, theological, denotes the fact that above all he was an apologist of the Christian religion and cannot be understood apart from a knowledge of the religious tradition in which he stood and of the religious conditions to which he addressed himself. The religious life of eighteenth century England represented a reaction from the convulsion under the Puritans during the seventeenth century. "The immediate effect of the reign of the Puritans was to bring all religion for a season into contempt."¹ This frenzy was soon exhausted, but the evil continued in extreme reactions that were equally devastating. The reaction against Puritanism issued in the result described by Bishop Butler in the preface to his Analogy in which he remarked that it had come to be taken for granted, in the England --- ¹ The Quarterly Review, "The Works and Character of William Paley," Volume XXXVIII. July and October, 1828, p. 305. of his day, "that Christianity is not so much a subject for inquiry, but that it is now at length, discovered to be fictitious." In 1751, Butler declared the deplorable distinction of the age to be "an avowed scorn of religion in some and a growing disregard of it in the generality." This state of dormancy in the Christian religion was not merely the by-product of sheer religious exhaustion after the theological excitements of the seventeenth century, but was in a large measure due to the combined influence of rationalism, naturalism and scepticism. The Deists, notably John Toland, who in 1696, published Christianity Not Mysterious; Anthony Collins, who in 1712 published his Discourse of Freethinking; and Matthew Tindal, who came forth in 1730, with Christianity as Old as Creation, were seeking to rationalize Christianity and rid it of what they called its priestly accretions. These men sought to liberate the mind of man by destroying the shackles of superstition which had long held it in bondage. They contended that true religion is no more than the republication of the simple truths in the religion of nature, --- 1 Butler, Joseph. Analogy of Religion, Advertisement to First Edition, p. 169. 2 Ibid. principles of which had been set forth in Lord Herbert of Cherbury's De Veritate. Even Christianity was no more than the republication of the religion of nature. A later Deist, Thomas Morgan, went so far as to declare that Christ himself was no more than a prophet. The rise of such independent theology had been made possible by the Reformation, however, it should not be forgotten that this rationalistic emphasis was as much a break with Protestantism as with Catholicism and involved the rejection of Protestant and Catholic principles alike.$^1$ In this period there were those who contended that all positive religion is a trick to deceive the credulous vulgar. Man's reason had been silenced for a time by a tempest of ungoverned zeal led by the Puritans, and, as a reaction against this extravagance, reason was declared to be the sole goddess of this nether world. Thus a religion of nature $^1$ McGiffert, A. C., Protestant Thought Before Kant, p. 187. not wholly unlike the Stoicism of the Roman Empire came to the front. In addition to this emphasis on reason there was the strong emphasis on natural theology. Francis Bacon had divided theology into two branches—the natural and the revealed, but now natural theology was declared to be quite adequate for man's religious life. Bacon's insistence that natural theology was sufficient to convince atheism but not to inform religion was laid aside, for the eighteenth century found that nature's lantern gave sufficient light even on the things of God. Consequently, God was brought within easy grasp of all, and man was elevated to a position hitherto unthinkable. Doctrines of the depravity of human nature and the utter helplessness of man were vehemently denounced and it was now discovered that man had been mistaken in thinking himself depraved. Moreover, man now found that he had native powers that liberated him from a passive dependence on God's grace, for now his own prudence could serve as his deity. 1 Bacon, Francis. The Philosophical Works of Francis Bacon, "The Advancement of Learning" edited by John M. Robertson, p. 89. With the exaltation of human nature, the nature and office of the Redeemer were brought low. The frantic voices of the Puritans that had sung hosannas for Christ's second and immediate coming to reign with his saints upon earth and to bind the great dragon were heard no more. It was decided that even Arius might not have been wrong in his less elevated views of the Messiah's person, and that those who had declared Him to be only a great and good man, who testified to the truth of his mission and the sincerity of his doctrine by the sacrifice of his life, were to be given an audience. All emphasis on the supernatural in religion was suppressed. The miracles were regarded as such stumbling blocks to the wise that some were traced to purely natural causes, some were regarded as allegorical, and some were placed in the category with the spurious miracles which imposters had passed off on succeeding generations. Instead of stressing man's need of salvation, the language of the ethical Seneca was made to supersede that of the evangelical Paul and the emphasis was: "For modes of faith let graceless zealots fight His can't be wrong whose life is in the right." 1 Quoted in Quarterly Review, Volume XXXVIII, July and October, 1828, p. 307. Not only was there the naturalism of the Deists, but the scepticism of David Hume and Edward Gibbon had also contributed to the religious decline of Paley's day. These men stand at the dawning of historic criticism. Hume had attempted to destroy the foundation on which the deistic argument for monotheism and for the existence of a simple, primitive, rational religion of nature had rested by arguing that history shows that polytheism preceded monotheism in the evolution of religion.$^1$ He ruled out the cause and effect argument for the existence of God by contending that human perception can penetrate only far enough to conclude that certain experiences are associated and that we are not warranted to conclude that there is a causal relation between them. If, therefore, the cause-effect relation is not a valid idea, the argument for a God based thereon is unfounded.$^2$ By his denial of the reality of substance Hume left no real permanent being behind personal experience. Thus, he contended, that there is no philosophical basis for immortality.$^3$ --- $^1$ The Natural History of Religion, Section I, p. 254. $^2$ The Treatise of Human Nature, Bk. I, part iii, Section vi, p. 43. $^3$ Ibid, Bk. I, part iv, Sect. iv, p. 81ff. The most devastating phase of Hume's work, so far as current Christianity was concerned, was his criticism of miracles, which in the eighteenth century were regarded as Christianity's main line of defense. His twofold argument was that experience is the source of all knowledge. In our experience we are more strongly impressed with the uniformity of nature than we are with the infallibility of human testimony. Thus, we may conclude that it was more likely that those who reported the miracles of the New Testament were deceived than that the uniform course of nature had been interrupted. Hume further argued that even if we granted that testimony may prove that unusual events have occurred, we could not prove that these unusual events established anything unless we could further prove that these miracles were wrought by divine power for that special purpose. Now, Paley's case for Christianity was dependent throughout on the evidential value of miracles. Hume's argument, however, influenced subsequent theology far more than Paley's. It is insisted today that the revelation which Christianity possesses is adequate to carry --- 1 Cairns, D. S. The Faith that Rebels, p. 23. 2 Hume, David. Enquiry Concerning Human Understanding. Sect. X. the accounts of miracles and has no need of miracle stories viewed as appendages for the support of the Gospel.$^1$ The kind of faith demanded by the Christian religion is now interpreted as one that supports the miracles of the Gospel rather than being supported by them. At the hands of rationalism, naturalism and scepticism, eighteenth century Christianity lost the extravagant fanaticism of a former century and gave way to a host of reasoning unbelievers. Paley described the efforts against Christianity in his day as follows: Infidelity is served up in every shape that is likely to allure, surprise, or beguile the imagination; in a fable, a tale, a novel, a poem; in interspersed and broken hints; remote and oblique surmises; in books of travels, of philosophy, of natural history; in a word, in any form rather than the right one, that of a professed and regular disquisition. And because the coarse buffoonery, and broad laugh, of the old and rude adversaries of the Christian faith, would offend the taste, perhaps, rather than the virtue, of this cultivated age, a graver irony, a more skilful and delicate $^1$ Cairns, D. S. The Faith that Rebels, p. 67. banter, is substituted in their place. An eloquent historian besides his more direct and therefore, fairer, attacks upon the credibility of the Evangelic story, has contrived to weave into his narration one continued sneer upon the cause of Christianity, and upon the writings and characters of its ancient patrons. The knowledge which this author possesses of the frame and conduct of the human mind, must have led him to observe, that such attacks do their execution without inquiry. Who can refute a sneer? Who can compute the number, much less one by one, scrutinize the justice of those disparaging insinuations, which crowd the pages of this elaborate history? What reader suspends his curiosity, or calls off his attention from the principal narrative, to examine references, to search into the foundation, or to weigh the reason, propriety, and force of every transient sarcasm, and sly allusion, by which the Christian testimony is depreciated and traduced: and by which, nevertheless, he may find his faith afterwards unsettled and perplexed? But the enemies of Christianity have pursued her with poisoned arrows. Obscenity itself is made the vehicle of infidelity. The awful doctrines, if we be not permitted to call them the sacred truths of our religion, together with all the adjuncts and appendages of its worship and external profession, have been sometimes impudently profaned by an unnatural conjunction with impure and lascivious images. The fondness for ridicule is almost universal. And ridicule to many minds is never so irresistible, as when seasoned with obscenity, and employed upon religion. But in proportion as these noxious principles take hold of the imagination; they infatuate the judgment; for trains of ludicrous and unchaste associations adhering to every sentiment and mention of religion, render the mind indisposed to receive either conviction from its evidence, or impressions from its authority. And this effect being exerted upon the sensitive part of our frame, is altogether independent of argument, proof, or reason; is as formidable to a true religion, as to a false one; to a well grounded faith, as to a chimerical mythology, or fabulous tradition. These were the trends in the religion of eighteenth century England until William Law in 1732, wrote his reply to Matthew Tindal in The Case for Reason. Law argued that "Reason not merely does not find truth in religion, it is the cause of all the disorders of our passions, the corruptions of our hearts." God is above the power of man to comprehend. "His own will is wisdom, and wisdom is His will." More than any other writer, William Law was responsible for the religious awakening that took place in the latter part of the eighteenth century. Law aroused Dr. Johnson to "thinking in earnest on religion." He also exerted profound influence on John Wesley, who was to play so large a part in bringing England back to God. II The return to religious faith in England, however, was not achieved entirely by revivalists and religious enthusiasts. There were also devout men who worked behind the scenes, and with their pens provided food for the thoughtful people who demanded a reasonable apologetic for their Christian faith. Such a man was William Paley, who came forth to present the case for Christianity in the --- 1 The Principles of Moral and Political Philosophy, p. 302. language of the common man by rationalizing the orthodox Christianity of his day. His strategy was far different from Law's. He took his place in the stream of rationalism and proceeded to formulate his argument against Deism in his most popular work, The Evidences of Christianity. Philosophically he might be characterized by Pfeiderer's term as a "rational supernaturalist." By this is meant that he combined a faith in a revealed religion with the empirical philosophy of Locke. Paley's religious philosophy is very close to the common tradition of his day. The three characteristic words of the eighteenth century were nature, reason and law. A very common phrase in the literature of that day was "a law of reason and Nature." Butler could even say that "Christianity is the promulgation of the Law of Nature."¹ This is very close to a statement of Cicero's in which he declared that "Zeno thinks natural law to be divine." The conception that the law of nature is a synonym for reality, then, goes back to Zeno, the founder of Stoicism, and from the days of Zeno the term law has been one of the most important concepts in philosophy. Before the nineteenth century, the term, law, was closely related to reason and nature. Prior to the nineteenth century if a student were asked to give a law of nature, he might have given "Thou shalt not kill" or "Be sure your sins will find you out." Between Zeno's time and the eighteenth century the discovery that anything was orderly meant that it was controlled by reason. The fact of order was the proof that nature was controlled by reason. It is a very curious thing indeed that by the twentieth century, philosophers felt that the presence of order in the universe argued for the absence of reason. Nature had become, by then, a self-running machine. Paley belonged to the period when the hand of God was seen manifestly at work in every part of the world. His doctrine of God reflects the strong influence of Samuel Clarke and John Locke upon him. He used Clarke's The Being and Attributes of God and Locke's Reasonableness of Christianity as textbooks at Cambridge. These works along with Derham's Physico-Theology, Tucker's Light of Nature Pursued, Lardner's --- 1 Exodus 20:13. 2 Numbers 32:23. The Credibility of the Gospel History formed the basis for his two books on Natural Theology and the Evidences of Christianity. Paley undertakes to prove the existence of God by the following analogy: From a watch, he reasons that we infer a maker. 1 Suppose, said he, that in crossing a heath I should stumble upon a stone and were asked how it came to be there; I might possibly answer that for anything I knew to the contrary, it had lain there forever. But suppose I should come upon a watch lying upon the ground, and it should be inquired how the watch happened to be in that place; I should hardly be able to give the same answer which I had given before for this reason, namely, that, when I examine the watch, I perceive that its several parts are framed and put together for a purpose and cannot avoid the inference that the watch must have had a maker. Paley then applies the analogy to our world and infers from it an almighty Creator. 2 Paley did not see what Kant later pointed out about the cosmological argument, namely, that while we may --- 1 This analogy had previously been used by Abraham Tucker. For an interesting history of this analogy see The Dictionary of National Biography, Vol. XLIII, p. 105; also Leslie Stephen's History of English Thought, Vol. I, p. 409. 2 Natural Theology, p. 9. infer from the world a Creator as great as the world, we are not justified in going beyond that to infer a Being who is greater than the world. In other words, Paley was justified in inferring from the presence of a watch the existence at some time of one capable of making a watch, but he could not infer from the presence of the watch alone the existence of one who is capable of making something greater than the watch. J. S. Mill has this very meaningful evaluation of Paley's argument: A very little consideration, however, suffices to show that though (the argument from design) has some force, its force is very generally overrated. Paley's illustration of a watch puts the case much too strongly. If I found a watch on an apparently desolate island, I should indeed infer that it had been left by a human being; but the inference would not be from marks of design, but because I already knew from direct experience that watches are made by men. I should draw the inference no less confidently from a footprint, or from any relic however insignificant which experience has taught me to attribute to man: as geologists infer the past existence of animals from coprolites, though no one sees marks of design in a coprolite. 1 Three Essays on Religion (1874), p. 168. Paley's type of reasoning in theology has very largely vanished, and it is not necessary to give a thorough examination of it here. Suffice it to say that Pascal long ago saw that the metaphysical proofs of God's existence are so involved that they make very little impression and offer too little striking force to be of use to most people. In fact for those capable of understanding them, they are of use only for the moment when the argument is taking place. After the argument, uncertainty returns, for one then begins to fear that he was mistaken about or deceived by it. Paley continues his argument from design by saying that from the wonderful adaptation of the human body, the eye, the hand, the muscles, we infer an almighty Designer. He, like Locke, declared, "The works of Nature everywhere sufficiently evidence a Deity." Following St. Thomas Aquinas, Paley took the statement of St. Paul to the effect that "ever since the creation of the world, His (God's) unseen attributes, his eternal power and divinity, have been plainly seen in the things he has made," to be the argument --- 1 Pensees, Paragraph 175. 2 Locke, John. An Essay Concerning Human Understanding, Bk. I, Ch. IV, p. 38. 3 Romans 1:20. from design. What St. Paul really said was not that the works of God's hands prove His existence but that they reveal the kind of God that He is.$^1$ It is interesting to remember that what Paley was saying in England about God, Holbach was saying in France about "Matter" or "Nature." The prime-mover for Holbach was not God but matter. Movement is a necessary attribute of matter, so why should we seek for a 'motor' outside Nature?$^2$ Paley was clinging to the Newtonian concept of the world while Holbach was insisting that to seek some supernatural first cause is the last infirmity of a noble mind. For him, even the immortal Newton was rather childish in his cosmology. Either Paley did not have the mental acumen to deal with such criticism or he was unaware of it. Neither did he take into account Berkeley's denial of the reality of matter which destroyed the whole concept of the world as a huge mechanism, a magnified watch. For Paley the world was not a constant divine spiritual activity impressing human minds only with itself. On the contrary, he believed that the world was real in itself. Therefore, for Paley the study of nature was the true 'preparative to Divinity.' In fact, his Natural Theology is more like a textbook in biology than a treatment of --- $^1$ Baillie, John. Our Knowledge of God, p. 126. $^2$ Systeme de la Nature, Vol. II, p. 185. theology. Paley's profound love for nature led him in the direction of the emphasis found in Wordsworth. Mr. Aldous Huxley has said that "for the good Wordsworthian, a walk in the country is the equivalent of going to Church, a tour through Westmoreland is as good as a pilgrimage to Jerusalem."¹ All things in Paley's world were bright and beautiful. Even pain was not the product of contrivance. He reasoned that teeth were designed for chewing, not for aching, and that even their aching has a benevolent purpose.² Misery is seen as contributing to man's life upon the earth as God would have it, for: A state totally incapable of misery, could not be a state of probation. . . . Nor would the purposes of trial be sufficiently provided for by a state in which happiness and misery regularly followed virtue and vice.³ Paley disagreed with Thomas Burnet who viewed the world as a mighty ruin.⁴ Burnet had gone even beyond Pascal, who had given a large place to the doctrine of the fall of man in his theology by contending that while being of itself incomprehensible, --- ¹ Essay on Wordsworth in the Tropics. ² Natural Theology, p. 384 ³ Paley's Sermons, Vol. V, Sermon V, p. 32. ⁴ Sacred Theory of the Earth. (1684 ed.), p. 129. the fall was the only starting point from which man's wretchedness could be made comprehensible.$^1$ To this Burnet added that the fall accounts for the chaotic conditions of the world of nature. He found that "disproportioned sin had jarred against Nature's chime." Therefore, for him the world may provide evidence of God's anger but not of His original intention. Burnet was obsessed with the imperfections of the earth. If we are to describe the earth as it really is, said he, we would find that: Though it be handsome and regular enough to the eye in certain parts of it, single tracts and regions; yet if we consider the whole surface of it, or the whole Exterior Region, 'tis as a broken and confused heap of bodies, plac'd in no order to one another, nor with any correspondency or regularity of parts: and such a body as the Moon appears to us, when 'tis looked upon with a good glass, rude and ragged. They are both in my judgment the image or picture of a great Ruine, and have the true aspect of a World lying in its rubbish.$^2$ --- $^1$ Pensees, The Provincial Letters, translated by W. F. Trotter and Thomas McCrie, Section vii, Fragment 441, p. 147. I believe these numbers correspond in every case with the numbers assigned in the definitive French edition of the Oeuvres, edited by Leon Brunschvicg. $^2$ Sacred Theory of the Earth, (1684 ed.), p. 125. Paley, on the other hand, naively overlooks the imperfections of earth and in a cheerful spirit beholds no cataclysm which has shattered the world-wide Eden. Others like Voltaire may send his hero about the world to spy out its morbid anatomy with a fiendish satisfaction but Paley was a man who could pour forth his blithe spirit in such language as this: It is a happy world after all; the air, the earth, the water, teem with delighted existence. In a spring noon; or a summer's evening, on whichever side I turn my eyes, myriads of happy beings crowd upon my view. The insect youth are on the wing. Swarms of newborn flies are trying their pinions in the air. Their sportive motions, their wanton mazes, their gratuitous activity, their continual change of place without use or purpose testify their joy, and the exultation they feel in their lately discovered faculties. For Paley even physical pain could contribute to man's blessedness. Moreover, it is well for us to remember that he was tortured with pain at the time of his writing yet he wrote of pain that it is seldom both violent and long continued. Even its pauses and intermissions become positive pleasures. "It has a power of shedding a satisfaction over intervals of ease, which I believe few enjoyments exceed." He examines the records of the --- 1 Natural Theology, p. 376. hospital in his community and finds 6,420 admitted but he does not sicken at that, for he finds the dead to be 234, the cured, 5,476. His eye settles on the last and he is content. Even a storm purifies the air, and it is better that a few should die therein than that all should perish.$^1$ Like Mandeville, Paley makes even evil play its role; however, he did not go so far as to say with him that the refinery needs the raw material of evil nor to say that public benefits exist not in spite of but because of the private vices of men. Mandeville had virtually thanked God for making sin so advantageous. Paley prefers to believe with John Ray, the founder of modern botany and zoology, and the most distinguished of the physico-theologians, that God has a purpose in these seeming imperfections. Ray believed that the lower ranks in the scale of being were made for the manifestation of God's Infinite Power and Wisdom.$^2$ Nature is to be regarded not as a lost paradise but as the finished and unimprovable product of divine wisdom, omnipotence, and benevolence. Paley was also indebted for his cosmology to William Derham from whom he draws information about the adaptability of $^1$ Natural Theology, p. 309. $^2$ Wisdom of God in the Creation (1701 ed.), p. 48. the human frame to life on earth.\textsuperscript{1} He virtually accepts Derham's cosmology in toto. Derham reasons that the globe is "a work too grand for anything less than a God to make."\textsuperscript{2} Let us cast our eyes here and there, let us ransack all the Globe, let us with the greatest accuracy inspect every part thereof, search out the inmost secrets of any of the Creatures; let us examine them all with our guages, measure them with our nicest rules, pry into them with our microscopes, and most exquisite instruments, still we find them to bear testimony to their infinite Workman; and that they exceed all humane skill so far, as that the most exquisite copies and imitations of the best artists, are no other than rude bungling pieces to them.\textsuperscript{3} Derham, however, is somewhat aware of the imperfections of the earth, for he contends that even if the globe were such a "rude, confused, inconvenient mass as he (Burnet) pretends, yet it is well enough for a sinful world."\textsuperscript{4} He regards poisonous and noxious creatures as "Rods and scourges to chastise us" or as "means to excite wisdom, care and industry."\textsuperscript{5} \begin{itemize} \item[1] \textit{Natural Theology}, p. 93. \item[2] \textit{Physico-Theology}, p. 38. \item[3] \textit{Ibid.} \item[4] \textit{Ibid.}, p. 48. \item[5] \textit{Ibid.} \end{itemize} It remained for David Hume to bring the most damaging evidence against this cosmological argument for God's existence. This he did by his statement that it is the very point in question whether you can infer that because a certain effect follows a certain antecedent that such antecedent is the cause of such effect. All that we are warranted in believing is that there is a certain observable pattern which has prevailed according to our limited observation. If, then, we cannot be certain about this cause-effect relationship, how can our proof of God from such an argument be valid? Yet Hume held that a refined and philosophical theism may be rationally arrived at but not through the cause-effect argument. He aims this direct barrage at Paley's argument. Even at this day, and in Europe, ask any of the vulgar why he believes in an omnipotent creator of the world; he will never mention the beauty of final causes, of which he is wholly ignorant: He will not hold out his hand, and bid you contemplate the suppleness and variety of joints in his fingers, their bending all one way, the counterpoise which they receive --- 1 Hume Selections, Edited by Charles W. Hendel, Jr. "The Natural History of Religion", Introduction, pp. 253, 254. from the thumb, the softness and fleshy parts of the inside of his hand, with all the other circumstances, which render that member fit for the use to which it was destined. To these he has been long accustomed; and he beholds them with listlessness and unconcern. He will tell you of the sudden and unexpected death of such a one; the fall and bruise of such another. The excessive draught of the season. The cold and rains of another. These he ascribes to the immediate operation of providence; and such events, as with good reasoners, are the chief difficulties in admitting a supreme intelligence, are with him the sole arguments for it. Paley's answer to this was really not an answer, it was simply a rigid declaration of the principle in question. He writes: There cannot be design without a designer; contrivance without a contriver; order without choice; arrangement without anything capable of arranging; subserviency and relation to a purpose, without that which could intend a purpose; means suitable to an end, and executing their office, in accomplishing that end, without the end ever having been contemplated or the means accommodated to it. 1 Ibid, Section VI, pp. 269, 270. 2 Natural Theology, p. 57. Now, it should be pointed out that Paley's argument differs greatly from the teleological argument of the Aristotelian type. Aristotle held that the natural order with which man is so integrally bound up, fulfills an end of absolute and intrinsic worth. On the other hand, Paley's argument is essentially anthropomorphic, resting upon an alleged analogy between natural existences and the artificial products of man's handicraft. He contended that man can gain a sufficient basis for the conception of God as an ordering intelligence in our knowledge of the self and of its relation to the products which it consciously designs. But, as Professor Norman Kemp Smith suggests: Before this argument could be taken as establishing the existence of the God of religion, it had of course to be supplemented by other types of argument. These, however, are supplementary to the argument from design; and their introduction is a virtual admission of its limited scope. In Paley's doctrine of man he places him in this 'best of all possible worlds' and gives him rights and capacities beyond --- 1 Smith, Norman Kemp. Hume's Dialogues Concerning Natural Religion, p. 29. the wildest dreams of the reformers. To such reformers as Calvin and Zwingli, man was a creature utterly subjected to the sovereignty of God, possessing, because of the fall, no rights of his own. But the Newtonian world of Paley seemed to work as perfectly as if there had been no fall. Even man is no longer vile but exactly as he should be. For Paley, man is a rational being who may demand consideration and fair treatment from God. God's only concern is man's happiness. In fact, all that is necessary to ascertain God's will is simply to ask the question, what will contribute the most pleasure to the most people? In common with his generation, Paley had endorsed Locke's conception that morality is the prime content of religion. The task of the preacher was no longer to foster a gloomy conviction of sin, nor even an enthusiastic yearning for salvation but simply to point his hearers to a sober understanding of the wisdom of God in creation, and to lead them to bask in the sunlight of God's wondrous benevolence. 1 McGiffert, A. C. Protestant Thought Before Kant, p. 188. 2 Paley, William. Moral and Political Philosophy, pp. 45-46. In viewing his doctrine of revelation, we are to remember that Paley was a devout exponent of the authority of the written revelation of God in the Bible. He held, however, that this revelation is not adequate for man's moral life.$^1$ Therefore revelation must be joined with the law of expediency and in the final analysis they are found to be in perfect agreement. Wherever the Bible clearly speaks, Paley held that its authority is absolutely binding. He did not, therefore, completely reduce revelation to the level of nature. Joseph Butler, in seeking to point out that the acceptance of the revelation of nature is fraught with the same difficulties as the acceptance of the revelation in the Scriptures, succeeded only in reducing the revelation of the Scriptures to the level of the revelation of nature. Butler takes his thesis from Origen, who contended that "he who believes the Scripture to have proceeded from Him who is the Author of Nature, may well expect to find the same sort of difficulties in it as are found in the Constitution of Nature."$^2$ --- $^1$ Paley, William. Moral and Political Philosophy, p. 4. $^2$ Butler, Joseph. Analogy of Religion. Part II, Ch. VIII, p. 276. distinctive feature in Butler's apologetic is that instead of following the manner of the physico-theologians by saying that all things are bright and beautiful and that the good God made them all, he chooses to show that nature is just as baffling and mysterious as the Scriptures. From this he infers that they both originated in the same mind. Since Nature is just as full of defects as the Scriptures, Butler sees no reason why the Deists who accept Nature as divine could not also accept the Scriptures as divine.$^1$ This, however, reduces the revelation of the Scriptures to such a level that one feels that in his effort to defend this revelation, Butler has virtually obliterated its meaning. In fact, if there is no more clarity or certainty in Revelation than in Nature, we might well conclude that Revelation is a part of Nature. It is to Paley's credit that so far as his theory is concerned he insisted upon the transcendent quality of the Scriptural revelation. Paley followed Locke in holding that "faith is assent to revelation."$^2$ He also held with Abraham Tucker that belief without proof is superstition, and thus sought to establish a $^1$ Butler, Joseph. Analogy of Religion, Part II, Ch. VIII, p. 276. $^2$ Locke, John. An Essay Concerning Human Understanding, p. 343. rational basis for his faith. The Deists contended that the evidence for religion was clear without resorting to philosophical proofs. They were just as strongly opposed to philosophical speculation as they were to the idea of Revelation. Paley excludes the element of venture from faith and leaves it as the acceptance of a rational proposition, an interpretation which even put aside the wager argument advanced by Bishop Wilkins. The Bishop contended that we should live as though there were a God for even if it should later be discovered that we were deceived, the benefits of virtuous living would still be ours, while if God does exist, we shall have from his hand an everlasting reward. This argument goes back to Blaise Pascal, and, at this point, it is interesting to observe how radically different from Pascal is Paley's interpretation of Christian faith. For Pascal, faith is different from proving, for proving is human, and faith is the gift of God. The just man shall live by faith. It is this faith which God himself gives in the heart that makes us to say not "I know" but "I believe."¹ This is what Pascal calls "the knowledge of the heart." Faith for Pascal was not the committal of the intellect to a proposition but the surrender of the whole self, including ¹ Pensees, The Provincial Letters, translated by W.F. Trotter and Thomas M'Crie, Section IV, Fragment 248, p. 88. the intellect, to God. For him, Christian faith included the response of love. "We love him because he first loved us."¹ As Locke later insisted, Pascal said that Christianity is not contrary to reason. The apologists first task is to make people want Christianity to be true, then he must show them that it is true. The natural situation of man is one in which God is already dimly sensed. He makes God say to man, "Console thyself. Thou wouldst not be seeking me if thou hadst not found me."² Pascal was reaching out to an understanding of a faith which is an outgoing of the whole man to God. For him there could not be a real and fundamental conflict between reason and faith. He speaks of the two excesses in theology as excluding reason and admitting only reason.³ Faith says indeed what the senses do not say but what it says is not contrary to the senses. It is beyond sense but not against sense.⁴ To show that religion is not at all contrary to reason, he abandoned the metaphysical proofs, which were commonly used, in favor of moral and --- ¹ I John 4:19. ² Pensees, The Provincial Letters, translated by W.F. Trotter and Thomas M'Crie, Section VII, Fragment 552, p. 177. ³ Ibid., Section IV, Fragment 253, p. 90. ⁴ Ibid., Section IV, Fragment 265, p. 93. historical proofs. He begins with man's wretchedness and infers from his awareness of his wretchedness, his greatness. This wretchedness commingled with his greatness can only be accounted for by the fall of man from his original state of perfection. The fall itself is incomprehensible but without it, all things else about man, writes Pascal, are incomprehensible. Out of this, Pascal reasons that man has need of a religion that can explain his condition and at the same time redeem him. This he finds in the historical religion of Jesus Christ. Paley's approach, as already stated, was radically different from this. He held before man certain external proofs in the form of the miracles of the Bible and declared that the acceptance of the truth of the revelation in the Bible, by virtue of the fact that its truth is attested by miracles, is Christian faith.$^1$ He thus left out the idea of communion with and committal to a personal God revealed in Christ which is so prevalent in Pascal. Pascal held that a full knowledge of God is conditioned on the venture of faith and that God has so ordained that certainty and $^1$ Sermons on Several Subjects, Sermon XV, p. 661. assurance in spiritual matters must be reserved only for those who search for him with their whole heart. Pascal uses the term "heart" in the Biblical sense of the whole personality and was thus much closer to the Hebraic psychology than was Paley. Tillotson, who became Archbishop of Canterbury in 1691, held that faith was not a special faculty and that there is no distinction between reason and faith. Above all else, Christianity must be reasonable. He believed in a supernatural revelation and yet it is to our reasons that this revelation must commend itself. One of the tenets of the broad Church of Paley's day was that reason is the only faculty by which true religion is recognizable. Yet, in this tradition there stands the very curious contention that by miracles the reason is convinced of the authenticity of revelation. For Tillotson, reason was not an intuitive faculty but a discursive power. He meant by reason the act of reasoning. It remained for Locke to work out the details of Tillotson's position. He held that our assent to revelation is --- 1 Moffat, James. The Golden Book of Tillotson. faith. But how are we to be sure that this revelation comes from God, and how are we to be sure of its direct meaning? First, he answers, we must be sure we have understood it aright and then we must understand that there are three kinds of propositions. There are those propositions which are according to reason, for example, the existence of one God. This proposition is according to reason for it is capable, Locke thought, of being demonstrated. Then, there are propositions that are above reason, for example, the resurrection, for which there can be no proof. Only a miracle can persuade us of the truth of such a proposition. Finally, there are propositions that are contrary to reason, for example, the existence of more than one God. Such a proposition could never be credited for I could never have a reason for crediting it. Chillingworth, Clarke and Wollaston all stood in this tradition. They would all agree with Locke that "Reason is natural revelation whereby the eternal Father of light and fountain of knowledge communicates a knowledge of himself." 1 Locke, John. An Essay Concerning Human Understanding, p. 343. 2 Ibid., Bk. IV, Ch. XIX, 4, p. 360. For Locke the purpose of miracles is purely to give attestation to revelation. Yet he held that not even a miracle can give attestation to anything contrary to reason to be revelation. A casual examination of Locke demonstrates the truth that theological liberalism of the nineteenth century was in reality rooted in the seventeenth century. This may be observed by noticing how much Locke and Harnack resemble one another. It is interesting to remember, however, that rationalism later threw the miracles out of court. In his insistence on the evidential value of miracles Paley was again very true to the traditional Christianity of his day. However, he goes a bit farther than his predecessors, for to him the distinctive Christian revelation is so supernatural that he holds that it could only be given through miracles.$^1$ "These miracles form, no doubt, our assurance that He (Christ) was sent from God."$^2$ The glories of the world above toward which we journey are for Paley so unspeakable that they stand in a category which only a miracle could properly describe. $^1$ Evidences of Christianity, p. 3 $^2$ Paley's Sermons, Vol. V, Sermon ii, p. 151. Paley's argument concerning the miracles gathers around the objections advanced by Hume. He takes issue with Hume's argument of probabilities in which it is contended that since we are more impressed with the orderliness of the universe than we are with the trustworthiness of human testimony, it is more probable that those reporting the miracles were mistaken than that the natural order should have been violated. The curious point in the total picture of Hume's philosophy is that the very man who contended that for all we can prove, anything may be the cause of anything, was also the man who argued against the possibility of miracles because they violate the unchangeable laws of nature. History, Hume argues, teems with accounts of miracles. Says he, the argument against miracles hinges upon the question of belief in the truth of testimony. Like all our beliefs, this one rests upon experience. Our experience is that men have memories which on the whole are trustworthy. But testimonies may conflict, or 1 Enquiry Concerning Human Understanding, Sect. X. their authority may be rendered doubtful by the manner of their delivery. When the event being related is a miracle (and by a miracle Hume means a violation of the laws of nature), since the law of nature itself has been established by a long period of observing an unalterable pattern, the mind is thus presented with one body of testimony set over against the other. The stronger testimony belongs to the changeless pattern of the law of nature. Hume writes: There is not to be found in all history, any miracle attested by a sufficient number of men, of such unquestioned good sense, education, and learning as to secure us against all delusion in themselves; of such undoubted integrity as to place them beyond all suspicion of any design to deceive others; of such credit and reputation in the eyes of mankind, as to have a great deal to lose in case of their being detected in any falsehood; and at the same time attesting facts, performed in such a public manner, and in so celebrated a part of the world, as to render the detection thereof unavoidable: all which circumstances are requisite to give us a full assurance in the testimony of men. 1 Hume, David. Works, vol. ii, pp. 94-95. Paley undertook to answer Hume by contending that the Christian revelation affords an adequate testimony, that the apostles were a 'sufficient number of men' and that they possessed the proper credentials to validate their testimony. He reasons as follows: If twelve men whose probity and good sense I had long known should seriously and circumstantially relate to me an account of a miracle wrought before their eyes, and in which it was impossible that they should be deceived; if the governor of the country, hearing a rumour of this account, should call these men into his presence, and offer them a short proposal either to confess the imposture or submit to be tied up to a gibbet if they should refuse with one voice to acknowledge that there existed any falsehood or imposture in the case; if this threat were communicated to them separately, yet with no different effect; if it was at last executed; if I myself saw them, one after another, consenting to be racked, burnt, or strangled rather than give up the truth of their account,—still, if Mr. Hume's rules be my guide, I am not to believe them. Now, I undertake to say that there exists not a sceptic in the world who would not believe them or who would defend such incredulity. Paley goes on to show that the spurious miracles of history do not belong in the category with those associated with --- 1 Paley, William. Evidences of Christianity, pp. 8, 9. the Christian faith. However, Hume regarded the Apostles as being uneducated members of the lower orders of mankind and Palestine as an isolated corner of the Roman world which was not to be compared with Athens or Rome. Therefore, miracles reported by these men from this area could not be accepted in the enlightened world. Hume's emphasis followed something of the same pattern established by Shaftesbury who had viciously assailed the characters and stories of the Bible and warned the poet to steer clear of them: The wit of the best poet is not sufficient to reconcile us to the campaign of a Joshua, or the Retreat of a Moses, by the assistance of an Egyptian Loan. Nor will it be possible, by the Muses Art, to make that Royal Hero appear amiable in human eyes, who found such favour in the eye of Heaven.¹ Since Paley's day the course of Christian apologetics has changed rather radically. Professor D. S. Cairns reminds us today that the miracles of the New Testament do not stand as sign posts to a deeper reality but that they belong to the very fabric of the Christian Gospel.² The pattern of current thought ¹ Shaftesbury, Works. Vol. i, p. 358. ² The Faith that Rebels. p. 25. is that the Gospel represents the unique intervention of God into the affairs of men and is of such inherent worth that it carries the miracles with it. It is not that because the miracles are so startling we must believe the stories in which they are set, but rather that the redeeming act of God in Christ is so startling that we should expect it to be accompanied with supernatural events. This change in thinking concerning the miracles goes back to the work of Thomas Wolleston who held that the resurrection is of the very essence of the Gospel and not a seal to prove something greater than itself in the Gospel. The importance of Paley's treatment of the miracles is that to a greater degree than any other writer he related them to that doctrine, which permeates all of his theology, namely, the doctrine of rewards and punishments after death. Paley took his departure from a belief in a benevolent Creator whose purpose was not only to enable men to share an earthly existence but by endowing him with the capacity for moral obedience made it possible for him through his obedience to enter a second state of --- 1 A Discourse on the Miracles of the Savior. existence infinitely more glorious than the first. Now, Paley reasons, if this be the purpose of the Creator, would it not be reasonable to suppose that He would communicate a knowledge of such a plan to His Creation? If this be one's belief concerning the plan of God for man, then Paley concludes that it is not unreasonable to believe that so glorious a purpose would have been revealed through miracles. Thus Paley relates his doctrine of miracles to his doctrine of revelation and also to his eschatology. In the forefront of all his writing and all his preaching, Paley sets the doctrine of rewards and punishments after death.$^1$ Most of the seventeenth and eighteenth century moralists could not see how the moral law would hold together without a final judgment where rewards and punishments would be meted out. Herbert of Cherbury went so far as to name this among his five common notions.$^2$ Even Voltaire believed that the doctrines of an awarding and avenging God are necessary to the maintenance of the moral order. He wrote, "If God did not exist we would have $^1$ The Principles of Moral and Political Philosophy, Bk. I, Ch. vii, p. 32. $^2$ De Veritate. to create Him but all Nature cries out that He does exist."¹ Sir Thomas Browne wrote, "Ipsa sui pretium virtus sibi, that virtue is her own reward is but a cold principle and not able to maintain our variable resolutions in a constant and settled way of goodness."² He further declared that we cannot hope "to be honest without thought of Heaven or Hell."³ Of course, there were those who were at work trying to divorce ethics from the doctrine of rewards and punishments. Shaftesbury declared that to be honest without thought of heaven and hell is the distinguishing mark of a true lover of virtue. For him, true Christianity produced a spontaneous goodness of the heart that was not dependent on rewards or punishments. This position was further advanced by Holbach, who thinks of the doctrine of the future life as a mirage which blinds men to the real and remediable evils of the present life. ¹ Voltaire (See Ueberweg) ² Religio Medici, p. 69. ³ Ibid. He asserts that: Religion has become the art of intoxicating men with enthusiasm, so as to divert their attention from the evils with which their rulers load them here on earth....They are made to hope that if they agree to being unhappy in this world, they will be happier in the next. When we deal with Paley's moral philosophy we shall undertake to show that the glaring weakness of his system lies in the fact that the rewards of eternity were in terms of quantitative considerations rather than in terms of qualitative moral and spiritual values. Schleiermacher later pointed out that true immortality is qualitative harmony with God and thus liberated the conception from the grossly materialistic point of view so prevalent in the previous century. Perhaps the greatest service that Paley performed for Christian theology was his refutation of the denial of the historicity of the Christian religion. How widespread this denial had come to be in the eighteenth century England may be seen in the previously quoted statement of Butler in which it is declared that many were taking it for granted that Christianity was fictitious. It should be observed that Paley's --- 1 Christianisme De' voile', quoted by Wickwar, Baron d'Holbach, (1935), p. 129. 2 The Christian Faith, p. 542. problem was a practical one which was forced upon him by the tide of unbelief, and was not comparable to the undertaking of what Professor D. M. Baillie has chosen to call the "Jesus of History Movement" of the nineteenth century.¹ This school was concerned with the recovery of the Jesus of History in an attempt to show that the starting point of Christian theology can never be in ready-made metaphysical dogmas about Christ, but rather in the historical person of Jesus of Nazareth with whom we are confronted in the Gospel story. Paley, on the other hand, was concerned to show that the metaphysical dogmas of the Church were historically authentic. In fact, the eighteenth century has been characterized as a time of freezing dogma into static forms. It is much to Paley's credit that even before the work of Ritschl, Harnack and Herrman, he was impressed with the necessity of getting back to the historical setting of the Gospel. For his Evidences of Christianity he drew heavily from the research of Nathaniel Lardner.² His treatment of the historicity of Paul, however, is quite original. ¹ God was in Christ, p. 48. ² Credibility of Miracles (1755 ed.), Vol. I, p. 23. This growing feeling for history was one of the most important parts of the legacy of the eighteenth century. There is a feeling as one reads Paley that his interest in the historical setting of the Gospel led him to embrace the Socinian view of the person of Christ. His admiration for Nathaniel Lardner's work is much in evidence and it is known that while reading Lardner's Letter on the Logos, Joseph Priestley became a Socinian, holding that God is the only proper object of worship and thus rejecting the Trinitarian doctrine of Christ's divinity and the Arian doctrine of his pre-existence. Priestley, who was a non-conformist, could demonstrate more completely than one related to the Church as was Paley, the ultimate development of the natural theology of the century. From Paley's notes from his lectures which are now in the British Museum one writer proves to his own satisfaction that Paley accepted the Unitarian view.$^1$ However, in Paley's published works he does not attempt formally to explain his ideas of the person of Christ. Perhaps our best source for $^1$ The Christian Life and Unitarian Herald, July 11, August 2, August 22, 1891. this information would be his sermons. As clear a passage on the subject as the writer could find is the following: That a person of a nature different from all other men; nay superior, for so he is distinctly described to be, to all created beings, whether men or angels; united with the Deity as no other person is united; that such a person should come down from heaven, and suffer upon earth the pains of an excruciating death and that these his submissions and sufferings should avail and produce a great effect in the procurement of the future salvation of mankind, cannot but excite wonder. Although in some passages Paley appears to identify the works of the Holy Spirit with the inner musings of man, he also speaks of the third Person of the Trinity as a "real, efficient, powerful, active Being whose cooperation is essential to the conviction, conversion, and moral welfare of man." Such statements as these led one writer to declare: On the whole, then, we think that he (Paley) was, nothing like a modern Socinian; that he was, at least something more than an ancient Arian; but that the precise shade of his creed cannot be determined by us and perhaps had not been determined by himself. --- 1 Sermons on Several Subjects, Sermon XVIII, p. 666. 2 Ibid, Sermon XXIV, p. 683. 3 Ibid, Sermon XXVII, p. 692. 4 Quarterly Review, Vol. XXVIII, July and October, 1828, pp. 328, 329. Still another writer declares that it would be easier to say what Paley's opinions on this subject were not, than to say precisely what they were.$^1$ His ideas of the person of Christ are nowhere formally explained, and are but very slightly unfolded even by passing intimations. The following is as distinct a passage as may be found in his sermons: In the mean time, from the whole of these declarations of this discussion, we collect that Jesus Christ, ascended into the heavens, is at this day, a great efficient Being in the universe; invested by his Father with a high authority, which he exercises, and will continue to exercise, to the end of the world.$^2$ To this may be added one other quotation: That a great and happy Being should voluntarily enter the world in a mean and low condition and humble himself to a death upon the Cross, that is, to be executed as a malefactor, in order, by whatever means it was done, to promote the attainment of salvation to mankind, was the theme they (the Apostles) dwelt upon with warmest thankfulness.$^3$ It appears to the present writer that Paley's emphasis is not that of the Socinian and that while he was certainly --- $^1$ Eclectic Review, Vol. V, January to June, 1809, p. 9. $^2$ Paley's Sermons, p. 348. $^3$ Ibid, p. 290. impressed with the genuine humanity of Jesus$^1$ he did not relinquish his hold on the divine Lord who is our Saviour and Redeemer.$^2$ Paley's emphasis on the divinity of Christ is seen in his treatment of the atoning death of the Redeemer. He divides the meaning of the atonement into two categories, namely, the spiritual and the moral. The spiritual consists in the benefit it procured us in the attainability of final salvation. The moral ends of the death of Christ consist in the additional motives which it furnishes to a life of virtue and religion, as it is a pattern, example, encouragement and incitement to virtue. He reasons further that the death of Christ teaches us to practice humility and patience and to crucify the flesh and the lusts of life.$^3$ To receive the benefits of Christ's atonement man must repent of the sins for which Christ died. Paley defines repentance as "a change of the heart from an evil to a good disposition". . . It is "an actual amendment of life... It is that disposition of mind by which 'he who stole steals no --- $^1$ Sermons on Several Subjects, Sermon XXII, p. 677. $^2$ Ibid. Sermon XVIII, p. 666. $^3$ Paley's Sermons, Vol. V, Sermon iv, pp. 169, 170, 171. more,' by which 'the wicked man turneth away from his wickedness and doeth that which is lawful and right'. . . . 'where restitution is practical, repentance cannot be sincere and effectual without it.'$^1$ Paley makes good works a condition of salvation, for he thinks that those who say that good works are necessary to salvation but are not willing that they should be called conditions of salvation are making a distinction too refined for common man to apprehend.$^2$ There appears to be a curious inconsistency at this point for in the same sermon Paley argues that the cause of salvation is not in anything we do or can do but in the good will and pleasure of God. It is to Paley's credit that in his study of history he did not lose the divinity of Christ in the maze of history. That is to say, in contending that Christ, the Revealer of God, is indeed in history, he did not make the mistake of Ritschl who held that Christ was also of history.$^3$ Nor did he, with --- $^1$ Paley's Sermons, Vol. V, Sermon iii, p. 158, 162. $^2$ The Eclectic Review, Vol. V, Part I, from January to June, 1809, p. 9. $^3$ Mackintosh, H.R. Types of Modern Theology, p. 157. Harnack, believe that the metaphysical implications of the Christian creed have their source in the infiltration of Greek philosophy.$^1$ He believed that the Christ of the Creed was One with the Christ of Galilee. Although we are being told today by Professor Rudolf Bultmann,$^2$ Dr. Edwin Bevan,$^3$ and Professor R.H. Lightfoot,$^4$ that the quest for the historical Jesus is in vain, and are being frequently reminded of Father Tyrrell's incisive criticism against the "Liberal Protestant" reconstruction of the figure of Jesus when he wrote, "The Christ that Harnack sees, looking back through nineteen centuries of Catholic darkness, is only the reflection of a liberal Protestant face, seen at the bottom of a deep well,"$^5$ still one feels that the creed must be anchored in historical fact and that Paley did well in holding them together. $^1$ Harnack, A. What is Christianity?, p. 224. $^2$ Jesus and the World, English Translation by Louise Rettibone Smith and Erminie Huntress, p. 28. $^3$ Christianity, p. 31. $^4$ History and Interpretation of the Gospels, pp. xiii, xiv. $^5$ Christianity at the Cross-Roads, p. 44. III We have seen how Paley has acquired a certain symbolic significance as an apologist of the Christian religion by defending the reasonableness and historicity of the claims of the Church against the challenge of Deism. We turn now to show how he dealt with Deism as it challenged the moral worthiness of the Christian claims. Contrary to the popular opinion Deism was not primarily a theological belief in an absentee God, who is utterly transcendent, nor was it an attempt to establish a rationalistic philosophy. In reality, Deism was primarily a moral movement attempting to separate the ethical from the non-ethical and ultimately the ethical from the religious in man's thinking. C. C. J. Webb correctly says that "the accepted meaning of Deism is belief in a God known from the light of nature apart from --- 1 The writer is not unmindful of the fact that no less a writer than W. R. Sorley held that Deism is primarily the belief in an absentee God, and the author of the article on Deism in the Encyclopedia of Religion and Ethics held that Deism stands for a philosophical rather than a religious view. On the other hand, Dr. Hayfeldbower, in The Relation of John Locke to English Deism, points out that with the exception of Herbert of Cherbury, the Deists scarcely touched philosophy and McGiffert in his chapter on Rationalism in his Protestant Thought Before Kant states that the Deists were interested in religion primarily as a means to virtue. revelation."1 The light of nature resided, as the forerunner of Deism, Lord Herbert of Cherbury, had said, in the five common notions, the third of which is that "virtue conjoined with piety is the principle part of divine worship."2 Man, therefore, has no need of a special revelation of the divine will. In fact, the Deists were interested in the development of ethics as a science utterly divorced from a special revelation. Prior to examining Paley's reaction to the moral philosophy of the Deists, let us look at the general trends of moral philosophy in England before Paley began his work. The dominant trend of Paley's day was in the direction of natural morality. Beginning with Thomas Hobbes there was a growing tendency in England to divorce ethics from a revealed religion. In fact, the strongest endeavor in seventeenth and eighteenth century thought, beginning with the work of Francis Bacon, was the attempt to separate natural from revealed theology.3 Out of this endeavor there grew the --- 1 Studies in The History of Natural Theology, p. 344. 2 De Veritate. 3 The Philosophical Works of Francis Bacon, Edited by John M. Robertson, (1905), p. 89. breach between natural and revealed morality. After the break down of the rigid ecclesiasticism accomplished by the reformers, a new freedom arose. The mind of man was liberated so that he might think for himself, and free philosophical endeavor became a possibility. The reformers had been practical men who were not interested in philosophy. Luther, in fact, had said that of itself philosophy could not rise to any knowledge of God. It is apparent that while Bacon accepted Luther's contention and himself made a plea for separation between philosophy and religion, he was not so much concerned for the claims of faith as he was that reason should be given the right to function unshackled by dogmatic chains. Bacon disposed of the claims of religion by saying, "As we are obliged to obey the divine law though our wills murmur against it, so we are obliged to believe the word of God though our reason is shocked by it." He held that man's knowledge is like water. Some comes from above, some from beneath. The light of nature coming from below empirically and revelation coming from above provide us with the totality of our knowledge. Bacon's famous sentence is that "Natural theology sufficeth to convince atheism 1 Ibid. but not to inform religion.\textsuperscript{1} Bacon contends that while plain philosophy can silence the atheist, it cannot give us sufficient Christian knowledge. On the other hand, he insists that the Bible is designed to teach religion, and to endeavor to build natural philosophy out of the first Chapter of Genesis would be utterly futile. This new quest for freedom of thought was united with a widespread campaign for toleration in which the citizens of England demanded liberty to profess any religion they should choose and to write books that deviated from the views of the Church and State. Thus liberated by Bacon's philosophy, Thomas Hobbes, who had served as Bacon's secretary, brought his contribution to the movement by contending that all morality and religion are subservient to politics. Hobbes identified the moral with the positive law. What the State allows is good, and what it disallows is evil. Laws of nature are immutable and eternal, but they do not become binding until the community has been established. Thus moral standards vary. Apart from \textsuperscript{1} \textit{Ibid.} the State, good and evil have no binding force. While Hobbes speaks constantly of revelation, he gives it a political significance. His blatant scepticism is revealed by the manner in which he attacks the theory of revelation. "To say God hath spoken to man in a dream, is no more than to say man dreamed that God hath spoken to him."¹ "To say one hath seen a vision, or heard a voice, is to say he hath dreamed between sleeping and waking."² Yet Hobbes was absolutely convinced that the dogmas of the Church were necessary to hold the community together. Morality thus became the product of arbitrary civil and ecclesiastical legislation. The immediate effect of Hobbes' work was to call forth the enmity of both moralists and theologians. Theologians thereby came to be joined with moralists until the whole of the theology of the eighteenth century took on a strong moral tone.³ The common task of theology and moral philosophy was to refute the arguments of Hobbes. ¹ Green, J. R. A Short History of the English People, p. 615. ² Ibid. ³ Stephen, Leslie. English Thought in the Eighteenth Century, Vol. ii, p. 2. One of the strongest opponents of Hobbes was Cudworth, the most distinguished of the Cambridge Platonists. He believed that the "essential and eternal distinctions of good and evil" are independent of mere arbitrary will whether human or divine.$^1$ He thinks of ethical truth as related to the universal essence of things, which is inseparable from the Eternal mind and just as immutable as the Eternal mind. He exalted the natural moral sense of man. To act aright, he maintained, we need only consult the natural law written on the heart. A more satisfactory refutation of Hobbism came from Bishop Richard Cumberland. Hobbes believed that in a state of nature, by which he meant man outside the control of civil government, it would be irrational for a man to obey the laws of nature, for he could never be assured that others would obey such laws. Therefore, by his obedience he would be defeating the true end which the laws had in mind which for him was self-preservation.$^2$ From such reasoning he concludes that $^1$ Eternal and Immutable Morality, pp. 16, 17. $^2$ Hobbes, Thomas. De Corpore Politico, Vol. IV., p. 225. the laws of nature are not laws at all but mere conclusions. To change the many conflicting wills of individual agents into one will, an absolute government must be established to which the individual must yield his undivided allegiance. Over against this, Cumberland insists that the laws of nature are real and valid.$^1$ He takes issue with Hobbes' view of man in which man is compared with "wolves", "bears" and "serpents"$^2$ by maintaining that if this were true, "It would evidently be impossible to reduce such beasts of prey, always thirsting after the blood of their fellows, into a civil state."$^3$ Furthermore he maintained that sympathy was as much a part of human nature as desire for self-preservation, for if this were not so, society could not exist. For Cumberland "Universal benevolence is the spring and source of every act of innocence and fidelity, of humanity and gratitude, and indeed of all the virtues by which property and commerce are maintained."$^4$ --- $^1$ De legibus naturae, p. 14. $^2$ Hobbes, Thomas. De homine. Vol. II (Latin works, Molesworth's ed.), p. 91. $^3$ De legibus naturae, p. 295. $^4$ Ibid., p. 114, 115. The point of Cumberland's originality lay in his attempt to discover an underlying principle from which all the moral laws could be deduced. This he finds in the general law of benevolence. He thus became the first exponent of a theory that long dominated English ethics and which set man to thinking of the high and lofty possibilities of human nature. Thenceforth the completely anti-social man whom Hobbes had depicted as morose, malignant and thoroughly miserable began to vanish and in his place there arose a new man capable of boundless good. Cumberland was joined by Lord Herbert of Cherbury, who, bright, hopeful, and optimistic, saw man as universally possessing by nature certain common notions which constitute the revelation of God in man and thus needing no further revelation from God. Lord Herbert's man stands adequately equipped to deliver his own soul. Locke also places man on an heretofore unparalleled pedestal. He exalts man not by storing his mind with innate ideas as had Lord Herbert of Cherbury but follows Tillotson in holding that reason is not an intuitive faculty but a discursive ability or capacity. Nothing is in the mind that was not first of all in the senses. Man is great not by virtue of the ideas he possesses but by virtue of his unlimited ability to apprehend the truth, nor can he want for a clear knowledge of God if he uses the faculties with which God has provided him. "Reason is natural Revelation, whereby the Father of Light, and fountain of all knowledge, communicates to mankind that portion of the truth which he has laid within the reach of their natural faculties."¹ Locke insisted that Christianity, properly understood, by which he meant the original, simple teaching of Jesus and the Apostles minus the priestly accretions of the centuries, was not inconsistent with reason. By the light of reason, God had revealed to all men that God is good and merciful. The same spark of reason that makes one a man shows him the law he is to obey and the way of atoning for his sins when he disobeys.² Mankind's need of a Savior came when the use of reason was forgotten and men allowed Priests to fill their heads with vice and superstition. It was necessary for Christ to come to simplify and purify the natural religion which had become so ¹ Ibid., Book IV, Ch. 19, Sect. 4, p. 360. ² The Reasonableness of Christianity as Delivered in the Scriptures., pp. 8, ff. overlaid with superstition. For Locke, Christ came to re-establish natural religion and natural morality. The Deists continually spoke of Christianity as the re-establishment of religion. For Locke it was enough to acknowledge Jesus as the Messiah and to practice the moral virtues which he proclaimed and which are in fundamental accord with the dictates of a reason which is hardly distinguishable from enlightened common sense. In the same year that Locke published his Reasonableness of Christianity, 1693, Charles Blount came forth with his Oracles of Reason. The main burden of this work was to show that God enjoins no positive duties on man in addition to natural duties. Man was now found to be capable of more than merely obeying laws. He could even be like God. For, Blount declared, our duty is to be like God, not to obey a series of laws. To act according to natural law was thus coming to be interpreted as meaning to be like God. As the concept of Nature expanded, a chair for a professor of the Law of Nature and Nations was established at Heidelberg in 1662, and Samuel Pufendorf was the first to occupy that chair. Thus the cry "follow nature" which had been raised in antiquity by Cynics, Stoics and Epicureans and which later came to link together the starry heavens above and the moral law within was once more surging to the front of man's thinking. The law that preserved the stars from wrong, was once more becoming the rule of duty. To be sure the age was not without its adherents to the older views, Samuel Clarke, the most distinguished scholar in England for a quarter of a century after Locke, although 1 It is noteworthy that Paley takes Pufendorf's work into consideration in the preface of The Moral and Political Philosophy. 2 One of the characteristics of Paley's age was that of speaking of morality under the metaphor of a law. From the time of Chrysippus the expression, "law of nature," was in constant use. By law of nature the Stoic meant that which is KαTα' φύσιν, according to the nature of things. To draw a distinction between laws rooted in the nature of things and those that were not, the Stoic fell back on a word which the Sophists had often used interchangeably with vόμος, namely, θέσις, the verbal substantive of τίθημι, meaning "I place," "I put." θέσις meant for them "A thing laid down." The Stoics used these words to distinguish between a vόμος θέσικος, a law laid down by man, and a vόμος φυσικός, a law of nature. It is the distinction maintained in Latin between the lex positiva, positive law, and the lex naturalis, natural law. The term, positive law became general in later thought. This distinction between positive law and natural law is one of the most important distinctions throughout the history of Western thought, for it distinguishes that which belongs to reality from that which does not. following the main outlines of the philosophy of Tillotson and Locke, still maintained that man was basically corrupt. For Clarke, the need of a revelation from God was seen not so much in the truth that the facts of religion have been perverted but rather in the fact that the original light of reason in man has been corrupted. He speaks of the corruptness of reason far more than Locke. Although Clarke was not strictly one of the Cambridge Platonists, he adopted some of their ethical principles. He accepted Cudworth's contention that the moral law is rooted in the nature of things, and that the fundamental precepts of the moral law are self-evident and unalterable thus embracing what came to be known as rational intuitionism. Clarke's fatal blunder came in his attempt to demonstrate what the self-evident moral intuitions are. He listed them as follows: reverence, equity, benevolence and self-preservation. An examination of these terms would show that they may conflict with one another unless they are rationally defined. Deism proper differed from the earlier writers like Clarke, Tillotson and Locke in that it represented the utter repudiation of revelation as a means of arriving at a knowledge of God and a man's moral duty. Earlier writers like Richard Hooper had strongly emphasized the law of nature but were also keenly aware of its inadequacy. When we come to Tillotson and Locke, the emphasis upon natural religion is stronger until there is a gradual fading out of revelation. Behind the endeavour of the Deists was the desire to work out a system of ethics for the common man by showing him that God demanded nothing of him but the performance of moral duties which are revealed to him by the law of nature.$^1$ John Toland, who published his Christianity not Mysterious in 1696, represents a half-way house between Locke and full-fledged Deism. He held that revelation is a means of revealing matters of fact we should not otherwise have known and is to be accepted on divine authority rather than because we have discovered the truth of it. Yet he insisted that there was nothing in Christianity that was contrary to reason or above reason. "Nothing inconceivable can be contained in the Gospel of the Word of God."$^2$ --- $^1$ McGiffert, A. D. Protestant Thought Before Kant, pp. 211, 212. $^2$ Christianity Not Mysterious, p. 22. At this point, perhaps we should be reminded that Deism proper distinguished between reason and rationalism. The Deists never interpreted religion in a speculative way. They scarcely appealed to philosophical proofs. In fact, they were the declared enemies of philosophy just as they were the declared enemies of anything belonging to man's inventions. They believed that the evidence of religion was clear without resorting to philosophical proof. They speak of reason but they do not mean reasoning. That is to say, they follow the Stoic line as against the Aristotelian. Deism went further and denied that there was such a thing as revelation apart from the light of nature. In 1730, Matthew Tindal published Christianity as Old as the Creation, a book which later came to be known as the Deists' Bible. His major thesis was that we must not demand in the name of religion anything that is against morality. True religion is doing good. The only difference between morality and religion is that morality is doing right because it is right. When right comes to be regarded as the will of God, it is religion. One is regarded as superstitious if he thinks that God requires of him anything more than to do justice, love mercy and serve the public good. While insisting that he is a Christian Deist, Tindal maintained that to be a Christian is neither to accept the Bible or the tradition of the Church but simply to act according to the law of reason. All that is in the Bible must be judged by reason or by the nature of things. For him, the supreme mission of Jesus was to purify the religion of nature. As the authority of nature grew in the minds of men, its grand concomitant, the dignity of human personality, was also enlarged. For as men got back to the pure religion of nature revealed afresh in Jesus of Nazareth, they became more and more impressed with an item that had been long overlooked, namely, his essential humanity. Thomas Chubb in his True Gospel, published in 1738, raised the question of the historicity of Jesus and concluded with an unusual emphasis upon his humanity. In both these items he antedated the efforts of the nineteenth century writers. The true Gospel for Chubb may be summed up in three points. First, we must conform our lives to the eternal and unalterable law of reason; then, if we have violated that rule, we must repent and reform to be forgiven; and, finally, there will be a last judgment before which all men must appear and receive the rewards and punishments for their deeds. Coming to the middle of the eighteenth century and to the work of Thomas Morgan, we find that by this time the emphasis upon Christianity as the most noteworthy revival of the religion of nature had deprived the Christ of all his supernatural attributes and had made of him only a prophet. The brightest exponent of the greatness of natural man in this period was Lord Shaftesbury. While actually not a Deist, Shaftesbury shares their version of man. He brings a devastating attack against Hobbes' view of man by declaring that "Hobbes in reckoning up the passions and affections which produce society, forgot to mention kindness, friendship, sociableness, love of company, natural affection, or anything of this kind." Shaftesbury is the typical English moralist of the enlightenment. He stands in opposition to all low and gloomy evaluations of man as the champion of unassisted human nature. So certain was he that man possessed the ability to direct his --- 1 The True Gospel of Jesus Christ Vindicated. 2 The Moral Philosopher, Vol. I, p. 98. 3 Characteristicks of Men, Manners, Opinions and Times. own life in the ways of righteousness that he became impatient with all who pictured God as one who provided a dynamic for right living by holding out rewards and punishments before man. For Shaftesbury, to be honest without thought of heaven or hell is the true mark of a real lover of virtue. There is a curious inconsistency in Shaftesbury's view of rewards and punishments. As long as they come in this life they may be the proper motive for moral living and are viewed as a part of the beautiful order of things but the moment they are removed from this life and made a part of the life to come he vehemently denounces them. Shaftesbury based right and wrong on the fundamental constitution of human nature itself, not on the will of God. He could thus maintain that even if one rejected the divine existence, which he did not do, he was nevertheless bound to maintain moral conduct. He had drawn from Whichcote the belief that human nature is not so perverse, but that it retains a 'secret sympathy with virtue and honesty.' Virtue itself is the foundation of happiness and sin brings its own misery. The praise of nature is reflected in all of Shaftesbury's writings. He even insists on the divine perfection of nature, by which he means the whole order of Creation. Professor Willey says: The divinity of Nature (like the 'good nature' of man) is affirmed by Shaftesbury both against the Atheists who think the universe a distracted chaos of atoms, and against the orthodox, who hold that we live in a world which has been permanently ruined by the fall of Adam. Shaftesbury's obsession with the glories of nature is splendidly portrayed in the following paragraph: O Glorious Nature! Supremely fair, and sovereignly good! All-loving and all-lovely, all-divine!......Whose every single work affords an ampler scene, and is a nobler spectacle than all which ever art presented! O mighty Nature! Wise substitute of Providence! impower'd Creator! Thee I invoke, and thee alone adore. To thee this solitude, this place, these rural meditations are sacred; whilst thus inspir'd with Harmony of Thought, tho unconfin'd by Words, and in loose numbers, I sing of Nature's order in created beings, and celebrate the beautys which resolve in thee, the source and principle of all beauty and perfection. 1 Characteristics of Men, Manners, Opinions and Times. 2 The Eighteenth Century Background, p. 62. 3 Shaftesbury's Works, Vol. ii (1727 ed.), pp. 344, 345. For Shaftesbury, true religion should be based upon nature, not upon revelation. He speaks of those who think they are extolling religion by exposing the "Corruption of Man's Heart" and succeed only in setting "moral virtue" as a "rival to religion."¹ Human nature he regards as a microcosm of the greater perfection of the universe. Human virtue, thus is found in following nature, for he thought it natural to be moral. One cannot but admire the efforts of the Deists for they took seriously the task that befell the early decades of the eighteenth century to re-establish a reasonable balance in the moral life of England. These men were neither puritan enthusiasts nor libertines, but sober minded and accomplished men of the world. They felt that uncontrolled enthusiasm in religion and unbridled vice were equally offensive to good taste and good sense. Along with Addison and Steele they sought to make vice ridiculous and to bring to the cause of decency and virtue the powerful allies of wit and good breeding. Thus for the eighteenth century the final court of appeal in matters of belief and conduct came to be reason and its practical ¹ The Moralists, pt. II, sect. 2, Works, vol. ii, p. 256. corollary, good sense. The philosophical rationalism of Descartes, the empiricism of Hobbes and Locke, the newly awakened interest in the natural sciences of which Sir Isaac Newton is typical, the reaction against seventeenth century preoccupation with questions of religion, all conspired to turn men's minds away from the mysteries of life and to focus their attention on the real and actual. Most of the literature of the day was given to moralizing, but its morality was that of enlightened worldliness. In religion and ethics the deeper springs of life had gone dry. The moral code was the product of the divinizing of nature. The maxim of the age became "What is, is right." Until Wesley and his Methodists began their work in 1740, with a strong appeal to the hearts of the people, the Christian religion in the eighteenth century pulpits had become so coldly rational that the orthodox churchman could hardly be distinguished from the "free-thinking" Deist with his reasoned "religion of nature." One historian writes: Never had religion seemed at a lower ebb. The progress of free inquiry, the aversion from theological strife which had been left by the Civil Wars, the new political and material channels opened to human energy, had produced a general indifference to all questions of religious speculation or religious life. The Church, predominant as its influence seemed at the close of the Revolution, had sunk into political insignificance...a large number of prelates were Whig partizans with no higher aim than that of promotion...a Welsh bishop avowed that he had seen his diocese but once, and habitually resided at the lakes of Westmoreland...A shrewd if prejudiced observer brands the English clergy of the day as the most lifeless in Europe, the most remiss of their labours in private and the least severe in their lives..."In the higher circles of society 'everyone laughs,'" said Montesquieu on his visit to England, "if one talks of religion."...Drunkenness and foul talk were thought no discredit to Walpole....Purity and fidelity to the marriage vow were sneered out of fashion; and Lord Chesterfield in his letters to his son, instructs him in the art of seduction as part of a polite education. Among the masses, rank ignorance prevailed. The rural peasantry had been reduced to pauperism by the poor laws and had no moral or religious training whatsoever. Hannah More said, "We saw but one Bible in the parish of Cheddar and that was used to prop a flower-pot." 1 Green, John Richard. A Short History of the English People, pp. 735, 736. The introduction of gin increased the drunkenness of the day until gin shops in London invited every passer-by to get drunk for a penny, or dead drunk for two pence.$^1$ It is altogether possible that these conditions have been somewhat exaggerated by historians, for as W. R. Matthews has said, "Nothing is easier than to draw an indictment against a century."$^2$ We may, however, know for a certainty that there was a characteristic grossness among the masses and a depreciation of idealism among the educated. In spite of her moral degeneration, England remained religious at heart and under the zealous leadership of men like Whitefield and the Wesleys and the equally earnest yet quiet and sane ministry of men like William Paley she was destined to regain her moral self-respect. --- $^1$ Green, John Richard. A Short History of the English People, pp. 1735, 1736. $^2$ Butler, Joseph. Fifteen Sermons and a Dissertation on the nature of Virtue, Editor's Introduction, p. XI. CHAPTER III AN EXPOSITION OF THE PRINCIPLES OF PALEY'S ETHICS Having examined the theological and philosophical trends of the eighteenth century, we come now to ask what was Paley's contribution to the stream of eighteenth century ethical thought? Wherein did his system differ from that of his predecessors? Was his treatment merely an eclectic system or did he differ from those writers like John Gay and Abraham Tucker from whom he drew so heavily? What was the unifying principle of his ethic? Did he give a satisfactory answer to the question, How may a man know his moral duty? What positive and enduring contribution did he make to the field of ethics? In answering these questions it is necessary to remind ourselves that Paley was not striving primarily for originality, although he does lay claim to being something more than a mere compiler.¹ His writing was based largely upon the notes ¹ Paley, William. The Principles of Moral and Political Philosophy, p. XVI. used in his lectures on Moral Philosophy at Cambridge. We should remember, therefore, that it is addressed principally to a class of students. In his presentation Paley expressly avoided the style of writing which prevailed among eighteenth century English moralists. He contended that their style was too ornamental, too full of adornment with no underlying meaning, and too full of superficial embellishments in the form of meaningless quotations from classical writers.$^1$ This, perhaps, was a carry-over from John Milton's strong emphasis upon the necessity of a re-examination of classical writers, which had resulted in a superficial fad of quoting from them whether or not the quotation made a positive contribution to the discussion. Paley was also averse to the fashion of his time of stringing detailed propositions together, a good illustration of which may be found in Dr. Ferguson's Institutes of Moral Philosophy. In contrast to this Paley offers a wealth of relevant discussion and illustrations to vivify his ethical propositions. The simplicity of Paley's style may be traced partly to his aversion to metaphysics and partly to his effort to avoid $^1$ The Principles of Moral and Political Philosophy, p. XVI. dwelling upon verbal and elementary distinctions which he did not believe to be vitally linked to the problems of practical morality. A good example of what he was reacting against may be found in Dr. Rutherford's Institutes of Natural Law. It is quite apparent that even the Deists with whom Paley took issue were averse to metaphysics. They were more interested in what nature teaches all men, king and peasant alike, than they were in that knowledge at which one may arrive at the end of a syllogistic process. For them reason was primarily intuitive, not discursive. It was to Paley's credit that he, like his fellow utilitarians, was more interested in the practical application than in the theory of ethics.¹ The practical nature of his work is manifested in his description of ethics which he defines as "that science which teaches men their duty and the reason for it."² Standing as he did in the midst of men who were endeavoring to arrive at a final principle which would clearly teach all men their duty and thus give to the realm of morals an order resembling that which Newton by his ¹ Mackenzie, John S. A Manual of Ethics, pp. 276, 279. ² The Principles of Moral and Political Philosophy, Bk. I., Ch. V, p. 11. principle of gravitation had given to the world of nature, Paley sought to accomplish this by uniting the law of nature with the precepts of revelation, for he believed it a very regrettable tendency in moral philosophy that these two should be severed. Paley insisted that ethics was not a complete science in itself. He argued with Dr. Johnson that: When the obligations of morality are taught let the sanctions of Christianity be never forgotten: by which it will be shown that they give strength and luster to each other: religion will appear to be the voice of reason, and morality the will of God.$^1$ As we move into the heart of Paley's ethics, let us bear in mind that the purpose of this chapter is to discover the underlying principles of his ethical system and to determine the method by which he arrived at them. One of the major debates among the writers of eighteenth century England centered around the problem of moral knowledge. How is man to know his moral duty? In fact, John Gay declared that this was the only problem on which moralists of his day were not agreed.$^2$ $^1$ The Preceptor, Preface. $^2$ King, William. An Essay on the Origin of Evil, Preliminary Dissertation Concerning Virtue or Merit by John Gay, (1732 ed.), p. XXVIII. Before examining Paley's answer to this question, perhaps it will be well to survey some of the typical answers in vogue in his day. First of all, there were those who still contended that Revelation must give the answer to this question. On the other side were men like Shaftesbury who believed that the defenders of traditional morality, which was based on the revelation of the Bible, had deliberately suppressed independent discussion of morals. He wrote: So much is the religious part of mankind alarmed by the freedom of some late pens, and so great a jealousy is raised everywhere on this account, that whatsoever an author may suggest in favour of religion, he will gain little credit in the cause if he allows the least advantage to any other principle. There was also in vogue in this period a fashionable cynicism which held that moral codes were either pernicious restraints upon human energies or artful impositions by statesmen upon the common herd. A good example of this is found in the Maxims of Rochefoucauld and Mandeville's Fable of the Bees. The real father of such philosophy, however, is Thomas Hobbes, 1 Characteristicks of Men, Manners, Opinions and Times, (1727 ed.), p. XXVIII. 2 Matthews, W. R. Butler's Fifteen Sermons, Introduction, p. XII. He was a thoroughgoing materialist believing that all that exists is matter in motion. The soul as an immaterial entity is nonexistent. Even material phenomena are the "internal" motions of material particles. In his attempt to show how the laws of human nature and society may be deduced from the laws of motion he maintained a consistent devotion to his materialistic philosophy. This theory led him to undertake an analysis of the mind in which he dealt primarily with desire and will. For Hobbes, man is a bundle of desires, the satisfaction of which is provided by external things. These desires are strictly analogous to physical forces, and there is no real freedom of choice, for the will becomes identified with the strongest desire. The objects of man's desires in the state of nature are either pleasure or self-preservation. In man's more advanced stage as he develops his reason he begins to desire a third object, namely, power. This desire is awakened as man projects himself into the future and realizes his need for security. At this point Hobbes' illustrious doctrine of the natural egoism of man emerges. By nature man is not a social being but is governed by three basic desires, namely, for pleasure, for preservation, and for power. Hobbes felt that to be consistent with his position he must demonstrate that the so-called social affections are no more than egoism in disguise. On pity he writes the following: Pity is the imagination or fiction of future calamity to ourselves, proceeding from the sense of another man's calamity. But when it lighteth on such as we think have not deserved the same the compassion is greater, because then there appeareth more probability that the same may happen to us: for the evil that happeneth to an innocent man may happen to every man. On Charity Hobbes writes in a similar vein: There is yet another passion sometimes called love but more properly good will or charity. There can be no greater argument to a man of his own power than to find himself able not only to accomplish his own desires but also to assist other men in theirs: and this is that conception wherein consisteth charity. In which, first is contained that natural affection of parents to their children...as also that affection wherewith men seek to assist those that adhere unto them. But the affection wherewith men many times bestow their benefits on strangers is not to be called charity, but either contract, whereby they seek to purchase friendship, or fear, which maketh them to purchase peace. By attempting to show that all affections have their source in self-interested love of power or pleasure, Hobbes --- 1 Human Nature, IX., p. 10. 2 Ibid., IX. 17. believes he has thus proved that genuinely disinterested affections are impossible. The consequence of such ethical theory is that it makes it impossible to speak of a common good which transcends and includes the true good of every man. Instead of a universal good there are as many goods as there are individuals. This is the strong emphasis which Hobbes continually makes: Every man for his own part, calleth that which pleaseth him and is delightful to himself, good and that evil which displeaseth him: insomuch that while every man differeth from another in constitution, they differ from one another concerning the common distinction between good and evil. Nor is there any such thing as absolute goodness, considered without relation: for even the goodness which we apprehended in God Almighty is His goodness to us!¹ On the nature of man Hobbes wrote that man stands in need of society, but because of his fundamental egoism he is unfit for society.² Man's natural condition is a state of 'a war of all against all.' This state is one of "continual fear and danger of violent death, and the life of man, solitary, poor, nasty, brutish and short."³ ¹ Human Nature, VII, 3. ² De Homine. (Latin Works, Molesworth's edition), Vol. II, p. 91. ³ Leviathan. p. xiii. To remedy this Hobbes proposes a "social contract" in which the individual surrenders to the state. An absolute government must be established to which the individual agent would yield his individual allegiance giving up everything save the right of defending himself from personal violence. The civil power would change the many conflicting wills into one will. It would define that which is just and that which is unjust and would even serve as the judge of all theological doctrines: It is as if every man should say to every man, I authorize and give up my right of governing myself to this man or to this assembly of men, on this condition, that thou give up thy right to him and authorize all his actions in like manner. This done, the multitude so united in one person is called a commonwealth....This is the generation of that great Leviathan, or rather (to speak more reverently) of that mortal God to which we owe, under the immortal God, our peace and defence. For Hobbes a man's moral duty is what the state says it is, for morality consists in those general rules, which Hobbes called "natural laws", which are necessary for the maintenance of society. W. R. Matthews calls attention to a point that has often been overlooked by the critics of Hobbes, namely, that 1 Leviathan, p. xvii. morality is rational and universal, for the general rules of society must be based upon reason and are always the necessary supports of that social order which is prerequisite to the welfare of the individual.$^1$ This does not, however, alter the fact that, for the individual, the source of moral obligation is not reason itself but the commands of the State: In the state of nature where every man is his own judge, and differeth from others concerning the names and appellations of things, and from those differences arise quarrels and breach of peace, it was necessary there should be a common measure of all things that might fall in controversy. As, for example, of what is to be called right, what good, what virtue... This common measure some say is right reason, with whom I should consent if there were any such thing in rerum natura. But commonly they that call for right reason to decide any controversy do mean their own. But this is certain, seeing right reason is not existent, the reason of some man or men must supply the place thereof and that man or men is he or they that have the sovereign power, and consequently the civil laws are to all subjects the measures of their actions, whereby to determine whether they be right or wrong, profitable or unprofitable, virtuous or vicious.$^2$ --- $^1$ Butler, Joseph. Fifteen Sermons and a Dissertation on the Nature of Virtue, Introduction, p. xvi. $^2$ De Corpore Politico, ii. 10.8. Hobbes' cynical view of man's inability to answer for himself the question of his moral duty was the center of much controversy among later moralists. Generally speaking there arose in opposition to his contentions two schools of thought known respectively as rational intuitionism and aesthetic intuitionism. Rational intuitionism was the product of the Cambridge Platonists who reacted against the tendency in Hobbes' philosophy to make morality an arbitrary matter of convention. They insisted that moral ideas are as universal and unalterable as the ideas of the intellect and that morality is rooted in the nature of the universe. Ralph Cudworth is the leading exponent of this position. Not only does Cudworth reject the idea that morality depends on the arbitrary law or convention of the state, but he also denounces the view of Calvin that morality depends on the arbitrary will of God. He contends that all knowledge is concerned with nothing else but universal ideas which are forever the same. He writes: There is no such thing as arbitrarious Essence, Mode or Relation that may be made indifferently anything at pleasure for an arbitrarious essence is a being without nature a contradiction and therefore a nonentity. Wherefore the natures of Justice and Injustice cannot be arbitrarious things that may be applicable by will indifferently to any actions or dispositions whatsoever. For the modes of all subsistent beings and the relations of things to one another, are immutably and necessarily what they are, and not arbitrary, being not by will but by nature.$^1$ Another refutation of the philosophy of Hobbes in vogue in the eighteenth century was that of Antony Ashley Cooper, the third Earl of Shaftesbury. He is the author of what came to be known as the "Moral Sense Theory" or "Aesthetic Intuitionism." Shaftesbury's supreme emphasis was on his interpretation of the nature of conscience. He believed in a special moral faculty in man, which he called the "moral sense", and which he defined as "a real affection or love towards equity and right, for its own sake, and on the account of its own natural beauty and worth."$^2$ This faculty enables men to distinguish between individual actions and thoughts as to their rightness and wrongness as they occur and is closely analogous to aesthetic appreciation or the sense of beauty. Man's moral sense enables him to distinguish between the base and ignoble just as his sense of beauty enables him to --- $^1$ Eternal and Immutable Morality, First Edition, pp. 16, 17. $^2$ Inquiry Concerning Virtue or Merit (1699), p. 31. discriminate between the unsightly and the beautiful. For Shaftesbury this moral sense or conscience was not based upon principles of morality. It was not a rational function by which man might apply the laws of morality to his conduct. On the contrary, it was man's instinctive ability to sense immediately the rightness of a virtuous action and the wrongness of a vicious one. It should be remembered, however, that Shaftesbury did not draw from the above that the good is primarily a matter of independent judgment. On the contrary, for him moral distinctions have independent reality, that is to say, a good act is good whether we apprehend its moral quality or not. Objectively a thing is good if it is in harmonious relations with the system of which it forms a part, and human goodness consists in being in harmony with the species to which the individual belongs. The ultimate criterion is the general good, hence benevolence is the sum of goodness. Since goodness is harmonious living, the virtuous man is one who maintains a balance between the social and altruistic impulses. Furthermore, Shaftesbury contends that even in the present world self-interest and virtue always coincide: To be well affected towards the Public Interest and one's own is not only consistent but inseparable; moral rectitude or virtue must be the advantage and vice the injury and disadvantage of every creature.\textsuperscript{1} Both Shaftesbury and his disciple, Hutcheson, had no conception of a rational or organic union between individual sentiment and social well being except the traditional one of exhibiting the personal advantages of benevolent conduct, and the disadvantages that accompany selfishness. Butler was not free from this. He thinks that Shaftesbury "has shown beyond all contradiction that virtue is naturally the interest or happiness and vice the misery of such a creature as man."\textsuperscript{2} For Butler the approval of conscience is thus made the criterion of morality. But a difficulty arises as to the way in which we are to regard the authority which conscience is said to carry along with it. Butler's utterances here commonly imply a teleological reference to an end implanted in human nature, and to be discovered by observing that nature—the realization of the end being obligatory, because it is shown to be the purpose which the author of nature had in view in making man as he is.\textsuperscript{3} The authority of conscience is derived from the purpose which it displays and \textsuperscript{1} \textit{Characteristics of Men, Manners, Opinions and Times}, (1711), Vol. II, p. 81; cf. pt. II., sects. 1 and 2. \textsuperscript{2} \textit{Sermons}, p. 103. \textsuperscript{3} \textit{Ibid.}, p. 104. carries within itself a claim to obedience; however, the justification of this claim depends on a theological basis. Hence, the question of the nature and origin of conscience is at once raised in order to determine the legitimacy of its claim to be rather than any other part of our constitution, a divinely-implanted guide. When Bishop Butler thus undertook to give an answer to the question of how man knows his moral duty, he appropriated the method used previously by Hobbes of inquiring into man's constitution, and undertaking an analysis thereof. His method, however, is not that of pure observation, for in the very outset he assumes the existence of final causes.$^1$ He likewise assumes the principle that if the nature of a creature is adapted to certain purposes, it was intended for those purposes,$^2$ and then proceeds to examine the nature of man to determine for what purpose it is adapted, believing that man will reach his highest goal by conforming to that purpose which is according to his nature. He warns against those erroneous views of what it means to follow nature, and concludes that the true meaning of following nature is to act in conformity with human nature taken as a whole, which involves the recognition of the supremacy of Conscience.$^3$ $^1$ Butler, Joseph. Fifteen Sermons and a Dissertation upon the Nature of Virtue, p. 47. $^2$ Ibid. $^3$ Ibid., pp. 50-53. Professor C. D. Broad points out that which Butler fully recognizes but does not endeavour to remedy, namely, that in one sense nobody can act against his nature. Broad writes: I think it would be better to say that virtue consists in acting in accordance with the ideal nature of man, and that vice consists in acting against it. No man's actual nature is the ideal nature of man. But this raises no special difficulty. We can form the conception of a perfect watch although no real watches are perfect. By employing the idea of a system used previously by Shaftesbury, Butler insisted that the essential thing about man as a moral being is that he is a complex whole of various propensities arranged in a hierarchy. These propensities must be kept in the proper relation of subordination to one another. That is to say, human nature is not what Hobbes said it was, namely, a mass of faculties and impulses. On the contrary it is capable of a systematic unity characterized by harmonious proportion. Furthermore, that harmony does not consist in a "mere balance" between self-regarding and benevolent tendencies, as Shaftesbury had taught. It is to be found in the subordination of the lower elements to those 1 Broad, C. D. Five Types of Ethical Theory, p. 57. which are in their nature, more authoritative.\textsuperscript{1} The superior principles in the nature of man are reasonable self-love and conscience.\textsuperscript{2} Sidgwick calls attention to a very common error with regard to these two principles, namely, that self-love is naturally subordinate to conscience.\textsuperscript{3} These, in reality, are co-ordinate in their authority. Butler writes: Reasonable self-love and conscience are the chief or superior principles in the nature of man: because an action may be suitable to this nature, though all other principles be violated, but becomes unsuitable, if either of those are.\textsuperscript{4} There are, however, passages in Butler's writing which have three possible interpretations. Namely, that Conscience is supreme,\textsuperscript{5} that Self-love is supreme\textsuperscript{6} and that the two have equal authority.\textsuperscript{7} Perhaps we can see in these passages \begin{itemize} \item \textsuperscript{1} Butler, Joseph. \textit{Fifteen Sermons and A Dissertation on the Nature of Virtue}, p. 68. \item \textsuperscript{2} \textit{Ibid.}, p. 57. \item \textsuperscript{3} \textit{Ibid.}, p. 182. \item \textsuperscript{4} \textit{Ibid.}, p. 68. \item \textsuperscript{5} Broad, C. D. \textit{Five Types of Ethical Theory}, p. 57. \item \textsuperscript{6} Butler, Joseph. \textit{Fifteen Sermons and A Dissertation on the Nature of Virtue}, Introduction by W. R. Matthews, p. XXII. \item \textsuperscript{7} \textit{Ibid.}, p. 68. \end{itemize} the inconsistency in Butler's theory. On the nature of Conscience, Butler occupies a halfway house between rational and aesthetic intuitionism. Apparently he agrees with Shaftesbury that there is a special moral faculty, but he makes it more than feeling or instinct. He calls it a "principle of reflection." Hence, it partakes of the nature of reason. Yet he did not identify it with reason as did the theoretical and the rational intuitionists. Butler makes duty coincident with our private interest. This is true for the most part in this world and entirely true in the next world. He, however, was not guilty of drawing a line of cleavage between this life and that which is to come. He simply views them as parts of the whole picture of man's existence. He also was recognizing the superficiality in Shaftesbury's view that virtue and self-interest are in perfect agreement in this life. Because this is manifestly untrue, Butler clings to his belief in a moral Governor of the universe who will in the future life be able to correct any discrepancies in the present. 1 Butler, Joseph. Fifteen Sermons and a Dissertation on the Nature of Virtue, p. 68. It should also be observed that in contrast with Hobbes, Butler contends that the social order is not artificial but natural. "It is as manifest that we were made for society, and to promote the happiness of it; as that we were intended to take care of our own life, and health, and private good."¹ He was thus transcending the exaggerated individualism of Calvinism and making an appeal for a proper regard for the wholeness of life. In fact, he concluded that the rightness or wrongness of an action, or even of an intention, can be judged only by viewing it in relation to the whole system in which it is a factor.² We might state his answer to how a man may know the good, in W. R. Matthews' summary of his position: "Anything is good which is in harmonious relations with the system of which it forms a part."³ Butler's teleological view of human nature is seen in his insistence that the dictates of conscience are the voice of God and not the pronouncement of a merely subjective tribunal. He contended that man is to act conformably to the economy of his nature by --- ¹ Ibid., p. 40. ² Broad, C. D. Five Types of Ethical Theory, p. 57. ³ Matthews, W. R. Introduction to Butler's Fifteen Sermons and a Dissertation on the Nature of Virtue, p. 55. allowing reasonable self-love to govern.\textsuperscript{1} The above arguments were in vogue when Paley took up his pen and sought to answer the question of how man knows his moral duty. He began by denying the theory of Shaftesbury and the intuitionists and by contending that all the supposed phenomena of the "moral sense" can be explained on the basis of expediency and that expediency is the objective principle by which all moral conduct must be judged. To enforce his belief that some new objective principle for the judging of moral conduct was necessary Paley pointed out the inadequacy of the methods by which morality was judged in his day. Instead of joining issue with the great basic systems of morality, he chose to deal with the common devices by which morality was measured in his day. The various devices for judging moral conduct with which Paley was familiar were: the law of honor, the law of the land, the Scriptures, and the moral sense. It is apparent that in distinguishing these different kinds of law, Paley was following Locke rather closely.\textsuperscript{2} \textsuperscript{1} Matthews, W. R. Introduction to Butler's \textit{Fifteen Sermons and a Dissertation on the Nature of Virtue}, p. 55. \textsuperscript{2} \textit{An Essay concerning Human Understanding}. Bk. II, Ch. XXVIII, p. 201. By the law of honor, Paley meant what Locke calls the law of opinion or reputation$^1$ or what came later to represent the etiquette of particular trades and particular classes of society.$^2$ In one of his sermons Paley writes the following: I should call the law of honor a system of rules well contrived by persons in the higher stations of life, to facilitate their intercourse with each other.$^3$ Paley contended that this law could not tell a man all of his moral duty because it only prescribes and regulates the duties between equals and thus omits those that relate to the Supreme Being, as well as those which we owe to our inferiors.$^4$ He saw that while some impulses of a man's heart may be checked by certain generally understood conventions and while the approval of society affords a strong sanction for obeying her customs, even so, there are times when eccentricity has its place in the moral life, and a man may be more truly moral by breaking the customs of his community than by keeping them. --- $^1$ An Essay Concerning Human Understanding, Bk. II, Ch. XXVIII, p. 202. $^2$ Mackenzie, John S. A Manual of Ethics, p. 342. $^3$ The Sermons of William Paley, Vol. V., Sermon XLVIII, p. 431. $^4$ The Principles of Moral and Political Philosophy, Bk. I, Ch. ii, p. 2 For example, if he should live in a community where infanticide is practiced, he would be more truly moral and would be obeying a higher law if he should repudiate this custom. The varying customs among different groups also reveal their inadequacy as an ideal for man's conduct. For example, a Chinese is very little ashamed of being detected as a cheat, but he would be manifestly disgraced if he did not treat his parents with proper respect or if he did not keep the tombs of his ancestors in good repair. Perhaps the chief weakness in Paley's argument at this point is due to his meager definition of the law of honor. This law is not confined to the rules of fashionable life. Rather, it is rooted in human nature and is felt by all levels of life from the savage to the monarch. The desire of the approval of one's fellows is to be found everywhere. At the same time, it must be allowed that a writer has the right to define his own terms, and it must be admitted that as Paley defines the law of honor his argument against its adequacy is very convincing. Paley also refused to accept Hobbes' position that the law of the land must tell a man what is right and what is wrong. Paley found the law of the land or the civil law to be inadequate for settling moral questions because it labors under two difficulties; first, because the law commands only where it is able to compel, consequently those duties, which by their nature must be voluntary, lie beyond the reach of its power; secondly, because the distinction between right and wrong is often too subtle to be stated in a law. Paley saw that civil laws are neither constant nor universal and while they bind a large segment of society, they break down as a power for moral rectitude when the circumstances which made these laws necessary change and when man's character changes. The civil law also recognizes that there are many duties which are not fit objects for compulsion. On the other hand, it permits many crimes which are incapable of definition, for no general rules can ever exactly fit a particular case. Paley thus points out the defects in the system that would regard human laws as a worthy rule of life. It is possible that a man might keep the written law entirely and still have the 1 De Corpore Politico, ii. 10.8 2 The Principles of Moral and Political Philosophy, Bk. I, Ch. ii, p. 2. 3 Ibid. wrong motive. Goodness of motive is essential to virtuous conduct. For instance, if a man simply pays his debts to avoid imprisonment, this would not of itself make him an honest man. In a charge to Clergymen, Paley cautions them against those members of their congregations who hold that the law of the land is an adequate monitor for the moral life: Amongst the rules which contend with religion for the government of life, the law of the land also has not a few who think it very sufficient to act up to its direction, and to keep within the limits which it prescribes, and this sort of character is common in our congregations. We are not to omit, therefore, to apprise those who propose to themselves a measure of conduct totally inadequate to the purpose. The boundaries which nature has assigned to human authority, the partial ends to which every legislator is obliged to confine his views, prevent human laws, even were they, what they never are, as perfect as they might be made from becoming competent rules of life to anyone who advances his hopes to the attainment of God Almighty's favour. In contradistinction, then, to these several systems which divide a great portion of mankind amongst them, we preach "faith which worketh by love," that principle of action and restraint which is found in a Christian alone."¹ A common misunderstanding of Paley is that he insisted ¹ Paley's Sermons. that the Scriptures alone are sufficient to define man's moral duty. Even W. R. Sorley made this mistake in his interpretation of Paley.¹ What Paley actually says is that the Scriptures are final where they speak but are inadequate as a system of morals because they do not attempt to give a detailed statement of man's duty but prefer rather to lay down such general rules as "worshipping God in spirit and in truth; doing as we would be done by; loving our neighbors as ourselves; forgiving others, as we expect forgiveness from God."² This might appear to be a unique statement for so orthodox an apologist as Paley. In reality, Paley was going back to an emphasis that had appeared often in the preaching of Archbishop Tillotson almost a century before.³ The writers of Scripture, according to Paley, assume that the persons addressed already possess a knowledge of the principles of natural justice. Therefore, they design their teaching not to present new rules of morality but to enforce the practice of morality by new sanctions and a greater --- ¹ Sorley, W. R. A History of English Philosophy, p. 201. ² The Principles of Moral and Political Philosophy, Bk. I, Ch. iv., p. 5. ³ Moffatt, James. The Golden Book of Tillotson, pp. 166, 169. certainty. Paley is here stating what is most certainly true about the Scriptures but it is exceedingly difficult to see how he can contend for this and in subsequent parts of his treatise contend that man is destitute of a moral sense. Perhaps again Paley has been misinterpreted. A number of critics take him to task most severely at this point.$^1$ Their mistake, as I shall later point out, was in interpreting Paley's denial of the innateness of the moral sense to mean that man was destitute of a conscience. Paley's critics, who have insisted on taking him literally and reading into his statements what he never intended, have said that he placed expediency above the authority of the Scriptures.$^2$ It was Paley's intention, however, to apply this principle only where Scripture is silent, or where it is not specific or where it is doubtful. For instance, Scripture declares itself against covenant-breakers. We bow to the decision—but what is a covenant? and what is it to break one?—this Scripture does not define. Here, therefore, we want a principle to guide us before we can apply Scripture. What is the principle? Expediency, says Paley. $^1$ Whately, Richard. Paley's Moral Philosophy with Annotations, p. 23. $^2$ Gisborne, Thomas. The Principles of Moral Philosophy Investigated and Applied to the Constitution of Civil Society, Bk. II, Ch. vi., p. 46. take another instance: Scripture declares itself against a lie; we allow the authority; "but what is truth?" may be asked with Pilate and surely without any irreverence. What principle is to decide us in determining the offence against which Scripture has fixed its canon? — Expediency, again, says Paley. "Resist not evil" is a positive injunction of Scripture, yet from other passages it is certain that occasions there may be where resistance is lawful. By what principle are we to draw the line? By the principle of expediency once more says Paley. We may thus conclude that while it is true that some strong statements such as "the utility of any moral rule alone it is which constitutes the obligation of it" would imply that Paley would exclude every other principle of judging moral conduct, in reality, this is just an inadvertent expression of a man enamoured by his system and not an adequate explanation of his total doctrine. Paley combines the authority of reason and Scripture in the following passage from one of his sermons: "To take for our guidance the rule of reason and the rule of Scripture is the perfection of moral excellence." 1 The Principles of Moral and Political Philosophy, Bk. II, Ch. vi, p. 46. 2 Paley's Sermons, Sermon XLVIII, p. 426. Paley continues his discussion of the inadequacy of the Scriptures by insisting that to deliver moral disquisitions was no part of the Savior's design: To teach morality at all was only a subordinate part of it, his great business being to supply what was more wanting than lessons of morality, namely, stronger moral sanctions and clearer assurances of a future judgment.$^1$ The Gospel stands in marked contrast with religious books that attempt to regulate human conduct by minute directions for every case and occurrence that may arise. For example, the Hindoo and Musselman religions attempt this, and to demonstrate the futility of such efforts, it has been observed that in the Musselman Code not less than seventy-five thousand precepts have been promulgated. Over against this Paley sets the fact that "the Christian religion has not ascertained the precise quantity of virtue necessary to salvation."$^2$ Indeed human language is not an adequate vehicle for conveying such knowledge, nor is it possible to constitute a standard of moral attainments accommodated to the almost --- $^1$ Evidences of Christianity, p. 256. $^2$ The Works of William Paley, Vol. V, p. 168, Sermon XIX. infinite diversity which subsists in the capacities and opportunities of different men. Paley might have been closer to the New Testament if he had suggested as did St. Paul, in his doctrine of justification by faith, that God does not measure a man by the distance a man has travelled on the journey toward perfection but by the direction of his life. He asks not whether a man has arrived, but does he have his face or his back towards the goal? Not only did Paley find the law of honor, the law of the land and the law of Scripture incapable of defining man's moral duty, but he also took violent issue with the moral sense philosophers, because they had threatened to make religion superfluous by an unrealistic exaltation of man. It has been objected that Paley also painted an unrealistic picture of man's ability by assigning to him, by his utilitarian theory, the power to predict even the infinite consequences of his action.$^1$ It is true that he claims that "Whatever is expedient is right."$^2$ --- $^1$ Dymond, Jonathan, Essays on the Private and Political Rights and Obligations of Mankind, p. 5. $^2$ The Principles of Moral and Political Philosophy, Bk. 2, c. 6, p. 46. However, Paley recognizes the limitations of this principle as he declares that "it is impossible to ascertain every duty by an immediate reference to public utility."¹ To compensate for such a limitation, said he, it is necessary to have certain established rules, which are absolutely obligatory, by which conduct may be gauged. The belief in conscience appears very early in English philosophy. Even Lord Bacon could write the following: "The light of nature not only shines upon the human mind through the medium of a rational faculty, but by an internal instinct according to the law of conscience, which is a sparkle of the purity of man's first estate." The denial of an innate moral sense, however, placed Paley in a tradition that was by no means new. John Gay and Abraham Tucker had given much attention to it. It was substantially the position advanced by Hobbes in the Leviathan and goes back at least as far as Aristotle's time when there were those who maintained that the diversities that appear in men's moral --- ¹ The Principles of Moral and Political Philosophy, Bk. 6, c. 12, p. 499. notions militate against the idea that the distinctions of moral right and wrong have any foundation in nature.$^1$ It should be noted that Paley does not attempt to give a thorough treatment of the nature and origin of the moral sense. He leaves this for those who were more inquisitive than he was concerned to be about the natural history and constitution of the human species.$^2$ For a proper evaluation of his position, however, it is necessary to inquire into the meaning of the moral sense in Paley's day. The ambiguity of the term makes it necessary to say a word about its meaning. In the first place, it should be noted that Butler, who gives the idea such prominence in his system, used the terms conscience, moral reason, moral sense or divine reason interchangeably.$^3$ Butler defines these terms simply as the "moral approving and disapproving faculty."$^4$ He writes: --- $^1$ Nicomachean Ethics, Bk. V., pp. 126, 128. $^2$ The Principles of Moral and Political Philosophy, Bk. II. C. V, p. 14. $^3$ Butler, Joseph. Fifteen Sermons and a Dissertation Upon the Nature of Virtue. Introduction and Notes by W. R. Matthews, p. 247. $^4$ Ibid. This way of speaking is taken from Epictetus, and is made use of as seeming the most full, and least liable to cavil. And the moral faculty may be understood to have these two epithets $\delta\omega\kappa\mu\alpha\sigma\tau\kappa\nu$ and $\alpha\tau\alpha\delta\omega\kappa\mu\alpha\sigma\tau\kappa\nu$, upon a double account, because, upon a survey of actions, whether before or after they are done, it determines them to be good or evil; and also because it determines itself to be the guide of action and of life, in contradistinction from all other faculties, or natural principles of action, in the very same manner as speculative reason directly and naturally judges of speculative truth and falsehood; and at the same time is attended with a consciousness upon reflection, that the natural right to judge of them belongs to it. Butler differed radically with Shaftesbury in his view of the moral sense. For Shaftesbury, the moral sense was a cultivated good taste which in a well-developed character passes into a kind of instinct which guarantees the choice of right and the avoidance of wrong. Both Shaftesbury and his disciple, Hutcheson, believed that what a cultivated moral sense approves is that which is beneficial to society as a whole. They urged, however, that it was not necessary to reflect upon this principle, --- 1 Ibid. 2 Characteristicks, "An Essay on the Freedom of Wit and Humour." Part III, Sect. IV. because it is embodied naturally in a cultivated taste. Butler stood against this view by making conscience the principle of reflection upon the law of rightness to which all the other impulses in human nature must be subordinate. The term conscience, is derived from the Latin conscire, to be conscious (of wrong). The Greek \textit{conscience}, the German Gewissen, and the old English Inwit, are similar in meaning. Conscientia used to be employed almost indifferently for conscience and for consciousness in general. The French writer, Malebranche, to whom Hume was so deeply indebted, used the term, conscience, more particularly in the sense of self-consciousness. Milton used the term to signify consciousness when in referring to the loss of his eyes he wrote: What supports me dost thou ask? The conscience, Friend, to have lost them overplaid In liberty's defence, my noble task, Of which all Europe rings from side to side. This passage, however, carries with it also the implication of a moral consciousness. The term took on a definitely moral connotation with the writings of Butler. Mackenzie calls attention to the fact that: \footnote{Matthews, W.R. \textit{Fifteen Sermons and a Dissertation Upon the Nature of Virtue} by Joseph Butler, 1949, Sermon II, pp. 56, 57.} Even in the moral sense of the term there is some ambiguity. It sometimes means a feeling of pleasure or pain, and especially a feeling of pain, accompanying the violation of a recognized principle of duty. At other times it means the principle of judgment by which we pronounce one action or one kind of action to be right and another wrong. In the latter sense, again, it may refer to this principle of judgment as it appears in a particular individual or in a body of men. Such phrases as 'the Non-conformist Conscience,' 'the Conscience of Europe' and the like, illustrate this use of the term. Paley's debate with the moral sense philosophers raged around the fact that they refused to go behind the mere facts of moral experience. His thought on the subject was the legitimate result of a thoroughgoing empiricism derived from Locke. He held that instead of being born with an adequate supply of moral maxims, we, in reality, obtain our first notions of moral good and evil by observing the conduct of others. He followed Locke and Tucker in thinking of man as a receptive waxen tablet rather than a bundle of tendencies and predispositions. As previously stated Paley had no debate with the fact that man was in possession of a conscience. On the contrary, his sermons abound in such passages as follow: --- 1 Mackenzie, J.S. A Manual of Ethics, fourth edition, 1900, p. 146. A serious man hardly ever passes a day, never a week, without meeting some warning to his conscience. The quickening or stirring of conscience within us is sometimes the first sign of a renewed and regenerated soul. There have been disputes concerning this principle of conscience, its origin, nature, extent, but all sides agree on one thing, namely, that it may be dead for a time in the human breast without any energy or activity whatsoever. The causes of this torpor and deadness, or rather the circumstances under which it is found have been often assigned. In many cases, I am afraid, it takes place so early in life that the person can hardly be said to have ever known what the remonstrances and admonitions of conscience were—This state of complete depravity in the effect of a totally neglected education, and of being thrown, when very young, amongst profligate examples. Paley's insistence that the moral sense is not innate but a product of education is seen further when he declares that: When a mind, perfectly ignorant, uninstructed and uneducated, falls at first into debauched and profligate society, then it is possible that conscience may never spring up—its influence over the heart may never have a commencement. --- 1 The Works of William Paley, Vol. V, Sermon 4, p. 23 2 The Sermons of William Paley, p. 115. 3 Ibid., p. 116. Hutcheson, who had developed the system of Shaftesbury, had contended from the fact that the majority of men approve of virtue immediately and apparently without regard to their own interest that only the presence of an innate moral sense could account for this. He held that the moral sense is "a determination of our minds to receive amiable or disagreeable ideas of actions." It should be said that Hutcheson later relinquished the view of the moral sense as a feeling of pleasure or pain and thought of it as a regulator of all our powers. John Gay, whose influence on Paley came indirectly through the works of Abraham Tucker, held that instead of untying the knot, Hutcheson simply cut it. That is to say, he felt that Hutcheson had not in reality explained disinterested action when he naively referred to the operation of an innate moral sense. Gay undertook to account for man's approval of good by a theory which later flowered into the associational psychology. He admitted that men approve virtue immediately and yet affirmed that such approval was the result of their having in 1 Inquiry Into the Original of Our Ideas of Beauty and Virtue, p. 94. the past associated pleasure with that which is approved. The love of money is used by Gay to illustrate the above. He states that men were not born with the love for money but rather perceived at first the many advantages money would bring. From thence they perceive the pleasure of possessing money, thence they desire and endeavor to obtain it. Then an actual pleasure is experienced in obtaining it. Thenceforth they desire to preserve the possession of it. Gay continues: Hence by dropping the intermediate steps between money and happiness, they join money and happiness immediately together and content themselves with the fantastical pleasure of having it, and make that which was at first pursued only as a means, to be to them a real end, and what their real happiness, or misery consists in. This principle of association, which was later to become prominent in the work of David Hartley, Gay believed to be sufficient to explain the disinterested practice of virtue. Concluding his answer to Hutcheson's doctrine, Gay writes: It is necessary in order to solve the principle actions of human life to suppose a moral sense (or what is signified by that name) and also public affections: but I deny that this moral sense, 1 An Essay on the Origin of Evil, p. LLV. or these public affections are innate or implanted in us; they are acquired either from our own observation or the imitation of others. A closer examination of Paley's argument will reveal how similar his approach was to that of Gay. He introduces his argument with a story that apparently was very familiar to the moralists of his day: The father of Caius Toranius had been proscribed by the triumvirate. Caius Toranius, coming over to the interests of that party, discovered to the officers who were in pursuit of his father's life, the place where he concealed himself, and gave them withal a description, by which they might distinguish his person when they found him. The old man, more anxious for the safety and fortunes of his son than about the little that might remain of his own life, began immediately to inquire of the officers who seized him, whether his son was well, whether he had done his duty to the satisfaction of his generals? "That son," replied one of the officers, "so dear to thy affections, betrayed thee to us; by his information thou art apprehended and diest." The officer with this struck a poniard to his heart, and the unhappy parent fell, not so much affected by his fate, as by the means to which he owed it. The question is then raised, if this story were related to a savage without experience, and without instruction, cut off 1 Ibid., p. LXII. 2 Paley, William, The Principles of Moral and Political Philosophy, Bk. I, Ch. v, pp. 6, 7. in his infancy from all intercourse with his species, and, consequently, under no possible influence of example, authority, education, sympathy or habit, whether such a one upon hearing this story would feel any degree of disapprobation of Toranius's conduct? Those who believe in the existence of the moral sense say that he would. It should be noted here that Paley is using an impossible analogy. If such a person should be found, it would hardly be proper to use him as a case in point from which to deduce that which is native to a normal man, for the obvious reason, that man upon coming into the world comes into a society, and that which is developed in such a society is a part of his normal equipment. Apart from such society it is doubtful if he could learn to reason, and the analogy could, in this instance, be used just as well to argue that the ability to reason is not the gift of nature to man. Those who believe in an innate moral sense do so on the grounds that examples of generosity, gratitude and fidelity are immediately approved while their opposites are immediately condemned without deliberation and without having any personal interest in them. They contend that many times we are unable to state a reason for our approbation. Furthermore, it is affirmed that this approbation is uniform and universal and therefore indicates the operation of the moral sense. Replying to these arguments Paley follows Locke's pattern of disproving innate ideas by asking if there are innate moral maxims, how many are there and what are they? Paley first of all denies the uniformity of moral approbations, contending that, "there is scarce a single vice which in some age or country of the world has not been countenanced by public opinion."¹ He cites as an example the fact that in some lands it is considered man's chief responsibility to care for his aged parents while in other lands it is considered an obligation to dispatch them out of the way. What Paley overlooks is the fact that even in the lands where the aged parents are destroyed the motive behind it is to save them from a wretched old age and is, therefore, a benevolent motive. From this it might be argued that man is universally prompted to do good whether or not there is agreement on what the good is. Secondly, he contends that the general approbation of some actions can be accounted for without the assistance of the ¹ The Principles of Moral and Political Philosophy, Bk. I, Ch. V, p. 8. moral sense. Here Paley goes back to Gay who had shown that approbations are not innate or implanted in us by way of instinct but are all deduced from the fact that rational creatures are dependent upon one another for their happiness. 1 Rather than an innate moral sense man has only the ability to determine what is best for himself and others. Paley accounted for the general approbation of certain actions by saying that these actions had proved beneficial in past experience and that after such approbation has arisen in our minds, the sentiment continues to accompany our idea of the same conduct although the benefit which incited it no longer exists. Taking its rise in this manner the continuity of the custom of approving certain actions may be accounted for by the principle of authority, by the principle of imitation and by the habit of approving certain actions inculcated in early youth. 2 As men grow up there arise fresh accessions of moral strength and vigor from censure and encouragement, from the reading of books and the hearing of conversations. Thus moral approval and disapproval of --- 1 An Essay on the Origin of Evil, p. XXXVI. 2 The Principles of Moral and Political Philosophy, Bk. I, Ch. V, p. 10. certain acts is communicated to all members of society. For Paley the distinctive faculty in man that separates him from the brute is not an innate moral sense but the ability to judge what is best for him and his ability to be trained along moral lines. His conscience then is the product of the impact made upon him by his society. Paley draws upon Hume for the reinforcement of his argument. Hume writes the following: From instances of popular tumults, seditions, factions, panics, and of all passions which are shared with a multitude, we may learn the influence of society in exciting and supporting any emotion; while the most ungovernable disorders are raised, we find, by that means, from the slightest and most frivolous occasions. He must be more or less than man who kindles not in the common blaze. What wonder, then, that moral sentiments are found of such influence in life, though springing from principles which may appear, at first sight, somewhat small and delicate.¹ Paley sees the principle of imitation as a vital factor in the determination of moral conduct. In his discussion of imitation in children, Paley goes further than either Gay or Tucker, with whom he was in agreement on the principles of association. ¹ Inquiry Concerning the Principles of Morals, p. 326. mentioned above. He states that "if there be anything in them (children) which deserves the name of instinct it is their propensity to imitation."¹ Children imitate nothing more readily than expressions of affection and aversion, of approbation, hatred, resentment and the like; and when these passions and expressions are once connected, which they soon will be by the same association which unite words with their ideas, the passion will follow the expression and attach upon the object to which the child has been accustomed to apply the epithet. "In a word, when almost everything else is learned by imitation, can we wonder to find the same cause concerned in the generation of our moral sentiments?"² Paley anticipated Mills' conclusion that the morality of action is perceived by the same senses by which other qualities of action are perceived;³ however, it appears that the fallacy in his argument is that he failed to distinguish between the idea of conscience, which defines it as the ability to draw a distinction between right and wrong, and the idea, which says that conscience --- ¹ The Principles of Moral and Political Philosophy, Bk. I, Chapter V, p. 11. ² Ibid. ³ Mill, J. S. Dissertations and Discussions Political, Philosophical and Historical, Second Edition, Vol. I, p. 139. is the totality of our moral ideas. Professor Adam Sedgwick wrote, "No one now speaks of an innate knowledge of morality, an innate moral sense or faculty, defining and determining the quality of all our moral judgments is all for which we contend."¹ If man does not possess as a part of his native equipment the ability to make a distinction between right and wrong, it is difficult to see how he could ever be adequately trained into a moral being no matter how wide and varied his experiences. On the other hand, it is very apparent that what a man calls right and what he calls wrong is the result of his training. Perhaps Paley would agree that man has by nature the ability to distinguish between right and wrong, but this ability he would not call the moral sense. He would surely understand that without this ability man could not be morally responsible. Paley apparently considers it the same thing to disprove the existence of moral maxims and to disprove an innate moral faculty, but one would not say that because a man is not born with certain innate tunes that he has no ear for music. Paley might as ¹ Sedgwick, Adam. A Discourse on the Studies of the University of Cambridge, p. 57. well have used his story of the wild boy to disprove the existence of human reason on the grounds that the unprejudiced savage could not have been made to understand immediately that the angles at the base of an isosceles triangle are demonstrably equal to each other. In discussing what he considers to be the pernicious tendencies which he sees in the doctrine of the moral sense, Paley contends that moral judgments based on innate maxims are always arbitrary, for there are no maxims that are absolutely and universally true. Even veracity, which would appear above all others to be a natural duty, must bend to circumstances, for it is often justifiably violated in cases in which an enemy, a thief, or a madman is involved.$^1$ The further objection to the moral instinct is raised by Paley on the ground that in order to make the instinct intelligible there must have been implanted together with the instinct a clear and precise idea of the object upon which it was to attach. The instinct and the idea of the object are inseparable even in the --- $^1$ The Principles of Moral and Political Philosophy, Bk. I, Ch. V, p. 11. imagination, and, as is true of all correlative ideas, must necessarily accompany each other.$^1$ In other words, if we be prompted by nature to the approbation of particular actions, we must have received also from nature a distinct conception of the action we are thus prompted to approve. This, Paley contends, we certainly have not received.$^2$ From this he concludes that either no such instincts as compose what is commonly called the moral sense exist, or that they are not different from prejudices and habits and are, therefore, untrustworthy in moral reasoning. Says he: I mean that it is not a safe way of arguing, to assume certain principles as so many dictates, impulses, and instincts of nature, and then to draw conclusions from these principles, as to the rectitude or wrongness of actions, independent of the tendency of such actions, or of any other consideration whatever.$^3$ In reply to Paley's insistence that ideas and instincts must be conjoined it might be suggested that the existence of an instinct does not presuppose in the animal notions of those objects on which the instinct is to be exerted. For example, a duck in his --- $^1$ Ibid., Bk. I, Ch. V, p. 12. $^2$ Ibid. $^3$ Ibid. shell has no notion of water. But perhaps this analogy would not apply in the realm of rational beings. Furthermore, to Paley's objection based on the lack of uniformity in the notions of good and evil, it might be said that the perversion of the moral sense does not argue against its reality. Moreover, it is not the presence of correct moral judgments but rather the presence of any kind of moral judgment that argues in favor of the moral sense. The power of discerning the presence of a moral quality in action is evidence that man is a moral being. Paley's argument would, therefore, prove the existence in many areas of a defective moral sense but not the non-existence of a moral sense. Even wrong actions may be justified on the basis of a good intention. One, for example, who has been trained to believe that the world is a place of misery and that the infant is better off not to encounter its troubles, might be said to have a good motive even in practicing infanticide. To find such practice would thus not prove that there are in certain areas parents who do not love their children. Rousseau argues for the universality of good intentions in the following passage: Cast your eyes over all the nations of the world and all the histories of nations amid so many inhuman and absurd superstitions, amid that prodigious diversity of manners and characters, you will find everywhere the same principles and distinctives of moral good and evil. The paganism of the ancient world produced indeed, abominable gods, who, on earth, would have been shunned or punished as monsters; and who offered, as a picture of supreme happiness, only crimes to commit, or passions to satiate. But vice, armed with this sacred authority, descended in vain from the eternal abode. She found in the heart of man, a moral instinct to repel her. The continence of Zenocrates was admired by those who celebrated the debaucheries of Jupiter. The chaste Lucretia adored the unchaste Venus. The most intrepid Roman sacrificed to fear. He invoked the god who de-throned his father and died without a murmur by the hand of his own. The most contemptible divinities were served by the greatest men. The holy voice of nature, stronger than that of the gods, made itself heard, and respected, and obeyed on earth, and seemed to banish to the confines of heaven guilt and the guilty. The pernicious tendency residing in conduct based on self-evident maxims Paley illustrates by suggesting that Aristotle, who believed in an innate moral sense, contended that it was a fundamental and self-evident maxim that nature intended barbarians to be slaves. This view Paley felt would militate against moral progress, 1 Quoted by Francis Wayland, The Elements of Moral Science (1847), p. 52. 2 Paley was mistaken Aristotle at this point. What Aristotle actually says in the Politics is that the only person who can be regarded as (δοῦλος φυσικός) a 'slave by nature', is one who though capable of acting under another's direction is incapable of acting rationally by himself, and that he has a natural right to freedom as soon as he becomes capable of being his own master. He may, however, be retained by force in a state of slavery. for such philosophy merely attempts to discover reasons and excuses for opinions and practices that are already in vogue. Paley was revolting against the divinizing of the status-quo by men like Burke and Hume, for he felt that such a movement contains no dynamic for the eradication of existing evils. Paley concludes his argument against the moral instincts by contending that a moral philosophy built upon such instincts would be inadequate to move a man toward moral behavior. Even if moral instincts do exist, if a man has only to reckon with the pangs of his own conscience over the violation of such instincts, then he would often be found willing to endure the pangs of conscience for what he considered the greater pleasure of sin. Paley thus recognized that the moral sense philosophers were asking for a kind of reverence toward that which is within man which man will hardly grant toward anything save that which is outside and above himself, namely, God. It should be remembered that Paley did not consider the conscience of less importance because it had been acquired. He did not make the mistake of some moralists who felt that to explain the origin of the conscience was at the same time to explain it away. Having thus discussed the inadequacy of the law of honor, the law of the land, the Scriptures and the moral sense in the formulation of moral philosophy, Paley affirms his belief in the necessity of a more adequate objective standard in ethics by which actions may be judged. He then proceeds to lay the foundation upon which such an objective standard may be built. Paley's more remote heritage in Richard Cumberland and his more immediate heritage in John Gay$^1$, Abraham Tucker$^2$ and John Locke$^3$ are revealed in his definition of virtue which for him was "the doing good to mankind in obedience to the will of God and for the sake of everlasting happiness."$^4$ This definition, which makes the "good of mankind" the subject, the "will of God"; the rule and "everlasting happiness" the motive of human virtue, contains all the essential principles of Paley's system of ethics. In the school of theological utilitarianism three names are prominent, Gay, Tucker and Paley. The distinguishing feature in Paley's definition, which sets it apart from that of John Gay and --- $^1$ King, William. An Essay on the Origin of Evil, Preliminary Essay by John Gay, p. XXXVI. $^2$ The Light of Nature Pursued, Pt. I, Ch. XXII, Sect. 2 $^3$ Essay on Human Understanding, Bk. IV, Ch. XXI, p. 370. $^4$ The Principles of Moral and Political Philosophy, Bk. I. Ch. VII, p. 27. Abraham Tucker, is his emphasis on eschatology. For him as for Butler life on this earth is a probation. Paley carried the results of human conduct into eternity and thus provided for his system a stronger theological sanction than appears in either of his predecessors. Tucker used the theological sanction very sparingly and avoided it altogether except where his system logically demanded it. On the other hand, Paley's system is permeated with theological references. He leans heavily upon the doctrines of rewards and punishments in eternity, while John Gay, whom we have observed to be the father of theological utilitarianism, makes no use of this idea at all. In saying this, the writer is not unmindful of the claim that all of the essential features of Paley's ethics were contained in Gay's Dissertation.$^1$ A careful examination of this Dissertation, however, has not revealed a single reference to rewards and punishments after death. On the other hand, there is scarcely one of Paley's sermons that does not mention it. Passages like the following occur very frequently. The things of this world are diminished to nothing, when we place them by the side of that great event (eternal judgment) which will arrive to all of us.$^2$ --- $^1$ Hastings, James. Encyclopedia of Religious Knowledge. "Article on Utilitarianism." Vol. XII, p. 560. $^2$ Paley's Sermons, Vol. V, Sermon XXXIV, p. 313. All the struggles, all the self-denial, all the pains we go through to preserve our virtue, will meet with a proportionable reward, a far more exceeding weight of glory.\textsuperscript{1} The modern mind is prone to rebel at so bald a statement of rewards and punishments after death. For most writers of the eighteenth century, however, it was not apparent how the moral order could hold together without this, and for Paley it was not apparent why happiness in Heaven should be any more disreputable as a human goal than happiness on earth. Tucker had a more ingenious eschatology than did Paley. He turns his eschatology into a form of Universalism which Paley never embraced. Furthermore, Tucker embraced Cumberland's belief that eternal happiness and perfection are vitally related so that they form an additional incitement to the individual agent to seize every little opportunity of contributing towards an advancement of the life of the entire race of humanity. Tucker also sees with Locke that punishment cannot be absolutely endless, for this would violate the principle of equity by keeping the balance perpetually on one side. He reasons that since wickedness is permitted by Heaven, it must be for some purpose and that God \textsuperscript{1} \textit{Ibid.}, Sermon VI, p. 46. could not be good if he did not purpose that the wicked in suffering for their sins should have some benefit from their sufferings.$^1$ In other words, suffering must be remedial. Paley was far too orthodox to allow his speculations to go so far. According to Mill, Paley does hold that our place hereafter will be determined by our degree of moral perfection, but this is not to be construed to mean that we shall be judged by the balance of our good and evil deeds, which depend upon opportunity and temptation. Rather shall we be judged by the intensity and continuity of our will to do good. That is to say, we shall be judged not by our deeds but by our dispositions.$^2$ He steadfastly believed that every step of advance in the direction of moral perfection will be something gained towards everlasting welfare. Paley is very close to the emphasis of St. Paul who made his appeal for sustained Christian service on the basis of the doctrine of resurrection. Following the discussion of the resurrection of the dead, St. Paul writes: "Therefore, my beloved brethren, be steadfast, immovable, always abounding in the work of the Lord, knowing that in the Lord your labor is not in vain."$^3$ --- $^1$ Light of Nature Pursued, Vol. II, p. 670. $^2$ Mill, J. S. Dissertations and Discussions, Political and Historical, (1848) Second Edition, Vol. I, p. 153. $^3$ I Corinthians 15:58. Shaftesbury's argument against basing ethics on rewards and punishments had been rather strongly felt until even the more optimistic types of theism were omitting this from their system in Paley's day and replacing it with an appeal for virtue for virtue's sake. Shaftesbury was insisting that to be honest without thought of heaven or hell is precisely the mark of a disinterested lover of virtue, and at the same time, Holbach was calling the doctrine of the future life "that mirage which blinds men to the real and remediable evils of the present life."¹ Believing that self-interest was the ruling principle in human nature, Paley was faced with the task of showing that it was to the agent's interest to be moral. No argument could prove this would always be true without the supernatural sanction of morality. Hence, Paley believed that theological utilitarianism which held out rewards and punishments after death was the only natural position for a Christian to embrace. Furthermore, Paley believed that utilitarian theories had often suffered from a practical deficiency, for the motives they had offered to induce the individual to sacrifice his own pleasure to the happiness of society had not been sufficient. Paley's belief in a ¹ Systeme De La Nature. Righteous Judge of the world who would mete out rewards and punishments in eternity thus had its advantages over theories which could only appeal to decidedly uncertain human sanctions. After arriving at a sanction for his ethic, Paley undertakes an analysis of the virtues. In this he neither follows the primitive Christian pattern nor the medieval attempt to harmonize the Christian with the Greek ethical traditions. The Greek moral teaching has Plato as its originator and named four cardinal virtues—wisdom, courage, temperance, and justice. The New Testament tradition recognized three cardinal graces—faith, hope and charity. The scholastics worked out an ethical pattern by combining the four Platonic virtues with the Pauline three and thus arrived at the seven cardinal Virtues which they set in contrast with the seven deadly Sins. They called the first four the 'natural virtues' and the remaining three the 'supernatural virtues.' Professor John Baillie calls attention to the fact that: Such a solution appears as mechanical, and as lacking in true historical understanding, as the corresponding distinction between natural and revealed theology. The Platonic and Pauline lists are, fundamentally, not complementary but rival statements, each claiming to cover in itself the whole necessary ground; so that instead of attempting to accept them both as they stand, we must either work them into one another or else choose between them.\textsuperscript{1} A glaring weakness in Paley's system is that, while standing in the Christian tradition, he utterly overlooks the Pauline virtues and gives attention first of all to those he received from Plato and then makes a list of his own, very few of which are distinctly Christian. The four cardinal virtues which Paley names are: prudence, fortitude, temperance and justice. Beyond these cardinal virtues Paley further divides all virtues into three kinds of duties: first, duties towards God, as piety, reverence, resignation and gratitude; secondly, duties toward other men, or relative duties; as justice, charity, fidelity and loyalty; and thirdly, duties toward ourselves; as chastity, sobriety, temperance, preservation of life and care of health.\textsuperscript{2} The motive behind all moral conduct for Paley is human happiness. He does not, however, confine this to the happiness of the individual agent, for it is "the tendency of the action to promote or diminish the general happiness,"\textsuperscript{3} which makes it right or wrong. \textsuperscript{1} \textit{Our Knowledge of God}, p. 128. \textsuperscript{2} \textit{The Principles of Moral and Political Philosophy}, p. 28. \textsuperscript{3} \textit{Ibid.}, Bk. I, Ch. vii, p. 28. He thus unduly simplifies the motive of action making pleasure the end of action rather than the by-product of the achievement of another end. Paley does not recognize the fundamental paradox in hedonism that the impulse towards pleasure, if too dominant will defeat its own aim. He overlooks the fact which Butler pointed out, that many kinds of pleasure would not exist were it not preceded by desires for other objects. For example, the object of hunger is the eating of food, not the pleasure of eating it.$^1$ Even when the emphasis is placed not on individual but general happiness, still there remains the fact, as Hutcheson pointed out, that unless the desire for happiness is preceded by the desire for the welfare of others, no happiness could result therefrom. "Pleasure ensues upon the satisfaction of certain wants and the wants must be prior to the satisfaction."$^2$ Paley does not discuss whether it is total or average happiness that is to be sought nor does he tell us how far we are to consider the interests of posterity when they seem to be in conflict with those of the present generation. $^1$ Butler, Joseph. Fifteen Sermons and A Dissertation on the Nature of Virtue. Sermon I, pp. 36, 37. $^2$ Mackenzie, J. S. A Manual of Ethics, p. 72. Paley's definition of happiness on first sight appears to be purely quantitative. He writes: "In strictness, any condition may be denominated happy, in which the amount or aggregate of pleasure exceeds that of pain, and the degree of happiness depends upon the quantity of this excess."¹ Happiness in this passage appears to be closely identified with pleasure and in the absolute sense is defined simply as "the greatest quantity of it (pleasure) ordinarily attainable in human life."² Sharing the aversion to metaphysics common in his day, Paley in no wise attempts to differentiate between the rational and the physical pleasures, for to him pleasures differ in nothing but in continuance and intensity.³ This apparent denial of qualitative distinctions between different classes of pleasures and pains sounds commonplace enough now, for it is generally agreed that it is the only consistent view for hedonism; however, while other English writers like John Gay had held views from which this position was deduced, Abraham Tucker was the first to state it,⁴ and it would seem that Paley is following ¹ The Principles of Moral and Political Philosophy, Bk. I, Ch. vi, p. 14. ² Ibid. ³ Ibid., p. 15. ⁴ The Light of Nature Pursued, Ch. XVI, Sect. 1. him at this point. Professor Whewell called this opinion brutish since it recognizes no difference between the pleasures of man and those of the lowest animals. Furthermore, it would appear that Paley naively believed that the computation of pleasure can be accurately made simply by observing the apparent cheerfulness, tranquillity and contentment of men of different tastes, tempers, stations and pursuits as if to say that the incalculable complexity of the human soul can be explored by observing a man's outward appearances. This reasoning is not unlike that of the student whose shoddy religiosity allowed him to contend that he could tell whether or not a man possessed the Holy Spirit by the way he smiled. A more thorough reading of Paley, however, will show that his definition of pleasure includes a qualitative emphasis and that Professor Whewell's accusation that he lumped all pleasures together is somewhat harsh. On the contrary, he expressly denies that all pleasure is productive of happiness. For him, happiness consists neither in pleasures of the senses, be they the animal gratification of the appetite for food or the more refined pleasures of music, nor in exemption from pain, nor in human greatness, for the pleasures of sense are fading. The exemption from physical pain does not free us from depression of spirits, and the pleasures of ambition are never fully satisfied. The only pleasures which are productive of happiness, Paley maintained, are those which possess the quality of endurance.$^1$ That which sets man's pleasure apart from the animals$^2$ is the fact that he has the ability to know beforehand those pleasures that endure. Hence, at this point, Paley was very close to Aristotle for whom pleasure was the satisfaction of the human being as a whole. Instead of embracing the naive position with which he has been associated, Paley, in reality contends that since the capacity and constitution of men are so diverse, it is impossible to propose a plan of happiness which will succeed for all. He reasons that we can only hope with our limited means to ascertain those conditions of life in which men in general find cheerfulness and contentment and although the apparent happiness of mankind is not always a true measure of their real happiness, Paley contends that it remains the best measure that we have.$^2$ --- $^1$ The Principles of Moral and Political Philosophy, Bk. I, Ch. vi, p. 20. $^2$ Ibid., Bk. I, Ch. vi, p. 21. Having settled on this hedonistic principle, Paley reasons that happiness consists in four things. First, it consists in the exercise of the social affections.¹ Those persons, who are surrounded by many objects of affection and endearment such as wife, children, kindred and friends, usually possess good spirits. The peevishness of monks and those who live a monastic life is attributed to the absence of those social affections. In this corporate social life described above there are opportunities for acts of bounty and beneficence which are productive of pleasure. Again, it is observable that "the exercise of our faculties either of body or mind in the pursuit of some engaging end,"² is another main source of human happiness. The plentitude of present gratifications is not adequate to make the possessor happy unless he have something to look forward to in reserve. This intolerable vacuity of mind accounts for "the dejection and ennui of almost all who are either born to so much that they want nothing more, or who have used up their satisfactions too soon, and drained ¹ Ibid. ² Ibid., p. 22. the sources of them."¹ The hope which is most important for our happiness is not that of idle repining but rather that which is most productive of engagement and activity. Herein, according to Paley, lies the value of a belief in a future state: A man who is in earnest in his endeavors after the happiness of a future state, has in this respect an advantage over all the world; for he has constantly before his eyes an object of supreme importance, productive of perpetual engagement and activity, and of which the pursuit (which can be said of no pursuit besides) lasts him to his life's end. Yet even he must have many ends, besides the far end; but then they will conduct to that, be subordinate, and in some way or other capable of being referred to that and derive their satisfaction, or an addition of happiness from that.² Significant engagement in projects such as public works, charities, etc., is a bulwark against the inroads of peevishness and irascibility, for Paley saw that when business engages the mind, man is usually happy, and that it is the intolerable idleness of mind that makes him so often miserable. In the third place, Paley observes that happiness is dependent upon the prudent constitution of habits. "The art in which ¹ Ibid. ² Ibid. the secret of human happiness in a great measure consists is, to set the habits in such a manner, that every change may be a change for the better."¹ He is not as rigid in his doctrine as was Aristotle who made the main issue in the moral life the establishment of good habits and then attributed to them such control over human conduct that moral freedom was virtually destroyed. On the contrary, Paley contended that the habits that are most advantageous are those which allow a deviation from them, for, said he, rigidity, or conformity often produces boredom and thus defeats man's true end which is happiness. For example, the socialite who habitually resorts in crowds receives no exhilaration from them as does the man who has learned to live alone and only occasionally enters the crowd. Solitude comes to the one clothed with melancholy; to the other, it brings liberty and quiet. On the same principle, Paley reasons that in circumstances of fortune it is not the income which a man possesses but the increase of income that affords the pleasure.² Although Paley argues in favor of keeping one's habits flexible, he, nevertheless, places great emphasis on the value of ¹ Ibid., p. 24. ² Ibid., p. 26, Bk. I, Ch. vi. habits in the regulation of human conduct. Contrary to the opinion of many of his critics, Paley had not insisted upon the adequacy of the hedonistic calculus for determining the course of conduct.$^1$ In fact, neither Paley nor his predecessor, Tucker, taught that we are to determine the morality of a particular action by computing its probable effects in the individual case. On the contrary, among the utilitarians it was Tucker who first anticipated the criticism which was to be so often brought against Paley by his critics.$^2$ Because Tucker and Paley recognized man's inability to compute adequately the consequences of his conduct they both insisted that we must act on general principles of expediency, not merely because we are intellectually finite beings, but because we are largely creatures of habit. The utilitarian theme was later brought into disrepute by the emphasis of Bentham who seemed to hold that we must compute our individual acts by this utilitarian principle instead of acting by general "rules" of utility.$^3$ Although not an hedonist himself, Hutcheson has assumed without question the possibility of computing with sufficient exactness --- $^1$ Ibid., p. 29. $^2$ The Light of Nature Pursued, Ch. XXII, SS. 11, 12. $^3$ An Introduction to the Principles of Morals and Legislation, pp. Iff. the effects of different kinds of actions, as regards their tendency for the general happiness, or unhappiness and of thus determining their 'objective' goodness or badness. As a matter of fact, only Hartley and Berkeley had even recognized a difficulty involved in the hedonistic calculus until Tucker did his work. Moreover, their suggestion of the difficulty was very general. Tucker's blazing honesty caused him not only to recognize the difficulty involved in his theory but even to give it an overemphasis. The following passage is a case in point: Our tastes, varying as much as our faces, make us very bad judges of one another's enjoyments... Nor do we judge much better of our own pleasure, for want of being well aware of their aptness to cloy upon repetition, and to change their relish perpetually according to our disposition of mind or body, or the circumstances we happen to stand in: neither can we trust even experience itself in this case for because a thing has pleased us once, we cannot always be sure it will do so again... But if we make mistakes in estimating pleasures singly, we commit more in computing the value of a series of them taken collectively.... Therefore, we are forced to take our pleasures in the lump, and estimate them upon view; as a man who guesses at a flock of sheep by the ground they cover, without being able to count them, and who will do it very imperfectly, until he has gotten an expertness by long and careful practice. For absent enjoyments, whether past or future, being not actually existent, we cannot hold them as it were in our hand to weigh them, but must judge by the representative idea we have of them in our imagination; and we ordinarily determine their value by the degree of desire we feel in ourselves toward them. The value of the above passage is that it shows that while Tucker was a thoroughgoing hedonist, he anticipated nearly all of the objections that were later to be raised by the anti-hedonists except the very important one which Spencer used in his early criticism of the Expediency Philosophy in Social Statistics, namely, that hedonistic values vary with the development of moral character. The objections to Paley's principle of measuring conduct by its tendency to promote or diminish the general happiness may be summed up in three major points, namely, the inability of man to calculate accurately the consequences of his actions, the contention that happiness is not the sole determinant of man's action, and the fact that there is nothing distinctly Christian about this principle. It might be added that these were the criticisms levelled against Paley in his own day. Kant's most devastating contention that such a principle deals only with questions of prudence and does not penetrate the field of morals at all came later and will be considered in the final chapter of this thesis. 1 The Light of Nature Pursued, Ch. XXII, SS 11, 12. Let us now examine the first objection to Paley's principle, namely, that man is unable to calculate accurately the consequences of his conduct. It is said that the endless chain of causes and effects may be known only to omniscience and not by the limited faculties of man.$^1$ In answer to this, it should be remembered that Paley, along with the other early Utilitarians did not make of their system a mere calculating theory in this obviously impracticable sense. Furthermore, while Paley did not believe that man had the ability to calculate the infinite consequences of his actions, he recognized at the same time that the very possibility of free moral actions is based upon our ability to foresee their consequences in a general way.$^2$ However imperfect our foresight may be, it remains a strong determinant of our conduct. It is not perfect, but neither is anything else in our constitution. Again, it should be remembered that the individual agent does not stand alone to predict the consequences of his actions, for he has not only his past experience to guide him but the accumulated wisdom of the ages. Hence, the uncertainty of the consequences of his actions is not as great as it --- $^1$ Gisborne, Thomas. The Principles of Moral Philosophy Investigated and Applied to the Constitution of Civil Society, p. 53. $^2$ Mill, J. S. Dissertations and Discussions, Political, Philosophical, and Historical, Second Edition, Vol. I, p. 141. might appear at first thought. The second objection to Paley's principle, namely, that happiness should not be the sole pre-determinant of man's conduct, is the most damaging of all. No one denies that happiness is desirable and to be sought. Nor can we deny that in a moral universe in some very real sense goodness and happiness are correlatives, as the seed and the fruit, but what we are not prepared to accept is that happiness is the sole pre-determinant of action. Life is far too complex for its springs of action to be thus simplified. Nor is it true that any one principle has yet been found that of itself offers to man an adequate guide. From a rational standpoint Paley's argument moves in a circle. He reasons from the goodness of God that He must desire every man's happiness, and when he is asked why we are to seek happiness, he answers because it is the will of God. The strong point in such argument is that it starts with an absolute and as Karl Barth is telling us today, man cannot live without an absolute. This is not to say that Barth would agree with Paley. His criticism of Paley would be the same that he brings against all natural theology, namely, that it fails to preserve the gulf between God and man, and when man arrives at a principle by which he may determine the will of God, he simply indicates that he has taken God into his possession. This, for Barth, destroys the true meaning of revelation and robs God of his majesty. We shall discuss this further in the final chapter of this thesis. The final objection to Paley's principle revolves around the fact that it is not distinctly Christian. It is seen that while Paley identifies rules of expediency with the will of God, he at the same time concludes that no such rules are absolutely binding. He contends that: Moral philosophy cannot pronounce that any rule of morality is so rigid as to bend to no exceptions; nor on the other hand, can she comprise these exceptions within any previous description. She confesses that the obligation of every law depends upon its ultimate utility; that this utility having a finite and determinate value, situations may be feigned, and consequently may possibly arise, in which the general tendency is outweighed by the enormity of the particular mischief; and of course, when ultimate utility, and consequently the will of God, render it as much an act of duty to break the rule as it is on other occasions to observe it.$^1$ But perhaps Paley is concerned here only to say that what appeared at one time to be the will of God for a man and on this authority was formulated as a rule of conduct may be altered under different circumstances. --- $^1$ The Principles of Moral and Political Philosophy, Bk. VI, Ch. xii, p. 498. It is further argued that the Deists, who did not believe in a special revelation, might be guided by Paley's principle as well as the orthodox Christian. Warburton affirms that Boyle, Collins, Tindal, Bolingbroke, and all the other writers against Revelation, except Hobbes, labored to show the Gospel system to be in the highest degree unreasonable.$^1$ A reference to Leland's account of deistical writers will show that by the term, "unreasonable", Warburton probably meant inexpedient. If, then, expediency is to be the supreme guide of Christian and non-Christian alike, what part is Christianity to play in determining man's moral conduct? Paley would answer by saying that Christianity affords the necessary sanction by offering rewards and punishments in eternity. We must bear in mind that Paley was not so much concerned with the discovery of ethical knowledge as he was with the provision of a strong sanction. A direct appeal to Scripture has also been made to show that in no part of the Scripture are we directed to frame our conduct in obedience to the rule of expediency.$^2$ Gisborne argues that there are two kinds of rules in the Scripture, absolute and precise rules $^1$ Warburton, William. Alliance Between Church and State. (4th edition), p. 78, note. $^2$ Gisborne, Thomas. The Principles of Moral Philosophy Investigated and Applied to the Constitution of Civil Society, pp. 50, 51. prohibiting idolatry, perjury, etc., and equally obligatory, general indeterminate rules, as reverence for parents. In the case of the first, no latitude is given for the exercise of human discretion while in the second, we are left to judge of the manner in which they are to be discharged. Yet there is no intimation in Scripture that expediency is to be the basis of our judgment. Moreover, it is contended that Revelation permits no doctrine that would be subversive to the spirit and obligation of her precepts. At the same time it is said that to allow every man to govern himself by expediency would take the government out of the hands of God and allow man to decide when God's laws are to be obeyed. It must be admitted that these criticisms may be justifiably brought against a thoroughgoing system of Utilitarianism. However, they manifest a decided misunderstanding of Paley's system. In the first place, let it be observed again that Paley is interested in applying the principle of expediency only where there is no clear word of God in the Scriptures. Not for a moment would Paley allow a man, as Gisborne contends that he does, to question the authority of God's written law and thus take to himself the authority to decide when he would or would not obey God's law. In the second place, it must readily be admitted that there is nothing distinctly Christian about Paley's principle of utility. This also will be further discussed in the final chapter. It was precisely because Paley recognized the limitations of the hedonistic calculus that he makes a strong appeal for the cultivation of proper habits. He contends that men rarely pause to deliberate on the moral implications of their conduct. On the contrary, action is determined immediately by an impulse which is the effect and energy of pre-established habits. In life's rapid opportunities there is little leisure for reflection. The value of good habits is seen in the fact that men who have to pause to deliberate when temptation confronts them usually reason themselves into error by what they consider at the time to be a plausible argument.¹ So strong does Paley believe the influence of certain habits to be that he virtually embraces a form of determinism which would leave a man so passive that he would not be free to choose his direction and would therefore all but be relieved of personal responsibility. At this point, Paley is close to the thoroughgoing determinism of Tucker.² We might ask if a man's conduct is determined by his habits, would it not be true that his teachers and his general environment rather than himself would be responsible for his conduct? ¹ The Principles of Moral and Political Philosophy, Bk. I, Ch. vii, p. 29. ² The Light of Nature Pursued, Ch. V, pt. I. Paley would answer that man's responsibility lies "in the forming and contracting of these habits." He writes: There are habits, not only of drinking, swearing and lying, and of some other things, which are commonly acknowledged to be habits, and called so; but of every modification of action, speech and thought. Man is a bundle of habits. There are habits of industry, attention, vigilance, advertency; of a prompt obedience to the judgement occurring, or of yielding to the first impulse of passion; of extending our views to the future, or of resting upon the present, of apprehending, methodizing, reasoning; of indolence and dilatoriness; of vanity, self-conceit, melancholy, partiality; of fretfulness, suspicion, captiousness, censorousness; of pride, ambition, covetousness; of over-reaching; intriguing, projecting; in a word, there is not a quality of function, either of body or mind, which does not feel the influence of this great law of animated nature. From the above consideration, Paley deduces a rule of life which he believes to be of considerable importance, namely, that many things are to be done and abstained from, solely for the sake of habit. For Paley the proper course of moral development is for one to begin by considering the good of mankind as the subject, the will of God as the rule, and everlasting happiness as the --- 1 The Principles of Moral and Political Philosophy, Bk. I, Ch. vii, p. 29. 2 Ibid., p. 31. motive and end of all virtue. When one becomes conformed to these principles, he performs many an act of virtue without having either the good of mankind, the will of God or everlasting happiness in his thoughts. Paley insists, however, that this can come about only as the result of having been consciously guided in the past by the desire to do the will of God, or to attain everlasting happiness or to contribute to the good of mankind, and that when these motives have solidified into a pattern of conduct, only then may they be forgotten. The final factor in the production of happiness in Paley's system is health, which is simply defined as "freedom from bodily distempers." And also as "that tranquillity, firmness and alacrity of mind, which we call good spirit." In this sense, health is of all things most needful and no price is too great to pay for it. It is an "enjoyment which the Deity has annexed to life." The next principle with which Paley was concerned was that of moral obligation. He presented this problem in the form of a question, namely, why am I obliged to keep my word? He then borrows the traditional answers cited by Gay. His first answer is --- 1 The Principles of Moral and Political Philosophy, Bk. I, Ch. vi, p. 26. 2 Ibid., p. 27. 3 Preliminary Dissertation Concerning the Fundamental Principle of Virtue or Morality, 1732, p. XXVIII. that of the Cambridge Platonist, Richard Cudworth, namely, I am obliged because it is right; next he cites the Stoic answer, because it is agreeable to the fitness of things or because it is conformable to reason and nature; then the answer advanced by William Wollaston, because it is conformable to truth; the answer of Richard Cumberland, because it promotes the public good, and finally, the answer of John Locke, John Gay and Abraham Tucker, because it is required by the will of God. After citing these answers, Paley draws two conclusions. The first is that these answers all ultimately coincide: The fitness of things, means their fitness to produce happiness; the nature of things, means that actual constitution of the world, by which some things, as such and such actions, for example, produce happiness, and others misery; reason is the principle by which we discover or judge of this constitution; truth is this judgment expressed or drawn out into propositions. So that it necessarily comes to pass, that what promotes the public happiness or happiness upon the whole, is agreeable to the fitness of things, to nature, to reason and to truth, and such is the divine character, that what promotes the general happiness is required by the will of God, and what has all the above properties, must needs be right; for right means no more than conformity to the rule we go by, whatever that rule be. 1 The Principles of Moral and Political Philosophy, Bk. II. Ch. i, pp. 36, 37. The above, Paley believes, accounts for the fact that from whatever different principles moralists may begin their inquiry their conclusions ultimately coincide. Paley's second conclusion is that not one of the traditional answers to the question of obligation is adequate, for upon receiving those answers to the question, why am I obliged to keep my word, a second question immediately occurs, namely, "Why am I obliged to do what is right, to act agreeably to the fitness of things, to conform to reason, nature, or truth, to promote the public good, or to obey the will of God?"¹ From this it appears necessary to inquire first into the meaning of obligation and then to cite reasons for such obligation. Paley gives obligation the following meaning: "A man is said to be obliged when he is urged by a violent motive resulting from the command of another."² Strong emphasis is placed on the fact that the motive must be violent. For example, if one who has been my benefactor on a small scale should be a candidate for office and solicit my vote, I may out of a motive of gratitude give it to him, but it could hardly be said that I was obliged to ¹ Ibid. ² Ibid., p. 37. do so. On the other hand, if my father, or master, any great benefactor or one on whom my fortune depends, solicits my vote, I would, because of the violent motive, be obliged to give it to him, and the only reason I need offer for such is that my father, master, or benefactor obliged me. The second element that Paley finds necessary in obligation is that it must result from the command of another. It must come from without and from above rather than being self-imposed. He reasons that if I offer a man a gratuity for the performance of some service, he could not be said to be obliged to accept my offer. On the other hand, if such a man be commanded by a magistrate he is obliged to comply. "Wherever the motive is violent enough and coupled with the idea of command, authority, law or the will of the superior, there, I take it, we always reckon ourselves to be obliged."¹ Hence, Paley concludes that we can be obliged by nothing except that by which we ourselves are to gain or lose something, for nothing else can constitute a violent motive to us. This is almost ¹ The Principles of Moral and Political Philosophy, Bk. II, Ch. ii, p. 38. verbally the position which Butler advanced. Note the following passage from one of his sermons: When we sit down in a cool hour we can neither justify to ourselves this or any other pursuit, till we are convinced that it will be for our happiness, or at least not contrary to it. Paley went so far as to hold that we should not be obliged to obey the laws, or the magistrate, unless rewards or punishments, pleasure or pain, somehow or other depended upon our obedience. Neither should we be obliged to do what is right, to practice virtue, or to obey the commands of God unless we should gain by so doing or lose by not so doing. It is very curious indeed that while Paley held that the individual's happiness must be subordinated to that of the public in general, his theory of obligation would make it impossible for him to make a sacrifice of his own happiness. He would agree with Butler, Shaftesbury and Hutcheson that self-renunciation could never be the result of calm deliberation. Paley would, therefore, pass under the judgment which Schleiermacher made on such theory when he wrote that the English school "with all 1 Sermons, Vol. IV, p. 88. their talk about virtue are really given up to pleasure." 1 Paley then answers the question why am I obliged to keep my word, by saying because I am urged to do so by a violent motive, namely, "the expectation of being after this life rewarded if I do, or punished if I do not, resulting from the command of another, namely, of God." 2 Beyond this, Paley sees no further question that can be asked. He, therefore, concludes that he has given a final answer to the question of moral obligation with the result that "private happiness is our motive and the will of God our rule" 3 in all our behavior. The chief weakness in such a position is that Paley reduces duty to meaning virtually the same thing as prudence. Furthermore, Paley fails to appreciate the fact that the distinction between prudence and duty was recognized even by those who did not recognize a divine command and who did not believe in a world to come. For example, Aristotle, who in his Ethics speaks of death as the "boundary beyond which there is neither good nor evil," and --- 1 Kritik der bisherigen Settenlehre (1803), p. 54. 2 The Principles of Moral and Political Philosophy, Bk. II, ch. iii, p. 39. 3 Ibid. by Cicero in his De Officiis, who makes a distinction between the (Honestum) virtuous, and the (Utile) expedient and who derides the idea of fearing the wrath of Jupiter and gives no evidence that he believed in a personal existence after death. If, as Paley believed, the idea of virtue or duty is deducible only from the thought of rewards and punishments in the world to come, it is very strange indeed that we find these ideas in systems of ethics that made little or no use of this doctrine. Paley expressly states that "he who would establish a system of morality independent of a future state, must look out for a different idea of moral obligation."¹ This position, however, is highly inconsistent with his account of how the idea of duty comes into being. That is to say, if the idea of duty is deducible only from the belief in a future state of rewards and punishments, then where such doctrine is not embraced it would be impossible for the idea of duty to come into being. Furthermore, where there is no idea of duty, there could be no moral obligation. By denying the doctrine of an innate moral sense and making the idea of duty dependent upon a belief in future rewards and punishments, Paley absolves the man ¹ Ibid. who is ignorant of such future state from responsibility for his conduct, for as St. Paul wrote, "where there is no knowledge there is no transgression."¹ Neither could Paley say "Where there is no law every man is a law unto himself."² Moreover, Paley's statement, that the difference between an act of prudence and an act of duty is that, in the one case, we consider what we shall gain in this life, and in the other what we shall lose in the next life, is like saying that sin does not lead to suffering because it is sin, but it is sin because it leads to suffering. At this point, Whately properly observes that this distinction between prudence and duty is no distinction at all, for whatever is done wholly and solely from motives of personal expediency, from calculations of individual loss or gain is always accounted a matter of prudence and not a virtue.³ This asks only what are the acts by which I will profit most? We need, however, in the face of such criticism again to remember that Paley was more interested in providing a strong sanction to enforce moral conduct than he was. --- ¹ Romans 4:15. ² Romans 2:14. ³ Whately, Richard. Paley's Moral Philosophy With Annotations, Annotation to Chapter III, Bk. ii, p. 68. in giving a principle by which moral acts could be defined, for it was the breakdown of strong and virile religion which he saw as the cause of the moral delinquency of his day. Paley's theory of rewards and punishments is the only consistent answer that may be given if one is to show that the individual rather than society is to profit by his virtue. For those embracing the eschatological sanction in ethics there remains only one question, namely, "What actions will be rewarded, and what will be punished?" Paley's answer is, those actions which are in harmony with the will of God will be rewarded and those out of harmony with the will of God will be punished. The question then arises, how are we to ascertain the will of God? In his answer, Paley might be called a rational revelationist. This is seen in the two methods which Paley proposes for ascertaining the will of God. The first is by the declarations of Scripture. The second is from the light of nature, or what we can learn of God's design from his works. ¹ Paley believed with Locke that the works of nature everywhere sufficiently evidence a Deity ¹ The Principles of Moral and Political Philosophy, Bk. II, Ch. iv., p. 41. and that "a rational creature who will but seriously reflect on them cannot miss the discovery of a Deity." Paley affirms his belief in the complementary nature of natural and revealed religion. Both branches of religion, he contends, have the same object, namely, the discovery of the will of God, and are divinely ordained for that purpose. Paley undertakes to answer Hume's complaint against the scheme of uniting ethics with Christian theology by observing that Hume's own treatise, which is manifestly devoid of theological references, provides no adequate motives to withhold men from the gratification of lust, revenge and avarice, or to prevent these passions from arising. For Paley, wherever the Scripture speaks specifically about a moral problem, no further inquiry needs to be made. However, he does not believe the Scriptures to be a mechanical book of rules; therefore, our knowledge of the will of God will come most often from the light of nature. Following Gay and Tucker he reasons that God, who is absolutely good, must will --- 1 An Essay Concerning Human Understanding, Bk. I, Ch. IV, pp. 37, 38. 2 Principles of Morals, fourth Appendix. the happiness of his creatures. Therefore, those actions which promote happiness must be agreeable to him. Thus Paley arrives at the fundamental principle of his entire system and to support such principle he offers the following conclusions concerning the Divine benevolence; when God created human beings one of three things might have constituted his intention, either he desired their happiness or he desired their misery or he was indifferent and unconcerned about both. The fact that he did not desire the misery of the race is demonstrated by the presence in the human constitution of senses which bring us more delight than pain. If God were some demoniacal power who desired the misery of his creation, "He, for example, might have made everything we tasted bitter, everything we saw loathsome, everything we touched a sting, every smell a stench, and every sound a discord."¹ If, on the other hand, God were not concerned about either our happiness or our misery, we must attribute to a very fortunate accident the fact that our senses have the capacity to receive pleasure and that so many external objects are capable of exciting it. Inasmuch as it is inconceivable that such should be the product of an accident, Paley ¹ Natural Theology, p. 384. concludes that we are left with the remaining proposition, namely, that God, when He created the race, desired its happiness and made provisions for it. This is the cosmological argument which was a part of the common stock of eighteenth century moralists and upon which Paley leaned so heavily in his theological writings. 1 He believed that the predominant tendency of the design was accurate proof of the disposition of the designer and found that all things with which he was acquainted were beneficial in design. Paley finds the benevolence of the Deity more manifestly demonstrated in the pleasures of very young children than in anything else, for while the pleasures of adulthood may be considered in a sense as the product of their own development and education, the overwhelming joys of childhood may not be so construed. Seeing the hand of God in the joys of childhood, Paley again concludes that God must desire and ordain the happiness of his creatures. Having established this conclusion, Paley proceeds to the rule built upon it, namely, "that the method of coming at the will of God con- --- 1 Evidences of Christianity, Natural Theology and Horae Paulinae. cerning any action, by the light of nature is to inquire into the tendency of that action, to promote or diminish the general happiness." Paley concludes that since actions are to be estimated by their tendency to promote or diminish happiness, it follows that "whatever is expedient is right. It is the utility of any moral rule alone which constitutes the obligation of it." Actions in the abstract are to be denominated right or wrong according to their tendency, and the agent is virtuous or vicious, according to his design. For example, in answering the question, whether it be right or wrong to minister to the needs of a common beggar, it would first be necessary to ascertain whether such would tend to promote public advantage or inconvenience. In answering the question, whether a man who ministers to beggars is to be adjudged virtuous, we must first inquire into his design. If his liberality arose from charity, he would be esteemed a virtuous man, if it arose from ostentation, he would not be worthy of such 1 The Principles of Moral and Political Philosophy, Bk. II, Ch. V, p. 46. 2 Ibid., p. 46. esteem. From such reasoning we may conclude that Paley went deeper into the springs of moral conduct than would the thorough-going utilitarian and that much of the criticism directed against the selfishness involved in this theory was unjust. It is also apparent that Paley was more aware of the complexity of moral conduct that some of his critics have believed, for he undertakes to break down this complexity by dividing the consequences of conduct into two categories, namely, the particular and general. He held that in estimating the consequences of a certain action it is never sufficient to observe merely the particular consequences. For on this procedure it would not be difficult to reason that the possessor of a great estate, who employs his power and influence for the oppression of all about him and whose estate would devolve by his death to a successor of opposite character, might be justifiably murdered. It is very apparent that such a crime would be useful in this particular case, however, there is a general consequence involved, which is far more relevant, namely, the violation of the necessary general rule, that no man should be put to death for his crimes, except by public authority. Paley writes: The particular bad consequence of an action, is the mischief which that single action directly and immediately occasions. The general bad consequence is, the violation of some necessary or useful general rule.$^1$ Such an act as the one described above could not, in the final sense, be said to be useful, for the general consequence of it is evil. Paley further provides for man's inability to predict the consequences of his actions by binding him to the observance of general rules. He contends that because the general effects of actions are far more consequential than particular effects, man is, therefore, under heavier obligation to obey the general rules of society. This is seen in the following: General rules are necessary in every moral government; and by moral government I mean any dispensation whose object is to influence the conduct of reasonable creatures. $^1$ Ibid., p. 47. For if, of two actions, perfectly similar, one be punished and the other be rewarded or forgiven, which is the consequence of rejecting general rules, the subjects of such a dispensation would no longer know, either what to expect or how to act. Rewards and punishments would cease to be such—would become accidents. Like the stroke of a thunderbolt, or the discovery of a mine, like a blank or a benefit ticket in a lottery, they would occasion pain or pleasure when they happened; but following in no known order, from any particular course of action, they could have no previous influence or effect upon conduct. The very idea of rewards and punishments which constitutes the sanction of Paley's Ethics, he believes to be inseparably related to the existence of general rules so that the same reasons that prompt us to believe in the doctrine of future rewards and punishments at the hand of God would prompt us to believe that the distribution of such rewards and punishments must be made according to general rules. For Paley the general consequence of an action may be determined by asking, what would be the consequence if the same sort of action were generally permitted? Paley's appreciation of the organic unity of society is seen in his contention that the --- 1 The Principles of Moral and Political Philosophy, Bk. II, Ch. vii, p. 49. measure of a man's guilt must always be in proportion to the whole mischief that would result if every man should act accordingly: Whatever is expedient is right. But then it must be expedient upon the whole, at the long run, in all its effects collateral and remote as well as in those which are immediate and direct; as it is obvious, that, in computing consequences, it makes no difference in what way, or at what distance they ensue. Paley undertakes to impress his argument upon his readers by a series of analogies. He reasons that the particular consequence of counterfeiting a guinea would be the loss of a guinea to the person who receives it: the general consequences (by which he means the consequence that would follow if the practice were generally permitted) would be the abolition of the use of money. Again the particular consequence of breaking into an unoccupied house would be the loss of a pair of silver candlesticks: the general consequence would be that nobody could leave his house unguarded. It is on the basis of the general consequence of a crime that Paley deems it just to give one thief the same punishment for stealing five pounds as another would receive for stealing fifty. 1 Ibid., p. 51. By this line of reasoning Paley demonstrates the logic behind the proposition that we are "not to do evil that good may come," for however great the particular good consequence may prove to be, it could not compensate for the evil that would be rampant if everyone should decide to disregard the rule that forbade it. Continuing his discussion of moral obligation, Paley makes "right" and "obligation" reciprocal. Wherever there is a right in one person, there is a corresponding obligation upon others.¹ That is to say, that one man's "right" to his estate means that others must abstain from it. Since moral obligation depends, as we have seen, upon the will of God, "right", which is correlative to it, must depend upon the same. "Right", therefore, signifies "the being consistent with the will of God."² Paley was rather close to the Cambridge Platonists when he saw that right and wrong were not arbitrary considerations but that they were fixed distinctions determined by the divine --- ¹ Ibid, p. 54. ² Ibid. will. This is simply another way of saying that God always acts rightly, and that it is inconceivable that he should act wrongly. By establishing the two principles, that God wills the happiness of his creatures, and that the will of God is the measure of right and wrong, Paley finds it possible to draw certain general conclusions which he regards as rules. From these rules we come to learn the specific actions that are right and wrong. We have seen in this chapter how Paley arrived at his belief in the necessity of an objective standard in the treatment of ethics, that this standard must be formulated in terms of the will of God, which may be ascertained from the tendency of any action to promote or diminish human happiness, and which is sanctioned by the rewards and punishments of the Righteous Judge in eternity. CHAPTER IV THE APPLICATION OF PALEY'S ETHICS Notwithstanding the weaknesses of his theory, Paley built a strong superstructure of ethics upon it. In fact, it is difficult to find fault with the way in which he applies his theory. Inasmuch as his chief concern was with practical applications rather than with expounding a theory, our judgment of his work should be primarily concerned with his exposition. Above all else Paley was an expositor, and we must not forget that exposition is as much a part of the science of ethics as is theory. W.R. Sorley reminds us that "ethics has not only to determine the end but to apply it to practice, so as to decide as to what is right or wrong in particular actions and virtuous or vicious in character."¹ In this chapter we shall be interested in Paley's consistency or inconsistency in the handling of his principles and his success or failure in deducing from these his concrete rules of morality. The practical nature of the science of ethics in the mind of Paley is seen in his definition of ethics as "that science ¹ The Ethics of Naturalism, p. 9. which teaches men their duty and the reasons of it."¹ From this Paley proceeds to divide man's duty into three categories, namely, our duties to others, called relative duties, our duties to ourselves, and our duties to God. The relative duties are further divided into three categories, namely, the determinate, the indeterminate, and the constitutional duties. The determinate duties deal with the handling of property, the making of promises, the making of contracts, truth-speaking, oaths, subscription to articles of religion, and the making of wills. Under the relative duties which are indeterminate Paley discusses charity, slavery, resentment, anger, revenge, duelling, litigation, gratitude, and slander. Under the relative duties which result from the constitution of the sexes the following are discussed: marriage, fornication, seduction, adultery, incest, polygamy, divorce, the duty of parents, the rights of parents, and the duty of children. The second general category, which Paley calls duties to ourselves, includes a discussion of the rights of self-defence, ¹ The Principles of Moral and Political Philosophy, Bk. I, Ch. i, p. i. drunkenness, and suicide. Then in the final category, called our duties to God, Paley places prayer, the use of Sabbatical institutions, and reverencing the Deity. Let us now examine these general categories by examining Paley's treatment of exemplary duties under each category. I Look first at those relative duties which he calls determinate. In this category we confront first of all a discussion of the use of the institution of property. This was one of the live issues in Paley's day. So important was his contribution to this subject that from the analogy with which he introduced his discussion of this problem he acquired the name "Pigeon" Paley. Here is his picture of the oppression of the masses of his day: If you should see a flock of pigeons in a field of corn and if (instead of each picking where and what it liked, taking just as much as it wanted and no more) you should see ninety-nine of them gathering all they got into a heap; reserving nothing for themselves but the chaff and the refuse; keeping this heap for one, and that the weakest, perhaps worst pigeon of the flock; sitting round and looking on all the winter, whilst this one was devouring, throwing about, and wasting it; and if a pigeon, more hardy and hungry than the rest, touched a grain of the hoard, all the others instantly flying upon it and tearing it to pieces: if you should see this, you would see nothing more than what is every day practiced and established among men. Paley takes the above analogy and applies it to the masses of his day who were being denied the proceeds of their labor which they had rightfully earned. He laments the fact that the labor of the ninety and nine was being spent solely for the comfort of the few privileged land owners. Such an open tirade against the policies of the reigning party of the day was bound to call forth their wrath, and was sufficient to bar the way against the ecclesiastical promotion which Paley richly deserved. When we bear in mind the relationship of the possession of property to suffrage during the reign of George III, we begin to see how delicate was the problem with which Paley was dealing. Of the eight millions of people, only a hundred and sixty thousand were electors at all. Walpole and Newcastle had made bribery and borough-jobbing the base of their power and George III --- 1 The Principles of Moral and Political Philosophy, Bk. III, Part i, ch. 1, pp. 68, 69. 2 Green, J. R. A Short History of the English People, p. 765. seized it in his turn as a base of the power he proposed to give to the crown. He used the royal revenue to buy seats and to buy votes. By scrutinizing the voting-list of the two houses George III distributed rewards and punishments as members voted according to his will or no. "Promotion in the civil service, preferment in the Church, and rank in the army was reserved for 'the King's friends.'"¹ In the light of this those who have considered Paley as a quiet conformist need to observe his courage when upon receiving a warning from Bishop Law that if he included his analogy concerning the pigeons that it might exclude him from a Bishopric, Paley sternly replied "Bishop or no Bishop it shall go in."² Furthermore, Paley struck at the very roots of the political corruption of his day with his vigorous protest against bribery. Concerning the oath against bribery in the election of members of Parliament he wrote the following: The several contrivances to evade this oath, such as the electors accepting money under colour of borrowing, and giving a promissory --- ¹ Ibid. ² Paley, Edmund. The Life of Dr. Paley, p. cclvi. note or other security for it, which is cancelled after the election; receiving money from a stranger, or a person in disguise, or out of a drawer, or purse, left open for the purpose; or promises of money to be paid after the election; or stipulating for a place, living, or other private advantages of any kind; if they escape the legal penalties of perjury, incur the moral guilt: for they are manifestly within the mischief and design of the statute which imposes the oath, and within the terms indeed of the oath itself; for the word "indirectly" is inserted on purpose to comprehend such cases as these. There is no doubt but that Paley's work stirred the public opinion against the corruption of that day until the second Pitt was able to lead such reforms as virtually to obliterate the bribery of the members of Parliament. There appears to be a rather curious inconsistency in Paley's insistence on the one hand on a rigid conformity to the oath by members of Parliament, while on the other hand he appeals for a rather loose interpretation of the Articles of Faith for Clergymen. In fact, he has been credited with the statement that "a man's conscience is no worse for a little ink." In all fairness to Paley, however, it should be remembered that he was not in this case appealing 1 The Principles of Moral and Political Philosophy, p. 133. for the right of the Clergy to be indifferent toward the Articles of Faith. On the contrary, he was appealing for the right to look behind the Articles themselves to the purpose for which they were instituted. This purpose, he insists, cannot be discovered in the bald statement of the Articles themselves but must be traced back to the intention of the thirteenth Elizabethan legislature, which was the imposer of the Articles.$^1$ Paley contended that the intention of this legislature was not that each clergyman should believe every separate proposition in the Articles. Instead of this, it was their purpose to exclude from office all abettors of Popery, Anabaptists, who were at that time a powerful party on the Continent, the Puritans, who were hostile to the episcopal constitution, and in general the members of such leading sects, or foreign establishments, as threatened to overthrow the Church of England.$^2$ Paley insisted that any one finding himself within the above descriptions ought not to subscribe to the Articles. He, however, emphatically stated that for Protestant Churches to renounce with all their might the infallibility of the Popes and at the same time insist on the infallibility of the thirty-nine Articles was highly inconsistent. $^1$ The Principles of Moral and Political Philosophy, Bk. III. Ch. XXII, p. 138. $^2$ Ibid. more, said Paley, subscription to these Articles does not bind a man against altering his opinion. Paley's critics have seen in his vacillation concerning the belief of each separate article of religion and in his later reasoning that one has justifiable grounds for lying to a murderer or a robber, ample proof of the moral unworthiness of the utilitarian theory. Compared with the strong statement of Kant concerning truth-speaking as an absolute obligation, Paley's argument loses its lustre. However, J. S. Mill denies that the principle of utility leads to the conclusions that Paley drew. For, says Mill, thorough-going utilitarianism would demand that in estimating the consequences of actions for the purpose of measuring their morality not only must the outward interests of all persons involved be considered but also their inward interests, namely, the consequences to their characters. The complexity of this consideration is far greater than Paley allowed for. He did not consider the effects that taking such liberty with the truth would have upon the character of the agent himself and also upon --- 1 A Defense of the Considerations on the Propriety of Requiring a Subscription to Articles of Faith, Sermons and Tracts, London (1802), p. 7. 2 Gisborne, Thomas. The Principles of Moral Philosophy Investigated and Applied to the Constitution of Civil Society, Bk. II, Ch. vi, p. 46. 3 Dissertations and Discussions, Political, Philosophical and Historical, Vol. I, Second Edition, pp. 129, 130. the others involved. Nor did he consider the total effect that the dulling of moral judgments of man would have upon society. That is not to say, however, that Paley was totally unaware of the internal principles at work in true morality, for in his sermon on honesty he states that the final judgment of a man's character must be decided by asking the question, is he honest upon principle or honest out of policy? That is to say, his honesty is a virtue only when he is honest from principle. Says Paley, the "test of honesty as a principle is when a transaction is of a nature to be perfectly secret, when the truth of it is known only to ourselves, to act then with complete fidelity is to have honesty as a principle."¹ Coming back to Paley's views on property, his utilitarianism is clearly seen when he raises the question whether or not private ownership of property will stand the test of expediency when its excessive possession causes so much poverty among the masses who do not and cannot possess it. To this question he brings the following answer: there must be some very great advantages in maintaining the right of private possession of property to counteract the misery suffered by those who possess none. Paley sees the following advantage in this institution: the fact that the cultivation ¹ Paley's Sermons, Vol. V, Sermon ix, p. 438. of the land can best be encouraged by keeping the masses dependent for their livelihood on such employment. Again, the production of the earth is preserved to maturity by men who possess the land and refuse to open their orchards to the passerby who would pluck the fruit prematurely. Furthermore, the possession of property improves the conveniency of living in two ways: it stimulates the division of mankind into distinct professions, which is impossible unless a man can exchange the productions of his own art for what he wants from others, and the possibility of exchange implies the possession of property. When a man is his own tailor, carpenter, cook, and huntsman, he, in all probability, will never be an expert in any of these callings. Consequently, life under such circumstances could never advance to the stage of convenience known in a highly cultivated society. Hence, Paley concludes that for all the disadvantage involved in the private possession of property, they are far outweighed by the advantages and that while inequality of property, in the degree in which it exists in most countries of Europe, abstractly considered, is an evil, it is an evil which flows from these rules concerning the acquisition and disposal of property by which men are incited to industry, and by which the object of their industry is rendered secure and valuable. In an age when France was in the convulsion of a revolution Paley's cautious good sense enabled him to remind Englishmen of their love of order and law, their distaste for violent changes, and their reverence for the past. In his Reasons for Contentment Addressed to the Labouring Part of the British Public, which he considered the best thing ever to come from his pen, Paley urged the laboring men of Britain to believe that nothing good would be finally gained in a division of the great estates. He again brought his utilitarian principle to the front and argued that: Either...large fortunes are not a public evil, or, if they be in any degree an evil, it is to be borne with, for the sake of those fixed and general rules concerning property, in the preservation and steadiness of which all are interested. Paley proceeds from this point to show that the condition of the laboring man is just as blessed as that of the nobility by enumerating the following advantages which he possesses: the constant train of employment, the want of which is one of the greatest plagues to the human soul, the advantage in providing for children. "With health of body, innocency of mind, and habits of industry, a --- 1 Paley's Works, Vol. VIII, 1809, "Reasons for Contentment", p. 183. poor man's child has nothing to be afraid of." On the other hand the nobleman's child is accustomed to ease and the parent is faced with the task of assuring him of an income which will guarantee him the pleasure of continuing in that ease. Furthermore, the poor have a greater relish for their pleasures than do the rich whose desires are dead and whose sensibilities are worn and tired. When once the habit is formed, Paley argues that the luxurious receive no greater pleasures from their dainties than the peasant does from his homely fare. He warns the poor against envying the rich man's ease, for that which is most frequently construed as ease is inactivity. Nothing, says he, is farther from ease than inactivity. Rest is ease, but no man can rest until first he has worked. Rest is cessation from labor. It cannot therefore be enjoyed or even known except by those who have known fatigue. In his appeal for contentment Paley writes: To learn the art of contentment is only to learn what happiness actually consists in. Sensual pleasures add little to its substance. Ease, if by that be meant exemption from labour, contributes nothing. One, however, constant spring of satisfaction, and almost infallible support of --- 1 Ibid., p. 188. cheerfulness and spirits, is the exercise of domestic affections, the presence of objects of tenderness and endearment in our families, our kindred, our friends. Now have the poor anything to complain of here?...The poor man has his wife and children about him; and what has the rich more? He has the same enjoyment of their society, the same solicitude for their welfare, the same pleasure in their good qualities, improvement and success.....if I were disposed to envy anyone, the subject of my envy would be, a healthy young man, in full possession of his strength and faculties, going forth in a morning to work for his wife and children or bringing them home his wages at night. After this strong appeal for contentment, Paley continues with this reminder. The only change to be desired is that gradual and progressive improvement of our circumstances which is the natural fruit of successful industry; when each year is something better than the last. His concluding word is to warn the masses against seeking to seize the rich by force through the medium of public uproar, for such would be to "not only venture out to sea in a storm, but to venture for nothing." 1 Ibid., pp. 193, 194. 2 Ibid., p. 196. 3 Ibid., p. 198. On the surface the above argument might appear to make Paley the champion of the privileged classes of his day. It should be remembered, however, that Paley was a vigorous defender of the rights of the poor. He worked tirelessly for the advancement of the Sunday Schools, that every poor child in the Kingdom might have a chance to learn to read. Not only did Paley advocate this, but he prepared a manual for teaching reading in the Sunday Schools. He inveighed against the popular opinion that it was not for the advantage or safety of the state that the children of the poor should receive any kind of education, or be even taught to read, contending that: It is in the highest degree both dishonorable to human reason, and disparaging to the institutions of social life, it, in fact, insinuates that the bulk of mankind can only be governed by the suppression and debasement of their intellectual faculties, and it likewise insinuates that the institutions of civil life rest for their support upon the ignorance of the greatest part of those who live under them. Paley then passionately declared, "I should be glad to see the day --- 1 Paley's Works, Vol. VIII. "The Young Christian Instructed in Reading and in the Principles of Religion," p. 201. 2 Paley's Sermons, Vol. VI, Charge viii, p. 62. when every child in the Kingdom was taught to read.\textsuperscript{1} In the second division of relative duties Paley places indeterminate duties. The most outstanding phase of this part of his work was his treatment of the question of slavery. As indicated in the biographical section of this thesis Paley was a strong crusader against slavery. In the year 1792, the residents of Carlisle met for the purpose of petitioning Parliament for the abolition of the slave trade. Mr. Paley had been made acquainted with the cruelties involved in this pernicious traffic by a relation who had made a fortune in the West Indies as a planter. He now found that neither his humanitarian feelings nor his common sense of morality would allow him to remain silent on the subject. In April, 1789, the newspapers carried a short treatise by Mr. Paley entitled "Arguments Against the unjust pretentions of slave dealers and holders, to be indemnified by pecuniary allowances, at the public expense, in case the slave trade should be abolished," which had been sent to the committee on abolishing \textsuperscript{1} \textit{Ibid.} slavery. This was designed to reach them for use in the first great discussion in the House of Commons on the abolition of the slave trade. The resolutions drawn up at Carlisle became the basis of the petition afterwards presented to the House of Commons, which presented a clear and comprehensive view of the leading arguments which eventually led to the abolition of slavery. It is much to Mr. Paley's honor that he suggested a plan for promoting the civilization of Africa, and for making some restitution to that devastated continent, for the malicious injustice and oppression which it had so long suffered. His proposition was that from the United States of America several little colonies of free negroes should be exported and allowed to settle in different parts of Africa that they might serve as patterns of more civilized life to the natives in these localities. In his Principles of Moral and Political Philosophy, Paley defines slavery as "an obligation to labour for the benefit of the master without the contract or consent of the servant."¹ ¹ The Principles of Moral and Political Philosophy, Bk. III, Part ii, Ch. 3, p. 149. This obligation may arise according to the law of nature from three causes: from crimes, from captivity and from debt. When, slavery is the punishment of the offenders crime, says Paley, the continuence of the slavery ought to be in strict proportion to the crime and when it is the result of captivity in war or the refusal to pay a private debt, it should cease as soon as the demand of the injured nation, or private creditor, is satisfied. Having enumerated what he considers the only justifiable causes of slavery Paley concluded that the slave trade upon the coast of Africa was not to be excused on any of the above principles. The fact was that when the slaves were brought to market in Africa no questions were asked about the origin or justice of the vender's title. It was, therefore, very evident that the title was not always founded on the commitment of some crime, the injury of some tribe nor even the refusal to pay a private debt. A defective title, however, was the least of the crimes with which the slave traffic was chargeable. Paley saw as the greater crime the fact that the natives, were being incited to war and mutual depredation for the sake of supplying their contracts, or furnishing the market with slaves. Here the wickedness begins: The slaves torn away from parents, wives, children, from their friends and companions, their fields and flocks, their home and country, are transported to the European settlements in America, with no more accommodation on shipboard, than what is provided for brutes. This is the second stage of cruelty; from which the miserable exiles are delivered, only to be placed, and that for life, in subjection to a dominion and system of laws, the most merciless and tyrannical that ever were tolerated upon the face of the earth. Paley deals with each of the defences projected by the slave-traffic as follows: to the argument that slavery was an economic necessity in America, that is, that the land could not be cultivated by hired servants without putting an impossible price on the produce of the land, he replies that the necessity for which the slave owner contends amounts to no more than saying that a pound of sugar which now sells for sixpence could not be afforded should it be advanced to sixpence-halfpenny. To the contention that slavery was a part of the civil constitution of most countries when Christianity appeared yet no passage is to be found in the Christian Scriptures by which it is condemned or prohibited, Paley replied that Christianity in seeking admission into all nations of the world abstained from intermeddling with the civil institutions of any. But, said he, it does --- 1 Ibid., p. 149. not follow from the silence of Scripture concerning them, that all the civil institutions which then prevailed were right. Moreover, the discharging of slaves from all obligation to obey their masters would have turned loose one half of mankind upon the other. The basis of the appeal for adherents to the Christian religion would have been lowered. Slaves would have been tempted to embrace it from ulterior motives, and masters would have been repelled from it and the most calamitous of all contests, a bellum servile, would have ensued, to the everlasting reproach if not to the utter annihilation of the Christian religion. To Paley's sound remarks may be added the fact that the Apostles while exhorting slaves to patience, never vindicated the institution choosing rather to dwell on the duty of taking care not to bring an ill-name on their religion. They are rather to suffer a wrong than to raise a prejudice against Christianity.$^1$ The Apostles considered it the Christian duty of a slave to forego any rights he may possess if such is necessary for the furtherance of the Gospel. Paley's proposal concerning emancipation was that it should be gradual under the protection of civil government and by $^1$ I Timothy V. the mild diffusion of the light and influence of Christianity. Howbeit he called his own government to immediate action and warned Britain that it was questionable: Whether a legislature, which had so long lent its assistance to the support of an institution replete with human misery, was fit to be trusted with an empire the most extensive ever obtained in any age or quarter of the world. Under his definition of relative duties Paley places in the third division those duties which result from the constitution of the sexes and proceeds to discuss the public use of marriage institutions, fornication, seduction, adultery, incest, polygamy, divorce, marriage, the duty of parents, the rights of parents and the duty of children. Paley's utilitarianism is very apparent in his treatment of the marriage institution. Marriage promotes the comfort and security of the female sex, makes possible the production of the greatest number of healthy children, facilitates the best form of government by distributing the community into separate families and by appointing over each the authority of a master of the family, secures the state by promoting the good behavior of its citizens, and encourages 1 Ibid., p. 150. industry to provide for the needs of the family. Paley gives as a reason for insisting upon abstinence from any conduct which tends in its general consequence to obstruct marriage the fact that whatever promotes the happiness of the majority is binding upon the whole. Paley argues against fornication on the ground that promiscuous concubinage discourages marriage, by abating the chief attraction of it. Says he, the male of the species will not undertake the incumbrance, expense, and restraint of married life, if they can gratify their passions at a cheaper price. Paley believed that since sexual passion is natural, it was intended to be gratified, but that the circumstances under which it may be gratified must be determined by the utilitarian principles and by the Scriptures. He condemns the practice of keeping a mistress even under circumstances of mutual fidelity and answers those who say that such a relationship is the same as marriage by raising the question, why, then, do they not marry? Furthermore, the relationship is not the same for the children, born in such a union. Moreover: It is immoral because it is pernicious that men and women should cohabit, without undertaking certain irrevocable obligations, and mutually conferring certain civil rights; if, therefore, 1 The Principles of Moral and Political Philosophy, Bk. III, pt. iii., ch. 1, p. 185. the law has annexed these rights and obligations to certain forms, so that they cannot be secured or undertaken by any other means, which is the case here, (for whatever the parties may promise to each other, nothing but the marriage ceremony can make their promise irrevocable), it becomes in the same degree immoral that men and women should cohabit without interposition of these forms. Every incentive to fornication must be viewed as an accessory to the crime. Among such accessories he lists wanton songs, pictures and books which incite temptation. Seduction is condemned on the ground that it destroys the greater happiness of the victim by diminishing her prospects of marriage. Marriage is that from which a woman expects her chief happiness. Without it she is bereft of security. If she is to support herself through employment, her very employment is dependent upon her character and reputation. If through seduction she has lost these, she has left one alternative, either to starve or to have recourse to prostitution for food and raiment. More detrimental than the economic aspect is that the loss of chastity destroys her moral principle. This destruction takes place whether the unlawful intercourse is discovered or not. 1 Ibid., Bk. III, part iii, Ch. 2, pp. 188, 189. To calculate the enormity of the crime of seduction Paley proposes that a father or a brother should announce for what consideration they would suffer this injury to a daughter or a sister. His conclusion would most often be that the total loss of his property would not create as much suffering on his part as would the loss of chastity on the part of his daughter or sister. Again the public at large loses the benefit of the women's service in her proper place and destination as a wife and parent. Weighing all the consequences Paley concludes that "not one half of the crimes for which men suffer death by the laws of England, are so flagitious as this." He laments the fact that in the light of the above the only punishment for this offense is a pecuniary satisfaction to the injured family for the loss of the daughter's service during her pregnancy or nurturing. Adultery receives the same treatment at the hands of Paley. Here a new sufferer is introduced, the injured husband who receives the most painful and incurable wound to his affections that human nature knows. Not only does adultery receive the condemnation of Paley, but he contends that "all behavior which is designed, 1 Ibid., p. 192. or which knowingly tends, to captivate the affection of a married woman, is a barbarous intrusion upon the peace and virtue of a family, though it fall short of adultery. In his discussion of divorce Paley first of all discusses the congruity of the right of the husband to put away his wife with the law of nature. He finds such a practice incongruous with the law of nature because such makes it impossible for parents to fulfill their duties to their children. Furthermore it is incompatible with the right which the mother possesses, as well as the father, to the gratitude of her children and the comfort of their society; of both of which she is deprived when she is dismissed from her husband's family. Paley then traces the effects of divorce upon the general happiness of married life and concludes that a lawgiver, whose views are directed by views of general utility, would make the marriage contract indissoluble because it preserves the peace and concord between married persons and gives them an incentive to contribute to their mutual well being realizing that neither can find their own comfort without promoting the pleasure of the other. Furthermore, new objects of desire would be continually sought after, if men could at will be released from their marital obligations. Expediency would demand that the real and permanent happiness of one half of the species should not be surrendered to the caprice and voluptuousness of the other half. Following his custom of combining expediency with the teachings of Scripture, Paley shows that while the law of Moses, for reasons of local expediency, permitted the Jewish husband to put away his wife, Christ revoked this permission and promulgated a law which was thenceforward to confine divorces to the single cause of adultery in the wife.$^1$ Paley held rigidly to the plain meaning of Christ's teaching. He held that when it was necessary for their mutual happiness that a husband and wife should separate, they may separate by common consent, nevertheless they are not to have the right of re-marriage. II In the second major category Paley places the duties to ourselves including self-defence, the consideration of drunkenness and suicide. The latter two duties are included because they are offences against the care of our faculties and preservation of our persons, which are accounted as duties to ourselves. $^1$ Matthew xix.9. Concerning the rights of self-defence Paley reasons that the law of nature immediately justifies taking the life of an assailant when one's life is threatened. This is true because the laws of society have not restrained the intended murderer nor can society make restitution of the life about to be taken. Homicide is justifiable to prevent the commission of a crime, which when committed, would be punishable with death, and in suppressing riots and in apprehending malefactors. As seen in the biographical section of this thesis, Paley was an ardent crusader for temperance even going so far as to seek the revoking of the licenses of many grog shops in his day. He argued against the mischief of drunkenness on the grounds that it weakens those inhibitions upon which our controlled behavior depends, and leads into excessive anger, and sins of lewdness; it disqualifies men for their duties by disordering their faculties, it is attended with expenses which most cannot afford, it brings great anxiety to the family of the drunkard, and shortens life. Not least among the consequences of drunkenness is the corruption of the drunkard's companions. While one may be free from family responsibilities and able by virtue of a strong constitution to withstand the devastation of constant drinking, in all probability there will be those in his society who have family responsibilities and whose constitutions cannot withstand the ravages of liquor. Furthermore, Paley reminds us of the endless chain of consequences which follow the influence of a drunkard upon another and he in turn upon another. To his argument Paley brings the argument of St. Paul. "Be not drunk with wine, wherein is excess."¹ "Let us walk honestly as in the day, not in rioting and drunkenness."² "Be not deceived; neither fornicators, nor drunkards,....shall inherit the kingdom of God."³ Furthermore, Paley sees that the guilt of drunkenness will be in proportion to the probability of criminal conduct which it incites. By virtue of this rule, those vices which are the acknowledged effects of drunkenness, are virtually as criminal as if committed when one has all his faculties and senses about him. A person then incurs a part of the guilt of these crimes when he brings himself into the condition which incites them. ¹ Ephesians v.18. ² Romans XIII.13. ³ I Corinthians vi. 9, 10. Upon the subject of suicide Paley marshalls all his dialectical skill to show the general consequences of such a practice. For the sake of argument he reduces the problem to this: May every man who pleases to destroy his life, innocently do so?¹ Most often men come to the decision to destroy themselves from the conclusion that they have become useless to mankind and forget that melancholy minds are prone to think themselves useless, when they really are not so. Suppose, said Paley, what the general consequence would be if a law were promulgated allowing each private person to destroy every man he met, whose longer continuance in the world he judged to be useless. The general consequences would assuredly be a permission to commit murder at pleasure. Moreover, no man can declare himself to be permanently useless, for he may always regain some measure of usefulness. Again, those contemplating suicide are called upon to consider whether the general sorrow for their death would not exceed that which they should suffer by continuing to live. Any consideration that would increase the toleration of suicide would result in the loss of many lives to the community and inasmuch as mankind must ¹ The Principles of Moral and Political Philosophy, Bk. IV. Ch. iii, p. 245. live in continual alarm for the fate of their friends and dearest relations, the unspeakable suffering that would result from this could not be justified on utilitarian grounds. Paley's eschatological emphasis comes to the front here as he reminds those who contemplate suicide that by remaining in this world and exercising those virtues which remain within their power, the opportunity to improve their condition in a future state is maintained. Finally there are many passages of Scripture from which we may deduce the will of God concerning suicide. In the Bible human life is spoken of as a term assigned or prescribed to us. "Let us run with patience the race that is set before us."¹ "That I may finish my course with joy."² The belief that we are at liberty to determine the duration of our lives is thus inconsistent with the implication of Scripture which considers life as a "race that is set before us" or as "our course." ¹ Hebrews 12:1. ² Acts 20:24. III The final major category of duties deals with our duties towards God including the duty of prayer, public worship, Sabbath observance and reverencing the Deity. Paley realizes that in one sense every duty is a duty to God since it is his will which makes it a duty. In this category he places those duties of which God is the object as well as the author. The moralist can only deal with the visible expressions of devotion to God. Paley divides these external duties into worship and reverence. The distinction between these two is that one consists in action and the other in forbearance. For example: When we go to Church on the Lord's day, led thither by a sense of duty towards God, we perform an act of worship: when we rest in a journey upon that day, from the same motive, we discharge a duty of reverence. Paley deduces the duty of prayer from the light of nature by showing that it is the universal method of man to obtain the object of his desire by entreaty. Says he, what is universal must be natural, and the impulse which God has planted in the human heart to obtain what we want from others by entreaty must lead us to intreat him as our supreme Governor for our desires. 1 Ibid., Bk. V, Chap. 1, pp. 253, 254. Prayer is necessary in the Christian life as a constant reminder of man's dependency upon God. Yet Paley makes the duty of prayer primarily dependent upon its efficacy, for, says he: I confess myself unable to conceive how any man can pray, or be obliged to pray, who expects nothing from his prayer; but who is persuaded, at the time he utters his request, that it cannot possibly produce the smallest impression upon the Being to whom it is addressed, or advantage to himself. Now the efficacy of prayer imparts that we obtain something in consequence of praying which we should not have received without prayer. To the objection to prayer which says that God's goodness and wisdom is such that if what we request in prayer be fit for us, we shall have it without praying and if it be not agreeable to his goodness and wisdom we cannot obtain it by praying, Paley replies that it is agreeable to the perfect wisdom and goodness of God to give us through prayer what he could not give us without prayer. It is God's will to change his will through prayer. Paley did not think of the immutability of God as the immobility of God but rather as his moral self-consistency. The question then arises what virtue is there in prayer which would make the granting of a favor consistent with God's 1 Ibid., Bk. V, Ch. ii, pp. 254, 255. wisdom, which would not have been so without it? Paley's reply reflects his utilitarian principle. The granting of a favor as a result of prayer, says he, would have a stronger possibility of producing good effects upon the recipient. That which is received without asking is often received without gratitude. Furthermore, the wisdom of the Deity is reflected in answered prayer by virtue of the fact that by withholding his favors until they are asked for, he encourages devotion in his rational creation by sustaining in them a sense of their dependence upon him. Again, prayer has a natural tendency to bring the petitioner within the rules which God has prescribed to the dispensation of his favors. Even the inconstancy of answered prayer Paley interprets in the light of expediency for, says he, if prayer were allowed to disturb the order of second causes appointed in the universe too much, it would be extremely detrimental to human well-being. For example, few would be willing to work if they could receive their wants through prayer. Moreover, no man would care for his health if prayer would immediately check the course of disease and restore his health. Therefore, there is of necessity the right possessed by God to withhold an answer to prayer, and even then God is discouraging carelessness and disorderliness in the race which restraint is necessary to the happiness of humanity. Against those who argue for the irrationality of praying for particular favors by name or of interceding for others or for whole nations as if to say that the happiness of others or whole nations could be dependent upon our prayers, Paley answers by saying: The happiness and misery of great numbers we see oftentimes at the disposal of one man's choice, or liable to be much affected by his conduct; what greater difficulty is there in supposing, that the prayers of an individual may avert a calamity from multitudes, or be accepted to the benefit of whole communities.$^1$ Having argued from the light of nature the probability of answered prayer, Paley then turns to the revelation of Scripture for the positive affirmation of the propriety of prayer. He then lists specific passages which enjoin prayer in general, for example, "Ask and it shall be given you, seek and ye shall find."$^2$ Examples of prayer for particular objects are also given, for example, "For this thing (to wit, some bodily infirmity, which he calls a 'thorn --- $^1$ Ibid., Bk. V, Chap. ii, pp. 260, 261. $^2$ Matthew VII.7. given him in the flesh') I besought the Lord thrice, that it might depart from me."¹ He calls attention to the directions to pray for natural or public blessings, for example, "Pray for the peace of Jerusalem."² Examples of intercession are mentioned as "Peter therefore was kept in prison, but prayer was made, without ceasing, of the Church unto God for him."³ Finally, a list of declarations and examples authorizing the repetition of unsuccessful prayers is given, for example, "And he left them and went away again, and prayed for the third time, saying the same words."⁴ Paley makes a strong appeal for a rigid observance of the Sabbath on the grounds of public utility. Because of the relaxation afforded to the laboring part of humanity and the consequent happiness of so great a part of humanity, it is every man's duty to uphold the observance of the Sabbath. The benefits of Sabbath observance are extended by Paley even to the brutes as they find respite from their toil. The light of nature reveals the necessity of one day's rest out of seven but only the Revelation of God can tell us which day to observe. ¹ 2 Corinthians XII.8. ² Psalm CXXII.6. ³ Acts XII.5 ⁴ Matthew XVI.44. At this point Paley takes up the question concerning the day which is to be observed, that is, whether it should be the seventh day of the week, the Jewish Sabbath, or the first day of the week, the Christian's Lord's day. He argues that it was not until the wilderness sojourn of the Israelites that an express command of God was given concerning the Sabbath. This, says he, emphasizes the fact that the Sabbath was distinctly a Jewish institution. Paley does not believe that the statement in the second chapter of Genesis concerning the sanctifying of the Sabbath day meant that God sanctified it as a universal institution at the dawn of creation, rather did he take the fact of his resting on the seventh day as the basis for sanctifying the day for his people in the wilderness. The passage in Ezekiel XX: 10, 11, 12, speaks of the Sabbath as being given to Israel. Paley believes this to be a reference to the historic event in the wilderness. If, then, the divine command was not given at the creation but rather in the wilderness, it does not apply to all men but only to the Jews. Furthermore, Paley shows that Exodus XXXI.16, 17, speaks of the Sabbath as a sign between God and his people. Coming to the relation of the Christian to the Sabbath, Paley shows that the observance of the Sabbath was not one of the articles enjoined by the Apostles in the fifteenth chapter of Acts. upon them "which from among the Gentiles were turned unto God." In Colossians II. 16, 17, Paul considers the Sabbath as a part of the Jewish ritual. The supreme question at this point should be: Did the founder of the Christian religion deliver any new command on this subject? The answer to this Paley finds in the fact that the practice of holding religious assemblies on the first day of the week was so early and universal in the Christian Church that it carries with it considerable proof of having originated from some precept of Christ or his Apostles, though none such is now extant. It was upon the first day of the week that the disciples were assembled, when Christ appeared to them for the first time after his resurrection.¹ The second meeting with the disciples was also on the first day of the week.² The same custom is found prevailing in a Church far from Jerusalem.³ By the time John wrote the Revelation the first day of the week had obtained the name of the Lord's Day. Paley did not contend for the carrying over of the Jewish prescription for the observance of the Sabbath into the Lord's day but only for the observance of worship on that day. In fact he states that: ¹ John XX:19. ² John XX.26. ³ Acts XX.6, 7. A cessation upon that day of labour, beyond the time of attendance upon public worship, is not intimated in any passage in the New Testament; nor did Christ or his Apostles deliver, that we know of, any command to their disciples for a discontinuance, upon that day, of the common offices of their professions.$^1$ Paley continues by insisting that it would have been highly improbable that Christ would have enjoined upon the Jews to whom he addressed his Gospel another day of rest when they already were observing one. Moreover, it is held that there is not sufficient proof that Christ intended to retain the duties of the Jewish Sabbath by shifting them to the first day of the week. Paley further contends that, while it is not improbable, still there remains no evidence in Scripture that the first day of the week was distinguished in commemoration of our Lord's resurrection. The law of Christianity is that the assembling upon the first day of the week for the purpose of public worship and religious instruction is of divine appointment. Further resting from employment is to be based on the law of nature and is binding upon the conscience because of the benefits it bestows upon the people. --- $^1$ The Principles of Moral and Political Philosophy, Bk. V., Ch. vi, p. 291. The final duty discussed in this category is that of reverencing the Deity. Paley pleads for a rigid observance of the third commandment, namely, "Thou shalt not take the name of the Lord thy God in vain." By vain is meant that which is useless and it is useless when it is not likely to serve a good purpose. For example, when the name of the deity is used in anger, in mirth, or to express courage, it is used in vain. Christ's command against swearing is a reaffirmation of the third commandment as well as an enlargement upon it.$^1$ Included under this should be mockery and ridicule of the Scriptures, for such is inconsistent with a religious frame of mind. A mind intent upon the attainment of heaven, says Paley, must reject with indignation every attempt to entertain with jests about heaven, for nothing but the most frivolous dissipation of thought can make even the inconsiderate forget the supreme importance of everything which relates to the future existence: Whilst the infidel mocks at the superstitions of the vulgar, insults over their credulous fears, their childish errors, and fantastic rites, it does not occur to him to observe that the most preposterous device by which the weakest devotee ever believed he was securing the happiness of a future life, is more rational than unconcern about it. Upon this subject, nothing is so absurd as indifference;—no folly so contemptible, as thoughtlessness and levity.$^2$ --- $^1$ Matthew V.35. $^2$ The Principles of Moral and Political Philosophy, Bk. V, Chapt. IX, p. 298. CHAPTER V AN EVALUATION OF PALEY'S ETHICS IN CONTRAST WITH CURRENT CHRISTIAN ETHICS Thus far in this thesis the writer has endeavored to set forth the principles of Paley's ethics in the light of his eighteenth century environment and to give a positive exposition of the practical application of his ethics. The next project will be to offer a critical evaluation of Paley's ethics in the light of current trends. Much that has been written against the utilitarian theory and psychological hedonism in general would, of course, apply to Paley. The most devastating criticism which has been brought against all the utilitarian theories is the contention of Kant that there is an absolute distinction between matters of prudence and matters of ethics. That is to say, simply to ask what action will bring the most happiness? raises only the question of prudence and does not touch the problem of morals. However, Kant is much closer to utilitarianism than is ordinarily thought. In fact, he insists that anyone who denies that he is in search of happiness is falsifying. Yet he denies that it is possible to calculate the relevance of any action to happiness. Therefore, it becomes necessary to act according to moral law. The way to make a happy world is to do one's duty and to act only in a way that one could wish all others to act. Kant insisted that "there is nothing in the world, or even out of it that can be called good without qualification, except a good will."¹ Paley is not far from Kant at this point. According to J. S. Mill, Paley held that we shall be judged by the intensity and continuity of our will to do good. That is to say, we shall be judged not by our deeds but by our dispositions.² As to Kant's objection that man is unable to predict the consequences of his action, let it be insisted that a part of man's moral responsibility is based upon his ability to see the consequences of his actions. A most convincing statement of man's ability at this point is made by Schäffle. He reasons that we are at least able to see as far as the next stage in the scenes of historical progress, and this is thought to lead to the ¹ Metaphysics of Morals. Section I. ² Dissertations and Discussions, Political and Historical. Vol. I, p. 153. conclusion that we should make this next stage of development our end; further than it, we cannot see, and, therefore, need not concern ourselves with a further end. If this is to mean that we have no ultimate end for conduct, Schäffle consoles us with the thought that we shall at least never be without a proximate end—and one which is always changing with the course of events. It is very apparent that the most commendable thing about utilitarianism is that it lends itself most directly to practical application by describing a definite end to be aimed at in life, namely, the greatest happiness of the greatest number. From this principle it is quite a simple matter to deduce rules upon which human conduct may be based. Adam Smith went so far as to say that the regard for general rules "is the only principle by which the bulk of mankind are capable of directing their actions." If this be true, it is not difficult to explain the readiness with which the eighteenth and nineteenth centuries responded to utilitarianism. In the subsequent development of moral philosophy it has become more and more apparent that no one principle can be adequate for the governing of the 1 Bau und Leben des sozialen Korpus, ii, p. 68. infinite complexity of moral conduct. ¹ Perhaps, however, we should not judge Paley by later Monistic Moralists. For it was the chief concern of moralists of Paley's day to find a simple method by which man might know his moral duty. In fact, John Gay said that this was the only problem confronting the moralists of his day. It has been charged that Paley had no originality. This is largely true, but perhaps there is a sense in which originality is not thinking differently from others but rather thinking for oneself. In this sense Paley was original. He was strongly influenced by his contemporaries. Yet he carefully weighed his material and made it his own. The hedonistic calculus was a part of his eighteenth century heritage. Butler, in referring to virtuous conduct, had said, "When we sit down in a cool hour we can neither justify to ourselves this or any other pursuit, 'till we are convinced that it will be for our happiness, or at least not contrary to it."² Shaftesbury and Hutcheson insisted that it is not necessary to reflect upon the principle of "the greatest happiness of the greatest number," ¹ An excellent treatment of the inadequacy of any one single principle for the guidance of the moral life may be found in Dr. Simmel's Einleitung in die Moralwissenschaft. ² Sermons, Sermon IV, p. 88. since it is naturally embodied in any cultivated taste. Sorley reminds us that even though these eighteenth century moralists were opposed to the selfish theory of human action, they never spoke of any sacrifice of private happiness.$^1$ In the light of this environment Paley's statement that, "We can be obliged by nothing but what we ourselves are to gain or lose something by,"$^2$ is not so obnoxious. Now, if pleasure is the object of action, then the utilitarian theory is the only valid one, and any argument against utilitarianism would logically begin with an attempt to show either that pleasure is not the end of action, or that it is not the sole end, or that it is not the chief end. Against the belief that pleasure is the goal which man pursues in action is the paradox of hedonism which insists that the quest of happiness is self-destructive, for the way to get happiness is to forget about it and aim at something else. Again, it should be remembered that pleasure is not an entity having an existence by itself independently of the object in which pleasure is felt. Consequently pleasure could never be the immediate goal of action. $^1$ Ethics of Naturalism. Ch. IV, p. 19. $^2$ Principles of Moral and Political Philosophy, Bk. ii, Ch. ii. It should be said to Paley's credit that in an age when reason was being emphasized so much that all of man's other powers were forgotten, that he recognized that man was not motivated solely by reason but that pleasure and pain are strong determinants of action. However, he failed to appreciate the fact to which Professor Sorley calls our attention, namely, that man is motivated "directly by pleasure and pain, and not by a mere estimate of pleasure and pain, but by pleasure and pain themselves."¹ Estimates of future pleasure and pain become motives for action not by being merely recognized (intellectually) but felt (emotionally), that is, by themselves becoming pleasurable or painful. It is obviously true that anything that satisfies the ultimate demands of our nature will be accompanied by pleasure and may be described as pleasure. This pleasure, however, must have some objective content which is something other than itself. The object producing pleasure may be any of a number of things as the pleasure of others or the fulfilment of duty. These things are objects which bring pleasure, but they are not pleasures in themselves. Moreover, to say that the most happiness of the most people is to be the goal of human action is the same as saying that the general ¹ The Ethics of Naturalism, p. 34. happiness is a good to the aggregate of all persons. The fallacy involved in this proposition is known in logic as "the fallacy of composition." As Professor Mackenzie pointed out, this fallacy infers that: Because my pleasures are a good to me, yours to you, his to him, and so on, therefore, my pleasures, plus your pleasures, plus his pleasures, are a good to me, plus you, plus him. It is forgotten that neither the pleasures nor the persons are capable of being made into an aggregate. If all human minds were capable of being rolled into one so as to form an aggregate, the above argument might hold true. But "the aggregate of all persons" is nobody. Therefore, nothing could be good to a nonentity. In other words, a good must be good to somebody. Paley was most assuredly in error when he insisted on a purely quantitative estimate of pleasure. He writes: In strictness, any condition may be denominated happy, in which the amount or aggregate of pleasure exceeds that of pain, and the degree of happiness depends upon the quantity of the excess. The fallacy here is that a sum of pleasures can no more be called pleasure than a sum of men can be called a man, for 1 Manual of Ethics, p. 219. 2 The Principles of Moral and Political Philosophy, Bk. I, Ch. VI, p. 14. pleasures can no more be added to one another than men can be added to one another. A particular pleasure may be desired but not a sum of pleasures, for such is a nonentity. The hedonism which identifies pleasure with our desires overlooks the fact that it is not our desires that we seek to satisfy but ourselves and that which would satisfy our desires depends upon the kind of person behind the desire. The nature of the highest happiness, then, would depend not on its quantity but on its belonging to the highest kind of character. In other words, it depends on the nature of the self and the spiritual environment in which he lives. The highest happiness then would be attained by living in the best spiritual environment and by satisfying the desires that belong to that environment. Furthermore, happiness is not found in the simple gratification of one single desire or of the greatest possible sum of desires. On the contrary, the real meaning of happiness is found in the systematizing of desire. Happiness at its highest is the feeling which accompanies the harmonious adjustment of the various essential elements in our lives or for the Christian man his essential unity with his fellows and with God. Therefore, while happiness is not the end of moral conduct it is an essential and inseparable element in its attainment. It should be remembered that Paley did not consistently hold to his quantitative theory of pleasure, for in insisting that not all pleasure is productive of happiness, he was introducing a determining factor which is above pleasure. One pleasure is more desirable than another, not because of its nature as pleasure, but because of some other quality it possesses. That is to say, pleasures must be rationally defined in order to determine those which are enduring, for only enduring pleasures are productive of happiness. II The chief concern of this chapter is not with the metaphysical implications of Paley's theory. On the contrary, since Paley was primarily an apologist of the Christian religion and was chiefly concerned with providing a theological sanction for ethics, we shall confine our efforts to answering two questions; namely, has the modern church made any significant advances beyond Paley in the field of ethics; and was there anything in Paley's system that the modern church needs to recapture? For the sake of simplification this discussion shall be arranged under four live issues in the field of ethics in Paley's day and in our own; namely, the relation of religion to ethics, the place of revelation in ethics, the place of reason in ethics, and finally, the place of eschatology in ethics. In the intervening period between Paley and the twentieth century, moral philosophers have emphasized their belief that the theological answer is too simple and easy to provide the final clue to man's moral problems. Obsessed with the theory of evolution the nineteenth century gave its allegiance to relativistic theories of ethics, and the breach between theology and ethics became strongly pronounced. Today, however, there is a movement away from relativism toward an authoritarian ethic. There are remarkable parallels between Paley's insistence upon the necessity of building the science of ethics on a theological foundation and the thought of men like Barth, Brunner and Niebuhr. In Paley's definition of virtue as, "The doing good to mankind in obedience to the will of God..." he was reacting against the eighteenth century humanistic rationalism which contended that morality may be based upon an innate moral sense. This was the position of Shaftesbury and Hutcheson who had a profound influence on Kant and caused him to be strongly prejudiced against a "theological ethic." In the Christian Church today there is a marked effort to bring ethics back to her only proper foundation, namely, a religion. 1 The Principles of Moral and Political Philosophy, Bk. I, Ch. vii, p. 27. which has as its center a revelation of the will of God. The fact that revelation is the keystone of modern Christian ethics is seen in Barth's definition of ethics: Ethics, so-called, I regard as the doctrine of God's command and do not consider it right to treat it otherwise than as an integral part of dogmatics, or to produce a dogmatics which does not include it.$^1$ Barth continues: "What is at stake in Christianity is the rule of God and nothing else."$^2$ Barth contends that in the realm of morals we must begin with God and to recognize the one and only God means to make all human systems of ethics relative. Furthermore, Barth supports this relativity of all human systems of ethics by citing Jesus' reply to the rich young ruler. "Why askest thou me concerning the good? One is good."$^3$ That is to say, only one possesses absolute goodness; goodness which is never on trial. Therefore, any objective ethical test cannot but lie beyond the world of space and time. Barth writes: "Our demonstrated existence in this world is measured upon a standard which is not at all a part of existence as we know it or conceive it."$^4$ --- $^1$ The Doctrine of the Word of God, Trans. G. T. Thomson, p. XIV. $^2$ The Resurrection of the Dead, p. 103. $^3$ Matthew 19:17. $^4$ The Word of God and the Word of Man, Trans. Douglas Horton, p. 138. Barth demonstrates the emptiness of all relative systems by contending that: "When the knowledge of God becomes manifest, they (all relative systems of ethics) no longer possess ultimate credibility."¹ Barth sees the relativism of all our codes and all our interpretations of life becoming evident in the modern revolt against "authority for its own sake." The "family for its own sake;" "art for its own sake;" work for its own sake;" even "religion for its own sake," are all rightly being rejected. These idols, says Barth, cannot stand alone.² In his concern to show the dependence of ethics upon a revelation from God, Barth argues that neither the unaided conscience nor the so-called religious consciousness can give us truth. On the contrary, truth can exist only in the moment of God's speaking to us, which determines our very existence. Starting with this conception of ethics Barth proceeds to show first that man is incapable of apprehending ethical truth or of fulfilling its requirements; and second, that both ethical truth, and ethical achievement are wholly dependent upon God's speaking to us. ¹ The Knowledge of God and the Service of God, Trans. J.L.M. Haire and Ian Henderson, pp. 18, 19. ² The Word of God and the Word of Man, Trans. Douglas Horton, pp. 292, 293. This emphasis is continued in the ethics of Emil Brunner. Insisting that there is but one true approach to morality and that all other approaches are ambiguous, Brunner starts with "a Divine Being" who must be the source of morality.$^1$ He discredits the practical approach to morality which looks for its authority to the agreement among men on moral issues and writes: There is scarcely one moral commandment which is everywhere accepted as final, on the contrary, the moral codes of the various peoples and civilizations completely contradict one another, not merely in points of detail but in principle.$^2$ Brunner is very close to Paley in his insistence that "to try to discover an original moral common sense behind these influences of the various religions is simply a wild-goose chase."$^3$ He insists that even conscience is not the voice of God but a sinister force driving us to despair.$^4$ Brunner concludes that man's endeavor to build human moral systems has culminated in the insoluble antithesis of religion versus ethics, freedom versus necessity, content versus formalism, individuality versus universality, and endaemonism versus rigorism.$^5$ --- $^1$ The Divine Imperative, p. 28. $^2$ Ibid., pp. 32, 33. $^3$ Ibid., p. 33. $^4$ Ibid., pp. 155ff. $^5$ Ibid., pp. 58ff. For Brunner the good is the sum of all the moral predicates which are not independent entities. On the contrary, ethics is the dependent child of theology and never its parent nor independent partner. Even the law of nature is the command of God.$^1$ His meaning is seen more clearly in his declaration that: Here there is no intrinsic good. What God does and wills is good; and all that opposes the will of God is bad. The good has its basis and its existence solely in the will of God....$^2$ the will of God only is good, and it is to be done because He wills it.$^3$ Another follower in this train is Reinhold Niebuhr. Concerning the ethic of Jesus, Niebuhr writes: It is concerned with the absolute demand of God upon human life and not with the expediencies required to keep the peace within a given society. It calls for an absolute obedience to the will of God without consideration of the consequences of moral action which must be the concern of any prudential ethic.$^4$ Niebuhr also insists on the thoroughgoing relativity of all human ethical insight and activity. He contends that the structure of human nature is such that any system of human ethics must --- $^1$ Justice and the Social Order, Trans. Mary Hottinger. $^2$ The Divine Imperative, p. 53. $^3$ Ibid., p. 58. $^4$ An Interpretation of Christian Ethics, p. 63. necessarily be relative.\textsuperscript{1} He sees the fundamental fallacy of rationalism in the fact that it regards man primarily as essentially an intellect which can by his unaided powers grasp all time and eternity. At the same time romanticism labors under the illusion that man is altogether a product of irrational forces. Niebuhr sees the failure of both rationalism and romanticism as due to "the lack of a principle of interpretation which can do justice to both the height of human self-transcendence and the organic unity between the spirit of man and his physical life."\textsuperscript{2} Although man has his rootage in this finite world, still on every side his nature aspires toward infinity until "the limits of the self lie finally outside the self."\textsuperscript{3} Thus Niebuhr reasons that since man is ever in the tension between what he is and what the reality which transcends him tells him he ought to be, it is inevitable that evidences of the relativity of his ethics should be manifested on all sides. Especially is this relativity in evidence in the sphere of relations between social groups. Niebuhr believes with Karl Mannheim that the ethical thought of all groups constitutes mere ideologies \textsuperscript{1} \textit{The Nature and Destiny of Man}, Vol. I, Chap. ii and v. \textsuperscript{2} \textit{Ibid.}, p. 123. \textsuperscript{3} \textit{Ibid.}, p. 156. \textsuperscript{4} \textit{Ibid.}, p. 196, 197. relative to social conditioning. Man is always prejudiced in his judgment of other parties: No party to the conflict has a perspective high enough to judge the merits of the opponents position. Every appeal to moral standards thus degenerates into a moral justification of the self against the enemy. For example, Niebuhr argues that in the dispute between the Jews and the Arabs in Palestine there is no human basis for a solution: The participants cannot find a common ground of rational morality from which to arbitrate the issues because the moral judgments which each brings to them are formed by the very historical forces which are in conflict. Niebuhr sees the same tragic relativity characterizing efforts to judge international conflicts. For even the so-called neutrals are incapable of disinterested action: There is, in short, no position in an international conflict from which impartial judgments are possible. Every judgment is colored by interest and every claim to impartiality fails in the end to obscure the partial and particular interest which prompted or corrupted it. Thus the international situation is a perfect picture of human finitude.... 1 Ibid., pp. 196, 197. 2 An Interpretation of Christian Ethics, p. 126. 3 Ibid., p. 127. 4 Ibid., p. 130. Going from the group to the individual, Niebuhr reasons that the individual is less biased in his judgment than the group but only in degree, not in kind, for: "We always judge ourselves by our own standards and weigh ourselves in balances which gives us a special advantage."¹ This finiteness of perspective and bias which characterizes all human judgments manifests the hopeless relativity of human ethics, however, the deepest expression of this relativity Niebuhr finds in the fact that any attempt to escape relativity is sinful and only intensifies it. Furthermore, Niebuhr argues that the very essence of sin is seen in man's effort to exalt his relative ideas into absolutes or to pretend that he is God. He writes: "That sin has its source not in temporality but in man's willful refusal to acknowledge the finite and determinate character of his existence."² All of man's attempts at morality are themselves tainted: Thus the moral urge to establish order in life is mixed with the ambition to make oneself the center of that order; and devotion to every transcendent value is corrupted by the effort to insert the interests of the self into that value. --- ¹ Ibid. ² The Nature and Destiny of Man, p. 177. ³ An Interpretation of Christian Ethics, p. 85. Moreover, Niebuhr contends that any attempt to elevate moral ideals is futile, for: "The higher the aspirations rise the more do sinful pretensions accompany them."¹ Thus he sees the international situation not only as a "picture of human finitude", but also as "a tragic revelation of the consequences of sinful dishonesty which accompany every effort to transcend it."² On the positive side of Niebuhr's ethic he contends that since man's relative nature is always reaching beyond itself, if the relativity of human ethics is to be transcended, it must come through the contacts between man and that which is beyond him. While Niebuhr believes that these contacts can only be described in myths rather than in the language of science, he nevertheless believes that they do take place in the revelation of God to man. Christian ethics is utterly dependent upon these revelations of God to man. Niebuhr writes: It does not establish a connection with horizontal points of a political or social ethics or with the diagonals which a prudential individual ethic draws between the moral ideal and the facts of a given situation. It has only a vertical dimension between the loving will of God and the will of man.³ --- ¹ Ibid. ² Ibid., p. 130. ³ Ibid., p. 39. In saying that Barth, Brunner and Niebuhr are like Paley in seeing the final meaning of morality in the will of God, we do not mean that they were in agreement as to how the will of God is known. On the contrary, they would utterly repudiate Paley's philosophical method of discerning the will of God through principles of expediency. When man presumes to thus describe the will of God he is, according to Barth, usurping the throne of God, for only God can manifest the will of God.$^1$ Brunner writes concerning the hedonistic calculus that while it is true that God wills our true happiness, we must not forget that, "He wills it in such a way that no one else knows what His will is."$^2$ Furthermore, Niebuhr insists that: "No pattern of human reason but only the will of God can be the principle of the form and order to which human life must be conformed."$^3$ Niebuhr repudiates Paley's method of reasoning from the goodness of God that He must desire the happiness of all men by contending that while God is a good God, He is, nevertheless, completely free.$^4$ We are not, therefore, to suggest that even the goodness of God is the basis of morality, for $^1$ The Knowledge of God and the Service of God, p. 20. $^2$ The Divine Imperative, p. 120. $^3$ The Nature and Destiny of Man, pp. 28, 29. $^4$ Ibid., p. 142. should we so do, we would be exalting a human relative category to an absolute status. Niebuhr emphatically insists that it is God's free self which is final and not merely something we can see in God. Moreover, Niebuhr refuses to give any further definition of good itself because to do so would be to subject himself to his own condemnation of the sin of making absolutes of the human thought patterns of a particular time and place. Therefore, the only account of good which he is willing to give is to identify it with the will of God who meets us at the limit of our experience. This insistence of Paley and of the modern school of neo-orthodoxy on an ethic based on religion is thoroughly in accord with the Christian tradition. Moreover, it is in complete harmony with the Hebraic psychology within which Christianity was formulated. Professor John Macmurray reminds us that the thing that distinguishes Hebrew culture from all others is that: Art and science, politics, law, morality and philosophy, or rather what corresponds to these autonomous spheres of activity in other cultures, remain, as in primitive society, aspects of religion. Religion, thus, never becomes a particular sphere of human activity, but remains the synthesis of all.¹ ¹ The Clue to History, p. 28. Christianity is not a dualistic view which severs ethics from religion, for it recognizes no ultimate separation between the service of God and social behavior. "Thou shalt love the Lord thy God"; "Thou shalt love thy neighbor as thyself." These are the two basic commandments, and they stand together. The close connection between religion and ethics within the framework of Christianity is revealed in the characteristic manner in which Paul writes his epistles. The first part deals with his theology or his reflection upon religious themes while the second part contains his ethical precepts and admonitions. A similar result is found in the Gospels where the evangelist follows a duality of structure. A narrative of events which contains the historical facts of theology will be given followed by certain ethical precepts. In other words, the ethical teaching of the New Testament is contained in a context which consists of a report of historical facts and an explanation of their religious significance. In the Old Testament there was a relationship between "haggada", the declaration or exposition of religious truth and "halakha", regulations for conduct. Likewise in the primitive Christian religion there was the distinction between the "kerygma", the proclamation of "the good news," and the "didache", the teaching. A convert to Christianity first of all responded to the "kerygma" and placed himself under the judgment and mercy of God revealed in Christ. He thus became a member of the Christian community, the church, and began to live a new life. He was then instructed in the ethical principles and obligations of the Christian life which are described by the Greek term, "didache", or teaching. Thus the order of approach in Christianity was first the proclamation of the Gospel and then the beginning of instruction in morals. This approach to ethics was set in marked contrast to that of contemporary Greek moralists who from the time of Aristotle had determined to establish a self-contained and self-justifying system of ethic. Christianity, however, presented ethics not as self-contained nor as self-justifying but as arising out of a response to the Gospel. In what is Paul's earliest extant epistle, and perhaps the earliest document of Christianity, the First Epistle to the Thessalonians, Paul addresses a congregation of newly converted Christians in the city now called Salonica in Macedonia. Fearing that these new converts from paganism might not fully appreciate the moral demands of the Gospel, Paul, after reviewing his theology in the first three chapters, proceeds to give to them what he calls "orders." The term which he uses was employed in military circles to describe army orders. This throws great light on Paul's attitude toward Christian liberty. He certainly does not think of the Christian attitude as anarchism. His "orders" to the Christians of Thessalonica are extremely practical. They are told to observe decent self-control in sexual relations, to respect the rights of others, to be honest and industrious, etc. Dr. C. H. Dodd has observed that these "orders" to which the Apostle refers belong to a regular course of ethical instruction for converts, the technical term for which was "catechesis". ¹ Paul also speaks of this body of instructions as "traditions". Dr. Dodd understands Paul's claim, that he received this tradition from others (I Corinthians 15:1-3), to mean that there was already in existence a traditional body of ethical teaching given to converts from paganism to Christianity. ² In writing to the Roman church, a church which he had not yet visited, Paul assumes that this body of ethical teaching has already been given them. He thanks God that the Roman Christians obey what he refers to as "the pattern of teaching" which they had received (Romans 6:17-18.) ¹ Gospel and Law, p. 14. ² Ibid., p. 15. Moreover, the style and form as well as content of such ethical exhortations as are found written by Paul in First Thessalonians (5:14-18), by the writer of Hebrews in Hebrews (13:1-3), and by Peter in his First Epistle (3:8-9), give evidence that these writers were influenced by the familiar form of ethical instruction or "catechesis" which existed in the earliest days of the Christian church. In addition to this Paul also claims to have a body of ethical instruction which he has received from the Lord and which is absolutely authoritative (1 Corinthians 7:8-12, 25, 40). He called upon his converts to "fulfill the law of Christ" (Galatians 6:2). Thus believing himself to have received authority from Christ, he gave "orders" to his converts, and unequivocally demanded obedience. It should be remembered, however, that Paul taught that these commands are addressed to those who have the resources of supernatural grace for their fulfilment. The law of Christ is based upon the revelation of the nature of the eternal God, and it affirms the principles upon which His world is built and which men cannot ignore without subjecting themselves to direst peril. Thus we conclude that ethics is dependent upon religion and that all moral obligation flows out of the moral nature of God as revealed in Christ. This does not mean, however, that an action is construed to be wrong because it is against an arbitrary will of God, but because it is against His intention for human life and therefore, it is against our highest welfare. By obeying the will of God man finds the highest fulfilment of that for which he was made. To refuse to act according to God's will is for man to find at death that he has not lived at all. The second item before us is the relation of revelation to ethics. How much Paley emphasized the central role of revelation in ethics has already been observed. We have also seen the central role of revelation in the system of Christian ethics that is fast moving to the front in current Christian circles. It must be remembered, however, that what Paley meant by revelation and what Barth, Brunner, and Niebuhr mean by it are vastly different. When Paley speaks of revelation he means the Bible as the Word of God. He regarded the Bible as the record of the dealings of an immutable God with people whose temperaments and circumstances were often like our own. 1 Macmurray, John. The Clue to History, p. 68. When, therefore, we wish to ascertain the will of God, we have only to go with seeking minds to the Bible and find how God dealt with men under similar circumstances in other days. Over against this neo-orthodoxy$^1$ is insisting that the Word of God is not to be identified with the Bible. The Word of God for Barth, Brunner, and Niebuhr cannot be divorced from God himself. For the Word of God to come to man is nothing less than for God himself to come. God's Word may come through the Bible or through preaching, but it is never to be identified with these. The Bible is the result of revelation. It is not the static vehicle which contains God's revelation, for God's revelation is never static. It is always dynamic and immediate. It is not something that hangs suspended in the stratosphere as a set of principles from which we, through the process of ratiocination can discern the will of God. It is rather, God breaking right through with this message to this man in this moment. It is significant that this view has spread very widely outside the school of neo-orthodoxy. For example, Dr. William --- $^1$ The writer understands that Barth, Brunner and especially Niebuhr have repudiated the idea that they belong to a school of thought. However, since many reviewers in America are choosing to classify them together under the category of "neo-orthodoxy," for the sake of convenience he chooses to follow this pattern. Temple says: "What is offered to man's apprehension in any specific revelation is not truth concerning God but the living God Himself."¹ Principal John Baillie writes: Revelation consists neither in the dictation of writings nor in the communication of information, but in personal communion—the self-disclosure of a personality. So also in the sphere of morals what has been revealed to us is not a code of rules which we must obey but a person to whom we are constrained to respond.² Coming back to Barth we find him contending that: "What God utters is never in any way known and true in abstraction from God Himself."³ God manifests His word in three forms, namely, preaching, Scripture, and revelation. Of these three Barth regards revelation itself as being ultimate while preaching and Scripture are mere forms of witness to the revelation itself. Furthermore, revelation can never be formulated into a code or system or displayed in scriptural quotation.⁴ On the contrary, revelation is always personal, living and purposive. It always has been and must forever remain God's mystery which when manifested leaves no residue that in itself may be called the "Word of God." For Barth contends ¹ Nature, Man and God, P. 322. ² Our Knowledge of God, p. 37. ³ The Problem of Ethics Today, p. 155. ⁴ Ibid., p. 159. that if God did not retain the manifestation of Himself in His own hands He would cease to be God.\textsuperscript{1} The Word of God cannot be known by the exercise of the intellect but only through divine grace acknowledged by faith which is itself the gift of a God who bestows it upon whom He pleases. Moreover, the Word of God is not a gift to mankind in general but is given "to this and that particular man."\textsuperscript{2} The only element of hope that Barth holds out in his ethics is seen in his contention that the other side of our despair is the breaking through of the Word of God upon us. This comes when we realize our impotence and look up to see the Light of God dawning upon us.\textsuperscript{3} This light does not come as a revelation of the particular acts which God approves but as a certain kind of existence which God demands. Neither does the light of God prescribe rules or details of our duty. Instead of this God demands that we choose our way in the light of the new existence which He approves for us. Brunner also follows in this tradition. He insists that the Bible represents a witness to the revelation of God which is not to be slavishly followed. While the commandments are helpful guides, \textsuperscript{1} \textit{The Knowledge of God and the Service of God}, p. 20. \textsuperscript{2} \textit{The Doctrine of the Word of God}, p. 181. \textsuperscript{3} \textit{The Word of God and the Word of Man}, p. 167ff. they do not of themselves constitute the Divine Imperative. This Divine Imperative must be unincumbered by any form of human control in order that it may come afresh to the particular person. Throughout his argument Brunner sternly warns against any human attempt to reduce the consistency of God to a principle, for this consistency itself can never be known save through the special revelation of God. Brunner stedfastly rejects any system of morality which would allow a moral code to usurp the throne of God. It is absolutely unthinkable to him that God should conform to a standard of good outside Himself. Brunner takes his stand firmly within the Old Testament tradition as he writes: An idea like that in the religion of Zarathustra that God became Lord because he chose the Good, the idea of a law which is even higher than God Himself is unthinkable in the Old Testament. Brunner combines his doctrine of revelation with his doctrine of man and insists that there is in man no nature apart from revelation. "Man has Spirit," he writes, only in that he is addressed by God...therefore, the human self is nothing which exists in its own right, no property of man, but a relation to a divine thou. 2 1 The Divine Imperative, page 53. 2 God and Man, English Translation, p. 155. humanity of man rests in nothing else than the divine Word addressed to him."1 For Niebuhr there are two kinds of revelation: private or general revelation, and public or specific revelations in history.2 The basis for our acceptance of special revelation is to be found in general revelation, however, we cannot fully understand general revelation apart from a special revelation in which God gives direction and force to conscience. In the special revelation of the Bible, Niebuhr says: A universal human experience, the sense of being commanded, placed under obligation and judged is interpreted as a relation between God and man in which it is God who makes demands and judgments upon man.3 Apart from such an interpretation of conscience through historical revelation, "conscience becomes falsified, because it is explained merely as man facing the court of social approval or disapproval or as facing his own 'best self'."4 These current conceptions of revelation are far more dynamic and vital than was that of Paley. However, it was commend- 1 Ibid., p. 160. 2 The Nature and Destiny of Man, Vol. I, pages 125 ff. 3 Ibid., p. 129. 4 Ibid., p. 130. able in Paley that in the face of the deistic opposition to all special revelation from God that he maintained his respect for the Book which contained the old, old story of God's dealings with men. Although, at times it appears that he is guilty of Bibliolatry, we must admit that even that is better than the total abandoning of the Bible. For if we are to be delivered from ethical relativism, we must begin with God. This is only made possible as God comes to us and as we have some word from God upon which our moral precepts may be founded. As Professor Pitirim Sorokin of Harvard has said: "It is only because they are derived from God that 'the moral values of Christian ethics are absolute.'" It has been objected that Paley's authority is an external force of a non-moral kind since it cannot be reasoned that the mere power of a supreme being could be accepted as sufficient ground for voluntary obedience to him. For such obedience would thereby become a "must", not an "ought." But this is a misinterpretation of Paley. He reasons from the absolute goodness of God that he must desire man's welfare and happiness. For him God's will is not an arbitrary fiat but the expression of absolute goodness. 1 The Crisis of Our Age, p. 139. Therefore, he grounded the basis of obligation to strive for the good in the nature of the good itself. iii The third phase of this chapter is to deal with the relation of reason to ethics. In common with the blithe spirit of eighteenth century England Paley saw man as the creation of a God who desired above all else man's happiness and had made the whole created order to serve this purpose. To be the recipient of God's bounty all that was necessary for man to do was for him to obey a rational interpretation of Scripture, and if this did not provide sufficient light, to reason from the standpoint of expediency concerning what course of action would bring the most happiness to the most people. Paley thus made reason and revelation to work hand in hand in the determining of the will of God. Since the work of Immanuel Kant, morality has become in many circles the by-product of logic. This trend developed until the liberalism of the early part of the twentieth century said that man is essentially good because he is rational, and his rationality is divine; so divine that all reason-defying paradoxes of the Christian faith, may be smoothly by-passed as not belonging to the essence of Christianity. Man was made the center and measure of all things, and it was held that the most distinctive emphasis in the teaching of Jesus was His emphasis upon the essential dignity of human personality which said that that which elevates and enriches human personality is right, and that which debases and destroys human personality is wrong. The current neo-orthodoxy is calling us away from the blind impasse of optimistic liberalism with its deified man and humanized god to a new realism about man and to a God who sits regnant above the human scene, a God who, to use Kierkegaard's phrase, possesses an "infinite qualitative difference." To neo-orthodoxy God is "ganz anders", wholly different and, therefore, cannot be defined in a rational formula. Niebuhr sees the pre-eminent sin of the twentieth century as man's pretension to have achieved a degree of knowledge which is beyond the limit of finite life. This he calls the "ideological taint" in which all human knowledge is involved and which is always something more than mere human ignorance. It is always partly an effort to hide that ignorance by pretension. Niebuhr concludes that: "No pattern of human rea- 1 Fosdick, Harry Emerson. A Guide to Understanding the Bible, p. 70. son but only the will of God can be the principle of the form and order to which human life must be conformed.\textsuperscript{1} Furthermore, Niebuhr refuses to give any further definition of good itself because to do so would be to subject himself to his own condemnation of the sin of making absolutes of the human thought patterns of a particular time and place. For Barth God is altogether incomprehensible to us. Our insight can never penetrate beyond his revelation nor can it fully grasp that revelation. Consequently the ultimate meaning of right and wrong for us can never mean anything more than the sovereign incomprehensible approval of God. Logic cannot serve to disentangle us from the relativistic ethical situation, for logic itself is dependent upon ethics. For Barth, knowledge is: "that confirmation of human acquaintance with an object whereby its trueness becomes a determining factor in the existence of the man who knows."\textsuperscript{1} If knowledge is real for us, it must change us in our very existence, therefore, logic, which is the science of knowledge, is dependent upon ethics: It is only when the logical question about things as they are is merged in the ethical question, about \textsuperscript{1} \textit{The Doctrine of the Word of God}, p. 226. things as they might be, about the good, that it becomes ultimate.\textsuperscript{1} Barth continues: Absolutely nothing, therefore, can come of submitting the question about the good to the question about the truth in the logical sense—as if it were not the very ground upon which the latter substantiates itself.\textsuperscript{2} Throughout the ethics of neo-orthodoxy there runs the common strain of scepticism, agnosticism and irrationalism which utterly contradicts the optimism and rationalism of Paley. For all the tremendous contribution of these writers, we at times yearn for the sweet reasonableness of the eighteenth century. Perhaps this is an evidence of the truth in Niebuhr's contention that man is not willing to own his finiteness. However, we would still believe that it is a grave error to belittle the rational factor in morality, for morality must be able to commend itself to man who is not solely intellect but who, nevertheless, has an intellect. Furthermore, if man's reason is as corrupt as these writers suppose, it is difficult to see how it can be used to prove that this is the case. \textsuperscript{1} \textit{The Word of God and the Word of Man}, p. 137. \textsuperscript{2} \textit{The Problem of Ethics Today}, p. 137. Perhaps Barth's refusal to assign to reason its proper place accounts for the fact that while his thought has affected the church most profoundly, it has done so only from a negative standpoint; and has not challenged the thought outside the church at all. The reason for this is very apparent. Barth has been more interested in establishing the absolute uniqueness of the Christian theology and ethic than in propagating it throughout the world. He has repudiated Christian apologetics but has also rejected the philosophical defense of the Christian world view as not only baseless or unconvincing, but as out of harmony with the Christian doctrine of revelation. He emphatically repudiates the belief that Christian truth is grounded in human reason. Emil Brunner joins Barth in this conclusion as he says that: "Revealed knowledge is poles apart from rational knowledge. These two forms of knowledge are as far from each other as heaven is from earth."¹ Niebuhr does not go as far in the revolt against reason as does Barth and Brunner, and yet his use of paradox often appears to ¹ Revelation and Reason, p. 16. be a convenient device for admitting the futility of attempting a rational explanation of man's moral predicament. For example, along with his neo-Calvinistic conception of sin Niebuhr places an equally confusing conception of human freedom in the following: Man is thus in the position of being unable to comprehend himself in his full stature of freedom without a principle of comprehension which is beyond his comprehension...the ultimate proof of the freedom of the human spirit is its own recognition that its will is not free to choose between good and evil.... Man is most free in the discovery that he is not free...Man's self-love and self-centeredness is inevitable, but not in such a way as to fit into the category of natural necessity. It is within and by his freedom that man sins. The final paradox is that the discovery of the inevitability of sin is man's highest assertion of freedom. This theology of paradox impresses the unsophisticated intellect as a gratuitous mystification; a twisted jungle of inconsistent opinions that get us nowhere. Instead of letting their yea be yea and their nay be nay, the neo-orthodox theologians feel that they must prove man's depravity by demonstrating to him his inability to wade through a maze of theological jargon. It would, of course, be grossly unfair to accuse these men of deliberately propagating theological irrationalism. On the contrary, even Karl 1 The Nature and Destiny of Man, Vol. I, pp. 125, 258, 260, 263. Barth declares that "Christian faith is not irrational, not anti-rational, not super-rational, but rational in the proper sense." At the same time he repudiates altogether the idea of a rational justification of faith. Perhaps this confusion has arisen over a misunderstanding of the nature and range of reason, and is due to the maintenance of the traditional dualism of faith and reason which refuses to see the broader view which instead of sharply differentiating between reason and the other essential phases of mental life sees reason as pervading life as a whole. The view of the function of reason which has become increasingly common in philosophical and theological circles since the time of Kant, Hegel and Schleiermacher is that it is practical as well as theoretical; it is concerned with values and norms as well as bare facts; and it has to do with ultimate reality as well as phenomena. In this sense reason is operative in religion, morality, and art as truly as it is in mathematics and natural science. "It is, then, proper to speak of a religious reason, a moral reason, and an aesthetic reason as well as a theoretical reason." 1 Dogmatics in Outline, p. 23. 2 Knudson, A.C. Basic Issues in Christian Thought, p. 43 In contrast with this modern revolt against the use of reason in theology and ethics stands Paley's firm confidence in man as a creature capable of receiving the revelation of God as it is recorded in the Bible. Furthermore, Paley never doubted that God, in making man a responsible being had endowed him with the ability to decide for himself what the will of God for his own life is. That is to say, Paley believed in a revelation from God which man is capable of receiving. He did not, like Barth, think of revelation as an experience in which man is neutral and inactive. Barth believes that even man's religious impulse, his reaching out after God has no independent spiritual significance. It "differs from the need of sleep only in degree."¹ Faith, however, is different from the religious impulse. Says Barth it is a divine response within us to a miraculous divine revelation and stands apart from all natural human activities. Paley believed that morality is best promoted through clear definitions of right and wrong. This does not mean that he was not aware of the infinite complexity of the moral demands made upon life. It simply means that Paley knew that man's conduct can only be properly judged in the light of his ability and that unless one can ¹ Römerbrief, p. 219. discern for himself the highest good, which for him was equated with the will of God, he could not be held morally responsible for doing the good. Instead of the "ganz anders" of Barth, for Paley God was the "wholly good" who wished the happiness of his creation. So thoroughly convinced was he of God's goodness that he felt himself justified in identifying anything which contributes most to the happiness of the most people with the will of God. Naive as this may be to the sophisticated mind, it has far more practical value for the ethics of the common man than does the baffling system growing out of the theology of paradox. The paralyzing agnosticism and pessimism of the neo-orthodox ethic is seen in Niebuhr's contention that it is characteristic of high religion that, "it excludes no action, not even the best, from the feeling of guilt."¹ In his doctrine of the sinfulness of even our best efforts Niebuhr cuts the nerve of morality. Perhaps it is wholesome to insist that the goal is never attained, but to say that our best is still only a guilty compromise is to encourage even the best man to ask, "What's the use?" In connection with our best possible action there may be a normal and rational feeling of imperfection but not of true guilt. Instead of seeing only the bad in man Paley saw the good and recognized that in ¹ An Interpretation of Christian Ethics, p. 82. formulating a doctrine of man it must be remembered that there is a problem of good as well as a problem of evil. The theological foundation of the ethics of Barth, Brunner and Niebuhr is fundamentally weak in that it stresses the fall of man more than the incarnation, the cross of victory, the open tomb of triumph and the extension of the incarnation through the union of the believer with Christ. This is not to deny the reality of the fall, for as Pascal said, "this is the mystery without which man becomes a mystery to himself." Yet rather than holding before man the dark Old Testament picture of the fall as the primary item in theology, it appears to be closer to the New Testament to insist that the incarnation itself argues the fact of man's capacity to receive God. This is not to deny that the incarnation is a miracle of divine grace nor that the incarnation was a unique event in human history. But it is to say that the incarnation posed no problem for God that was not cared for in man's creation when God made man in His own image with the capacity for fellowship with God. Furthermore, by insisting upon the primacy of the incarnation, the cross and the resurrection the scene is changed from the darkness of the fall to the portrayal of the fact that God by His grace has now entered the field on the side of man and that in the conquering cross and the open tomb He offers man victory over sin and death in a fellowship of faith that overcomes the world. As the Apostle put it: "As in Adam all die even so in Christ shall all be made alive."¹ Barth would call this theology of the divine immanence the arch heresy of the modern church and in so doing maintains the traditional view which Borden P. Bowne characterizes as an emphasis on "the undivineness of the natural and the un-naturalness of the divine."² In certain passages Brunner also seems to stand against any emphasis upon the immanence of God. For example, he writes: Believing God is the antithesis of experiencing God....our faith stands opposed to all experience just as it stands opposed to death and the Devil.³ Christian faith for this school is so superempirical and superhuman that Barth tells us that we do not know when we have it; we can only "believe that we believe."⁴ --- ¹ I Corinthians 15:22. ² The Immanence of God, Preface. ³ Die Mystik und das Wort, p. 388. ⁴ Römerbrief, p. 128. Over against this one finds the following statement by John Oman most refreshing: The present vehement insistence that religion should only be a crisis of decision about our dealings with a transcendent God, . . . and that all concern with human affairs is a descent from the empyrean into the quagmires and mists of time, seems to be a mere denial . . . that "the earth is the Lord's and the fulness thereof. . . ."¹ The school of neo-orthodoxy has turned from understanding to cling to mystery. They reject knowledge to trust in a misguided concept of faith. Our Lord did not identify faith with a blind plunge into the dark but with the courage to venture according to the understanding. His question was "Why are ye so fearful? How is that ye have no faith?" Modern dualism makes faith the opposite of understanding—an irrational assertion of something that we cannot understand. Professor John Macmurray calls this interpretation, "Moral cowardice masquerading as faith,"²..."a will to believe in mystery which is in itself the manifestation of fear."³ --- ¹ Concerning the Ministry, pp. 104, 105. ² The Clue to History, p. 99. ³ Ibid., p. 100. The final concern of this chapter will be with the relationship of eschatology to ethics. As often stated throughout this thesis Paley's chief concern was with providing a theological sanction for utilitarianism. He believed that the only way of bringing egoistic conduct into harmony with utilitarianism was by emphasizing that God has ordained the general happiness as the rule of human conduct and that He will reward or punish in another life those who obey or disobey that rule. A review of the sermons of Paley will discredit the claim that he was crudely materialistic in his concept of eternity. He writes, "Heaven is infinitely greater than mere compensation, which natural religion might lead us to expect."¹ In another sermon he states: I can easily believe that many of the opinions and notions we now erroneously entertain, especially concerning the place, condition, nature, occupation, and happiness of departed saints, may hereafter appear to us as wild, as odd, as unlikely and ill founded, as our childish fancies appear to us now.² Furthermore, Paley does not make the fear of eternal punishment the basis of morality. He expressly states that, "There ¹ Sermons and Tracts, Sermon XXII, p. 201. ² Ibid., Sermon XXV, p. 335. is great uncertainty in what is done under the impression of some fright...when the thoughts are...disturbed and the spirit is sunk and overwhelmed."1 Again he states, "Salvation comprehends much more than being saved from punishment...."2 The recognition that the resurrection of Christ was in the forefront of Apostolic preaching and the belief in its practical corollary that all men shall rise again from the dead, "they that have done good to the resurrection of life and they that have done evil to the resurrection of damnation" led Paley to conclude with the Apostles that we should ask since this is true, what manner of men ought we to be? He observes that whenever a set speech of the Apostles' at a new place is recorded, that is, whenever he first opens the great message of Christianity to strangers, the great argument is the resurrection. For example, Paul declares that he delivered unto the Corinthians "first of all" the message of the death and resurrection of Jesus (1 Corinthians 15:1ff.). Based upon the resurrection of Jesus is His promise of victory over death to the believer. Concerning the promise of Christ of the resurrection (John 4:28-29), Paley writes: --- 1Ibid., Sermon X, p. 236. 2Ibid., Sermon XXVI, p. 248. These words are so important that if Jesus Christ had never delivered any other, if he had come into the world and pronounced only this simple declaration, and proved the truth and certainty of it by the miracles which he wrought, he would have left enough to have guided his followers to everlasting happiness; he would have done more towards making mankind virtuous and happy than all the teachers and all the wisdom that ever appeared upon the earth had done before him. Paley believed in the enduring value of human personality and realized that to take away the eternal hope would mean that there would be no Gospel left. "If we in this life only have hope in Christ we are of all men most miserable." (I Corinthians 15:19.) There is also a strong eschatological sanction running throughout the ethics of neo-orthodoxy. However, it is a sanction related to what has come to be called "axiological eschatology", the belief that every generation is directly under God's judgment (as opposed to "teleological eschatology", which puts the judgment at some future time.) Niebuhr, however, goes beyond the present scene and looks for the fulfilment of our hopes in a kingdom beyond this world. In his discussion of the resurrection of the body, Niebuhr --- 1 Sermons and Tracts, Sermon XXIX, pp. 28-29. takes it as a symbol which means that the body and the natural basis of life are integral components of the personality, not something to be repudiated in the interests of a purely spiritual life. When, therefore, life reaches its goal, these too will have a share in its fulfillment. He does not, however, expect the resuscitation of the body which has been committed to the grave. Niebuhr insists that while we must take the symbols seriously, we should not take them literally. He firmly holds to the belief that our unfulfilled hopes may be realized in eternity, in a Kingdom of God which lies beyond our success and failure, into which the one is built and the other is redeemed. He sees the end of history in the final judgment and our final satisfaction in the city which hath foundations where beyond these voices there is peace.$^1$ Karl Barth sees the resurrection of Jesus as the completion of the victory of God. He warns: We must not transmute the resurrection into a spiritual event. We must listen to it and let it tell us the story how there was an empty grave, that new life beyond death did become visible... To those who know this, the break between the old world and the new is proclaimed. They have still a tiny stretch to run, till it becomes visible that God in Jesus Christ has accomplished all for them.$^2$ --- 1. An Interpretation of Christian Ethics, p. 247. 2. Dogmatics in Outline, p. 123. Barth does not agree with Paley's conception of God as a judge. He sees that the Biblical meaning of the judge is not primarily one who rewards some and punishes others. Rather is he the one who creates order and restores what has been destroyed. At the same time Barth insists that these visions of the last judgment are not meaningless. They signify that God knows everything that exists and happens. As we ponder this we may well be terrified, for "that which is not of God's grace and right cannot exist."¹ There can be no question but that the doctrine of life beyond the grave is a basic part of the Christian religion. In describing this Professor A.E. Taylor writes: For the Israelite until long after the return from the captivity, as for the ordinary Greek, all the real interests of men, including even the interest of worshipping Yahweh and keeping His laws, belong to this side of the 'great divide.' What lies on the other side is an existence so dreary and meaningless that a man does best to keep it at arm's length so long as he may, and to avert his thoughts from it. In the great tradition of Christianity...the point of view is completely reversed. Practical emphasis falls always not on this life, but on that which awaits man on the other side of bodily death. It is there that we are told to look for our real home and our true destiny.² ¹ Dogmatics in Outline, p. 123. ² Ibid., p. 135. Since this is the characteristic view of a Christian, we are not to condemn Paley for emphasizing it so strongly in his ethic. Of course, there is the familiar humanistic objection that the Christian belief in a future life has unduly diverted attention from this life. Moralists in general object to basing ethics in this world on rewards in another world on the grounds that this tends to lead us to the attitude that this life is unimportant. The pragmatist says the future is too nebulous: what we need is to get busy and make a better world in the present. As Paley presented his sanction it is quite obvious that an infinite amount of happiness in eternity could outweigh any amount of earthly misery. There is no doubt but that an extreme transcendentalism which defines religion solely in terms of another life reflects the inability to believe in God and this world at the same time and is therefore spiritually deficient. However, the belief in a future life of bliss does not logically imply that the values of this life are to be neglected, and in practice it is the exception rather than the rule that it leads to the neglect of this world. In fact, Paley emphatically insists that while keeping his eye on a more abiding city the Christian must at the same time earnestly intercede for the peace and welfare of this world.\textsuperscript{1} Moreover, it must be recognized that some of the world's most ardent toilers have been those who were sustained by a blessed hope. For example, the writer has the privilege of teaching in a theological seminary where many students are trained for foreign mission service. After ten years of intensive preparation in medical and theological training, one of the most capable and charming young ladies ever to enroll in our seminary was appointed by our foreign mission board to go to Joinkrama, Nigeria in the delta region of British West Africa which has been called "the back side of nowhere." There life is unspeakably hard. The rain falls three hundred and sixty days out of three hundred and sixty-five. There is no electricity, no running water in the houses. The river is the place where the natives bury their dead, wash their clothes, bathe, and then drink the water. One out of every seven has leprosy. Smallpox is rampant. The mission appointee, Miss Aletha Fuller, gave this testimony: "There is only one doctor in all the area of Joinkrama and when I get there I will be the only nurse." Then she asked, "Do I think of it as a sacrifice? No, for I want to give the best years of my life in service for Christ and to God whose grace \textsuperscript{1} \textit{Sermons}, Sermon XI, p. 142. has always and shall always be sufficient." Then she said in closing: "If I may see a host of black faces up yonder it will be worth all the effort." In reply to the critic who says that a belief in a future life makes one indifferent toward service in this life it might be noted that the man who says this life is all, therefore, make the most of it, usually means make the most of it for yourself. One of the most amazing achievements of the Apostolic era is the fact that in this period when the sense of impending catastrophe was so strong and everything in the world seemed temporary and so much emphasis was being placed upon the thought that only things which would survive the passing of heaven and earth were worthy of attention, that the church should produce anything like a code of social ethics. We should expect that in the face of the expectation of the end of the world with the immediate return of the Lord the Apostles would be utterly indifferent to human affairs. But notice the emphasis in the First Epistle of Peter: But the end of all things is at hand; be ye therefore sober, and watch unto prayer. And above all things have fervent charity among yourselves, for charity shall cover the multitude of sins. Use hospitality one to another without grudging. As every man hath received the gift, even so minister the same one to another, as good stewards of the manifold grace of God. (I Peter 4:7-10.) Paul writes: "The night is far spent, the day is at hand. Let us therefore, cast off the works of darkness and let us put on the armour of light." (Romans 13:12) "The world", writes John, "is passing away, and the world's desire, but he who does God's will abides forever." (I John 2:17.) Now we do not criticize Paley for his belief in life after death nor for his belief in rewards and punishments after death, nor can we say that working for rewards in eternity is not a part of the Gospel. In answer to the objection that this is a very selfish view we might answer that surely our Lord knew what He was talking about when he said: "Lay up for yourselves treasures in Heaven where neither moth nor rust doth corrupt and where thieves do not break through nor steal,"¹ and also: "for great is your reward in Heaven."² It is conceivable, however, that if this motive should become too dominant it might destroy the very essence of the Christian ¹ Matthew 6:20. ² Matthew 5:12b. faith. For example, if one is simply interested in the prudential earning of rewards, he might soon forget that he is a debtor to divine grace. If he seeks what God has to give more than God Himself, he becomes an idol worshipper. The witch of Alexandria, walking the streets armed with a pitcher of water and a flaming torch, and crying "Would that I could quench hell with this water and burn heaven with this torch, so that men would love God for Himself alone," was mistress of a white magic, not of a black art.$^1$ The Christian is explicitly taught to seek not his own glory here or hereafter but the glory of God. The doctrines of heaven and hell are facts that belong to the Christian religion, but this does not mean that they are essentially related to the highest motives for ethics. Rewards and punishments may belong to a certain stage of moral development in a child. Perhaps it would help in the forming of good habits, but as the child matures morally, the need for rewards and punishments should disappear. Our Lord had something to say against those who followed Him for the loaves and fishes. Instead of thinking in terms of external rewards perhaps it would be better to regard eternal life as John regarded it as the present gift of God to the man who through $^1$ Buttrick, G.A. The Parables of Jesus, p. 163. faith enters the fellowship of Christ. This means that what the man of faith shall be in eternity he is rapidly becoming today. John construes the goal of the Christian life in terms of character. "Beloved it doth not yet appear what we shall be, but we know that when he shall appear we shall be like him; for we shall see him as he is. And every man that hath this hope in him purifieth himself, even as he is pure." (I John 3:2-3). A remarkable silence surrounds the Apostles description of the believer's final destiny. It is somewhat akin to the wholesome agnosticism of Richard Baxter who wrote: Our knowledge of that life is small. The eye of faith is dim, But 'tis enough that Christ knows all And I shall be with him. Moreover, if a man could be scientifically certain of rewards for his good deeds in eternity would this not cut the nerve of faith by removing the element of venture therefrom? Furthermore, it is declared that the motive behind Christian service is to be love. Only one new commandment did Jesus give His disciples, namely, this: "A new commandment give I unto you that ye love one another as I have loved you." (John 13:34.) It would thus appear that Paley might have improved his ethic by making it more distinctly Christian. Instead of making heaven and hell pure appeals to a selfish, self-regard he might have viewed them as the normal result of a life that delights in or refuses the fellowship of God here. The Christian is to find delight in the fellowship of his Lord more than in anything his Lord might give him: He and I in that bright homeland One great joy will share. Mine to be forever with him, His that I am there. Paley might also have emphasized that religion brings blessedness in our present life and that the only assurance that a man may have that he will enjoy the fellowship of God beyond the grave is the assurance that he shares that fellowship now. This fellowship is a fellowship of love which the Apostle Paul found so rich and deathless here that he could declare, "I am persuaded that neither death nor life...shall be able to separate us from the love of God which is in Christ Jesus, our Lord. (Romans 8:38-39). As John Oman puts it: We should not be reconciled to God because we believe in another life, but we should believe in another life because, being reconciled to God, we find a meaning in life which is ever expanding and a purpose death cannot end...Thus we rightly and religiously believe in another life, because we are serving the purpose of a love for which this life is too small. 1 Grace and Personality, p. 306. Oman reasons further that the ethical meaning of love is to treat every man as an end in himself and to respect him for what he ought to become. Then he concludes: Yet how are we to continue to say what he ought to be, when, if the whole story end at the grave, we know it is what he never will be?¹ Oman concludes his argument for eternal life by holding that although the moral order is valid though it is not fully realized in time, yet it does not follow that it would still be valid even if it were never to be realized. He contends that instead of a castle in the air, morality is either life's ultimate meaning or it is nothing. The ultimate meaning of this moral order is love, but it would be absurd to say that a moral order with love at its heart could finally issue in death. He sees love as self-abnegation, not self-regard. This, however, does not mean that love is self-destruction or self-disregard. It is, therefore, only because love is itself our best self-realization, that it has the right to avert attention from ourselves to the fulfillment of its own behests; and it can be so only if the world is so constituted that deliverance from self means to be saved. He concludes: ¹ Ibid., p. 310. This gives a due place to self-love, while delivering us from a utilitarian morality, which makes self-love the measure and end of morals. Utilitarianism says, conscience is only self-love wisely judging what really pleases us; a true morality says, right self-love is only conscience wholly determined by God's will of love, which serves what is worthy of God's image in us and blesses us because it is in accord with the true order in which God has placed us.$^1$ Let us conclude by saying that while he gave imperfect expression to the central features of his ethic, still do we believe that Paley did well in insisting that religion is the foundation of morals, that belief in revelation is essential to Christian ethics, that reason must have its part in the apprehension of revelation and that the eschatological goal must be included in any complete statement of Christian ethics. 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DOMESTIC ENERGY USERS' NETWORK Members Convenor Age Concern NZ Child Poverty Action Group Grey Power Federation Public Health Association Rural Women NZ: Molly Melhuish, 04-568-4873, 027- 230-5911,[email protected] Secretary: Sarah Free, 04 383 7337 [email protected] To the Electricity Authority: Cross-submission: Transmission Pricing Methodology Molly Melhuish, March 28 2013 SUMMARY: Industry submissions on transmission pricing methodology say the proposal would create new costs and risks that will drive consumer prices higher. DEUN concludes that the proposal is just the latest and most extreme of a series of regulatory initiatives that are supporting price rises and squeezing out small independent innovative competitors to the main retailer-generators. This cross-submission refers to about 55 submissions that were made to the Authority's consultation document on Transmission Pricing Methodology, together with about a dozen reports by expert economists. Transpower's covering letter amounts to an excellent summary of views from the wide spectrum of industry interests (few consumers made submissions). Transmission pricing is challenging and has a history of causing dispute. As a sector, we have allowed this challenge to divert resources and attention away from issues that have greater potential to improve outcomes for consumers. This was our experience in the 1990s when Transpower governed transmission pricing. The Authority has put forward a novel approach to trying to resolve this challenge. While the proposal is intellectually seductive, using a complex modelling approach to setting transmission pricing will only increase disputes. The old arguments over allocating the costs of past investments will continue, and will be cloaked in more complexity. We should not be trying to change something that is not broken. Rather than a radical departure from current arrangements, Transpower's view is that we should be holding to a stable, simple and durable approach to transmission pricing so that we can collectively direct our focus and resources at matters more likely to deliver benefits. A possible exception is the HVDC, where there are acknowledged inefficiencies in the current methodology. Elements of the Authority's approach may provide a mechanism to improve that and this should be tested through industry consultation against other options. The quotations below exemplify a number of themes relevant to domestic consumer interests. Section numbers have been retained where they occur, to help readers who seek the context of the quotations in the original submissions. Table of Acronyms, p. 12. 1. QUOTES FROM SUBMISSIONS The Authority's proposal is not shown to be in the long term benefit of consumers. The Authority's proposal would lead to higher prices for consumers. The proposal would reduce reliability of supply by removing much of the incentive to control peak loads on the system. \| Mighty River Power \| The proposal to levy the charge across peak injections will incentivise generators to avoid meeting peak demand and reduce investment in peaking generation plant. That, of course, has obvious implications for security and reliability of supply for end use consumers, being important statutory objectives. \| \|---\|---\| \| Price Waterhouse coopers, for 22 small lines companies \| EDB annual information disclosures suggest that EDBs shed about 5% of their load on average at the GXP peak, which is a sizable reduction in peak load. Distributors are investing heavily in "avoided distribution" initiatives to reduce peak demand. Investments in new smart-meter based load- management equipment are also being made, which will facilitate greater participation in load control. Community interests via ownership are a factor that incentivises distributors to respond to these price signals to reduce transmission charges for consumers. \| The proposal would reduce economic efficiency of electricity supply – - through generators behaving less efficiently; - through the grid being under-utilised; - through reduced use of load control; - through least-cost generation not dispatched; Mighty River Power Generators will also look to alter wholesale market offers to avoid transmission charges, which may mean least cost generation is not dispatched. - through inefficiently allocating charges to reflect sunk costs a practice. In fact, the US Court of Appeal decision that is discussed appears to caution against the practice. The proposal would make both small retailers and small distributed generators less competitive - - and undermine the value of their investments. Innovation would be suppressed by the loss of small retailers and generators, and the reluctance of retailers to signal benefits of demand reduction. It will not be possible to hedge against some of the risks, and this could lead to financial distress. The proposal would create wealth transfers that give perverse incentives to generators, reducing security, reliability, efficiency, and asset values. Asset values are already at risk, both in transmission and generation, because of the surplus of capacity in both. Transpower assets that are clearly uneconomic should be written down. Regulatory uncertainty has been greatly increased by such a radical proposed change \| Mighty River Power \| 3.11 We believe the regulatory uncertainty created by the Authority's proposal not only has implications for the costs of future generation developments (increasing risk premiums and hurdle rates), but also for the cost of capital for other infrastructure sectors. Such uncertainty will negatively influence the overall perception that international capital providers have of the regulatory approach to infrastructure assets in New Zealand. \| \|---\|---\| \| Trustpower \| Investors in long-term infrastructure face investment risk from changes to rules. If the decisions of the regulator are not rational, predictable and aligned with overseas practice, this will raise the cost of capital and bias investments away from capital-intensive assets with long economic lives. \| \| NZ Council Infrastructure development \| we strongly oppose any attempt by the Authority to apply charges to past investment which has already been consulted and agreed upon. . . . Any retrospective changes to the methodology not only carry implications for investor certainty and wider Government policy at a time when this is most critical, but do not meet basic societal expectations of fairness. \| The cost-benefit analysis of the proposal was extensively criticised. DEUN concludes from the above summary of industry commentary relevant to consumers that the Authority's proposal cannot achieve a standard of consensus appropriate for a change in the Code. Therefore the status quo transmission pricing methodology should be retained at present. In the longer term, fundamental issues must be addressed as to the meaning of "long term benefit of consumers". 2. BACKGROUND TO THIS PROPOSAL Transmission pricing methodology has been the subject of intense lobbying for a decade or more. South Island generators now pay about $150 million per year in transmission charges. To counter lobbying on this and other matters, the Electricity Authority was set up to be independent of ministerial interference. A consistent theme of the submissions is that the proposal will probably increase lobbying rather than reducing it. Unlike its predecessor the Electricity Commission, the Authority interpreted its statutory objective as ignoring wealth transfers, so as to allow profit maximising even when that meant continuing consumer price rises. This is explained in the Interpretation of the Statutory Objective: A.7 … the Authority's decisions will be consistent with expanding the 'size of the economic pie', whereas if direct wealth transfers are included (but indirect wealth effects excluded) then regulatory initiatives can be adopted even when they 'shrink the pie'. DEUN has consistently challenged the legitimacy of the Authority's interpretation, and this is reinforced by a legal opinion summarised in the Vector submission: consumers is a consumer benefits tests rather than a public benefits test. The Authority is required to consult on every proposal. Its Advisory Group charter requires them to strive to reach consensus. 3.7. If an Advisory Group is unable to reach consensus on a matter under consideration within an agreed timeframe, the Authority may request the Advisory Group to conclude its deliberations and report the differing views to the Board for consideration. The Board expects feedback from the Advisory Group which addresses the views of the minority as well as those of the majority. This is a very big ask, for businesses whose fiduciary duty to their shareholders conflicts with their regulatory responsibilities as set out in the Authority's foundation documents. When successive technical advisory groups failed to reach consensus on transmission pricing methodology, the Authority proposed an entirely new approach based on formal principles. It first consulted on its proposed framework - a hierarchy of transmission charging elements beginning with market and market-like charges, and ending with administered residual charges. DEUN'S submission on the framework supported the idea of a first-principles approach – - indeed we have widely circulated a very different first-principles approach to regulation of a competitive electricity market, by Hugh Outhred in 1992 1 . It is the highly innovative application of the Authority's framework - in particular the use of the SPD model that calculates half-hourly spot prices to also calculate up to half the transmission charge – that is seen by industry as creating unacceptable costs and risks. 3. WHERE TO FROM HERE? Below is a sample of recommendations for further action from a selection of the submissions. DEUN and a few others recommend a return to the status quo transmission pricing methodology, saying typically that any change would be met by still more lobbying, the cost of which would far outweigh the benefit. Note that Meridian and Comalco, and also NZX, support the proposal. 1 Outhred, H.R., "Principles of a Market-Based Electricity Industry and Possible Steps Toward Implementation in Australia". International Conference on Advances in Power System Control, Operation and Management, Hong Kong, 7-10 December 1993 Meridian \| TrustPower \| TrustPower considers the Authority’s proposal would meet neither the efficiency criteria nor the objective of promoting competition. We consider the long-term interests of consumers are unlikely to be served by a certain and immediate increase in energy prices, offset against a very uncertain and speculative benefit of improved scrutiny of future transmission investments. TrustPower therefore urges the Authority to review both the fundamental basis for its proposal, and the elements contained therein. \| \|---\|---\| \| Transpower \| We should not be trying to change something that is not broken. Rather than a radical departure from current arrangements, Transpower's view is that we should be holding to a stable, simple and durable approach to transmission pricing so that we can collectively direct our focus and resources at matters more likely to deliver benefits. A possible exception is the HVDC, where there are acknowledged inefficiencies in the current methodology. Elements of the Authority's approach may provide a mechanism to improve that and this should be tested through industry consultation against other options. \| \| Price Waterhouse Coopers \| If the EA is to proceed with the proposal then we support the ENA‟s calls for an industry working group to be established to investigate a limited scope of alternative options as well as provide practical guidance on implementation issues \| \| Vector \| The most effective way for the Authority to ensure the TPM is durable and stable is simply not to (further) review it. The Authority could adopt the philosophy of Spanish explorer Hernando Cortez who burnt his boats as an effective way of preventing any thought of change in course. Vector recommends the Authority adopt a clear and high threshold/burden of proof for major regulatory changes such as to the TPM to help ensure its regulatory decisions are stable and durable. \| \| Electricity Networks Association \| ENA does not consider the centre-piece of the proposal, namely the SPD- based charging method, is fit for purpose in its proposed form. What is now needed is a project and a process that builds on this and the previous TPM work and distils from it a small number of practical and well grounded proposals for the IC charge. \| \| Unison \| Unison submits that, in-line with the Code Amendment Principle 2, the Authority has provided insufficient evidence to substantiate that the proposal will address a “clearly identified efficiency gain or market or regulatory failure”. Accordingly, Unison does not support any deviation from the status quo recovery of transmission charges \| \| NZ Council Infrastructure Development \| \| We recommend the establishment of a collaborative industry initiative led by the Authority to identify the optimum allocation of transmission costs, taking into consideration investment certainty, perceptions of equity, transition costs and long term economic efficiency. \| \|---\|---\|---\| \| Pacific Aluminium (Comalco) \| \| Pacific Aluminium supports the proposal in so far as it seeks to improve the current transmission pricing methodology, albeit with some modifications which we set out in this submission. \| \| MEUG \| The industry needs clarity on what might happen next. Following on from the views on the proposal and process above, MEUG suggest the Authority: a) Does not issue the guidelines in the proposal to Transpower; b) Consults on possible next steps for reviewing the TPM taking into account that: . . . the level of grid investment for the next decade is likely to be modest at best. iv) There are many other opportunities for improvement in the market that are competing with resources that might otherwise be used on a review of TPM. \| \| From the domestic consumer's perspective, incremental change will only perpetuate the faults of the present consultative processes. The only change that could give us confidence that the pricing process would be in the long-term benefit of consumers would be to revoke the Authority's interpretation of its statutory objective, and direct the regulator to recognise electricity as an essential service, as is done in all other countries. Regulation will never achieve stability until "long term benefit of consumers" means exactly what it says. 4. CONCLUSION The TPM proposal is just the latest in a series of regulatory initiatives that have created new risks and costs to market participants: Customer Compensation Scheme, Scarcity Pricing, Stress Tests, What's My Number … These together with a host of consultations are taxing the regulatory capability of Electricity Market Participants, especially the smaller competitors in the retail, distribution, and distributed generation sectors. These new direct costs, and new risk premiums, are driving continuing price increases to domestic consumers. We were always told that our power prices had to rise to meet the long run marginal cost of new generation and lines networks. Now that these assets have been built there is surplus capacity in both power stations and lines. We expected prices to fall, as they would in any competitive market affected by a glut of supply. Instead, prices rose again this year. Companies complain about the increasing burden of regulatory compliance - yet the five large generator-retailers are all able to pass the new compliance costs on to their consumers. Switching retailers only steps a consumer from one price escalator to another, while the escalators themselves deliver continuing profits to the companies, and dividends and taxes to the government. As flat demand is suppressing the commercial returns from new power stations, the only way to maintain the dividends expected by shareholders is to raise prices. This would be helped by any exit from the market of independent businesses that could compete on the basis of price and service. The transmission pricing proposal significantly increases the complexity of regulation. The regulator's ability to create new costs and risks, and thus support further price rises, seems to have no upper bound whatsoever. Domestic consumers have no confidence in the pricing process. Domestic consumers had no representatives in the advisory groups that led to the transmission pricing methodology proposal. Their nominee for the Wholesale Advisory Group was rejected. Consensus that excludes domestic consumers is no consensus at all. The only way to achieve long-term regulatory stability would be to return to treating electricity as an essential service, in line with international practice. Transmission Pricing Methodology and all other Code Amendments must actually promote the long term benefit of consumers, not support the building of new power stations and lines in the hope of "expanding the size of the economic pie". 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www.jyoungpharm.org Seminal Oxidative Stress Biochemistry in Male Infertile Patients–An Overview Radha Vembu 1 , G Ragesh 2, *, Uma Maheshwara Reddy 3 , Anjalakshi Chandrasekar 4 1 Porur, Chennai, Tamil Nadu, INDIA. Department of Reproductive Medicine, Sri Ramachandra Medical College and Hospital, Institute of Higher Education and Research (DU), 2 Porur, Chennai, Tamil Nadu, INDIA. Department of Pharmacy Practice, Sri Ramachandra Faculty of Pharmacy, Sri Ramachandra Institute of Higher Education and Research (DU), 3 Porur, Chennai, Tamil Nadu, INDIA. Department of Pharmacology, Sri Ramachandra Faculty of Pharmacy, Sri Ramachandra Institute of Higher Education and Research (DU), 4Department of Obstetrics and Gynaecology, AC Hospital, Ayanavaram, Chennai, Tamil Nadu, INDIA. ABSTRACT The problem of infertility affects approximately 15 percent of couples in their reproductive years. Even after frequent, unprotected sexual activities for a year, or more, they are not able to conceive. Male infertility is a factor in more than a third of these couples. The cause of male infertility is low sperm production, abnormal sperm function, or blockages preventing sperm from being delivered. Infertility in men can be caused by illnesses, injuries, chronic health problems, lifestyle choices, and other factors. When you can't conceive a child, it can be stressful, and frustrating, but there are several treatments available for male infertility. Sometimes signs and symptoms can be attributed to underlying problems. This includes an inherited disorder, hormonal imbalance, dilated veins around the testes, or a condition that prevents the passage of sperm. Male infertility is predominantly caused by varicocele, infection, abnormal ejaculation, antibodies that attack sperm, tumours, undescended testicles, hormonal imbalance, defects in the tubes that carry sperm, chromosome abnormalities, sexual dysfunction, and celiac disease. The oxidative biochemistry in sperm are addressed in this study. Keywords: Reactive oxygen species, Sperm quality, Free radical, Non-systematic review, Intrinsic, and extrinsic factors. INTRODUCTION Infertility is a global health issue. It is estimated that worldwide, 60 to 80 million couples struggle with infertility each year, of which approximately 15–20 million live in India alone. 1,2 According to a large study of more than 8,500 couples by the World Health Organisation (WHO), the male factor contributes to infertility by 51.2%. Infertility is defined as failure to conceive after one year of regular unprotected intercourse with the same partner. As per WHO study, the incidence of men infertility in India is about 10–15%. Male infertility contributes to 50% of the total infertile cases. 3 Over 90% of male infertility complaints are due to low sperm counts, low sperm quality, or both. Sperm count below 20 million per millilitre is called Oligospermia (low sperm count). Sperm motility problems and irregular sperm morphology are examples of poor sperm quality. Seminal analysis is a critical component in making a definite diagnosis of male infertility. This DOI: 10.5530/097515050334 Copyright Information : Copyright Author (s) 2023 Distributed under Creative Commons CC-BY 4.0 Publishing Partner : EManuscript Tech. [www.emanuscript.in] Journal of Young Pharmacists,Vol 15, Issue 1, Jan-Mar, 2023 test evaluates sperm count, motility, and morphology. Reactive oxygen species (ROS), which are defined as oxygen ions, free radicals, and peroxides, induce infertility in two ways. First, ROS damage the sperm membrane, reducing motility, and the ability of the sperm to fuse with the egg. Second, the ROS directly degrade the sperm deoxyribonucleic acid (DNA), jeopardising the embryo's family genomic impact. Despite the widespread link between poor sperm quality and oxidative stress, men are rarely checked for or treated for this problem. Instead, 'mechanical' therapies such as in vitro fertilisation–intracytoplasmic sperm injection (IVF–ICSI), or intrauterine insemination (IUI) are typically provided. This is less than ideal because neither IVF– ICSI nor IUI therapy directly alleviates oxidative damage to sperm DNA. Furthermore, immediate treatment of oxidative stress may enable spontaneous conception, preserving expensive medical resources. 4–6 The prevalence for male infertility is exactly not known, but estimates suggest that the 10–year comparison of sperm quality, and quantity (2000–2001 to 2010–2011), the percentage of semen ejaculation, which is considered less than normal (below 4 ml), increased from 34% to 65% and the most suitable ejaculation volume (more than 4 ml) went down from 15% to 3%. The study from India 7 stating that, declining 37 Correspondence: Mr. G Ragesh Department of Pharmacy Practice, Sri Ramachandra Faculty of Pharmacy, Sri Ramachandra Institute of Higher Education and Research (DU), Porur, Chennai, Tamil Nadu, INDIA. Email id: [email protected] Received: 27-04-2022 ; Revised: 23-08-2022 ; Accepted: 10-09-2022. semen quality among 7,770 South Indian infertile men and it was confirmed that 30.31 % of decline in sperm count, sperm morphology, and motility was reduced by 51.25 % and 22.92 % respectively. But, these confirmations are failing to project the reason for drop in percentage of semen ejaculation, and quality in infertile men. A similar study in Calcutta, 8 included the semen analysis of 3,729 men presenting with infertility problems in two distinct decades between 1981–1985 and 2000–2006. The result confirmed that, decline in the sperm motility parameters, and seminal volume in the present decade. A decline was seen only in sperm motility with increasing age in both decades. The exact reason for the decline in semen quality is still not clear. There are few studies from western countries have demonstrated a link in relation to the oxidative stress in semen and which is created by leukocytes in seminal plasma. In India, there is no studies which demonstrates the association between the oxidative stress, and semen quality in the larger population. This be a huge lacuna or unfilled space in male infertility research in India and also in other countries. MATERIALS AND METHODS It's a non-systematic narrative review conducted with the aim to describe the specific problem or cause for decline in sperm quality. The literature search was done on Cochrane Library, Springer, Elsevier titles, Scopus, and Science Direct. The boolean search strategy were adopted and the keywords used were oxidative stress, male infertility, sperm quality, spermatozoa, ROS, intrinsic, and extrinsic factors. Additionally, specific words were also searched. Abstracts in the research paper were assessed, based that the full–text publications were saved, and reviewed. Case study, case review, books, and monographs were excluded. Editorials, letter to communication, and opinions were included in this review work. Several governments, organisation, and associated websites were examined for relevant information. No segregation of the collected literatures like national and international works. The literature was not categorised according to a certain time period. The majority of the literature was arranged in a simple narrative format. Oxidative Stress Biochemistry Males may have two primary ROS spawning systems: A putative nicotinamide adenine dinucleotide phosphate oxidase (NADH) at the sperm membrane and in mitochondrial level low sperm diphorase (mitochondrial NADH–dependent oxidoreductase) reaction. 9 Mitochondria is the major energy source for sperms and ROS are principally produced in bovine sperm by dead spermatozoa via an aromatic amino acid oxidase–catalysed process. 10 The two primary sources of ROS in sperm are leukocytes and immature spermatozoa. 11 Excessive ROS generation by leukocytes, particularly neutrophils, and macrophages, has been linked to sperm abnormalities. 12 The absence of endogenous defence mechanisms and second 38 exposure of gametes and embryos to various manipulation techniques as well as environment that can contribute to the formation of oxidative stress are two important dynamics supporting ROS build up in vitro. 13 ROS levels may occasionally fluctuate within a fertile person, but they have no effect on sperm concentration, or motility. This might be because healthy people have enough antioxidant defence systems. Variations in the ROS levels might be caused by transitory subclinical infection and transient spermatogenesis defects such as cytoplasm retention or the periodic presence of aberrant spermatozoa in sperm. 14 ROS formation is a normal biological process in the body, but an imbalance between ROS and antioxidant scavenging activity is detrimental to sperm quality, and results in male infertility. 15 ROS produced by spermatozoa have an important role in normal physiological activities such as sperm capacitation, acrosome response, fertilizations ability maintenance, and stability of the mitochondrial capsule in the mid-piece in bovine. 16 Controlled ROS production may act as signalling molecules (second messengers) in a variety of cell types; they are crucial mediators of sperm activities. Evidence has been revealed that superoxide anion (•O 2 ), in particular, is essential for the late stages of embryo development, such as two germ cell layers, and the egg cylinder. 17 Although there is a substantial negative association between ROS and IVF rate, 18 regulated formation of ROS has been demonstrated to be needed for the development of capacitation and hyper activation, 19 the two sperm processes required for fertilizations. In vivo physiological quantities of ROS are implicated in sperm membrane fluidity, fertilising ability, and acrosome response. 20 Maintaining an appropriate ROS level is thus critical for proper sperm functioning. ROS have a negative impact on the sperm plasma membrane, DNA, and physiological processes, lowering the quality of spermatozoa. The axosome and related thick fibres of the mid-piece within sperm are coated by mitochondria, which create energy from adenosine triphosphate (ATP) depleted intracellular reserves. 21 Elevated ROS inhibits movement and fertilisation capability. Further, leukocytospermia is a condition where there's an upsurge in leukocyte infiltration in the sperm, which is related with a large number of defective sperm morphology, reduced sperm motility, and increased DNA damage. When compared to males without varicocele, individuals with varicocele had higher seminal lipid peroxidation. 22 A balance of ROS and antioxidants is required for optimum sperm activity and fertilisation. ROS causes spermatozoa to produce cyclic adenosine monophosphate (cAMP), which inhibits tyrosine phosphatase, resulting in tyrosine phosphorylation. H 2 O 2 specifically induces capacitation via tyrosine phosphorylation, which initiates a cell signalling cascade. Capacitation needs ROS but can also be blocked by catalase (CAT). 23 High amounts of ROS have been shown to stimulate the acrosome reaction, whereas catalase, or superoxide dismutase (SOD) suppresses the acrosome response 3. ROS–modulated tyrosine phosphorylation appears to be the mechanism causing the acrosome response. 24 ROS Journal of Young Pharmacists,Vol 15, Issue 1, Jan-Mar, 2023 can potentially have an impact on motility. When spermatozoa are exposed to ROS, hyperactivation occurs. 25 The flagellum becomes hyper activated as a result of ROS–mediated tyrosine phosphorylation. Tyrosine phosphorylation also promotes sperm–oocyte fusion by increasing sperm membrane binding to the zona pellucida ZP–3 protein, promoting sperm–oocyte fusion. 19 DISCUSSION Though generation of ROS is essential for reproductive function as they act as signalling molecule, oxidative stress (OS) is found to have some detrimental effects over fertility. Redox Imbalance occurs as a result of increased ROS along with decreased antioxidant defence, leading to reduced sperm motility, and sperm DNA damage. There are large amounts of unsaturated fatty acids in the cell membrane of spermatozoa making it more susceptible to the deleterious effects of ROS promoting the peroxidation of lipids which causes increased in intracellular oxidative burden. 26–29 Also, ROS induces cyclic adenosine monophosphate (cAMP) in spermatozoa that inhibits tyrosine phosphatase leading to tyrosine phosphorylation. 23 In particular, H 2 O 2 stimulates capacitation via tyrosine phosphorylation triggering a cell signalling cascade. Capacitation not only requires ROS, but it can be inhibited by catalase (CAT). It has been described that high levels of ROS promote the acrosome reaction, whereas the presence of CAT, or superoxide dismutase (SOD) inhibits the acrosome reaction. The mechanism of inducing the acrosome reaction appears to be ROS–modulated tyrosine phosphorylation. Motility can also be affected by ROS. Hyper activation is increased when spermatozoa are exposed to ROS. 25 ROS–mediated tyrosine phosphorylation in the flagellum causes hyper activation. 19 Tyrosine phosphorylation also augments sperm membrane binding to the zona pellucida ZP–3 protein, promoting sperm–oocyte fusion. ATP is formed as a result of oxidative phosphorylation that is enzymatically controlled within mitochondria. As a result of this enzymatic reduction, free radicals are formed due to unpaired electrons. The addition of one electron to dioxygen leads to the formation of primary ROS is called the superoxide anion radical which is then converted to secondary ROS directly/indirectly as hydroxyl/ peroxyl/hydrogen peroxide (the same applies to nitrogen derivative). 5,30,31 Semen analysis has revealed that leukocytes with neutral predominance and sperm are the two principal sources of free radical's producers. 12 There is a positive correlation between seminal leukocyte number and ROS production. 32,33 Inverse correlations between sperm maturation (teratozoospermia) and NADPH production. 34,24 A study in animal models shows that expose to pesticides and phthalates will not only induce oxidative stress also can lead to the disruption of hypothalamic– pituitary gonadal axis leading to inhibition of gametogenesis and steroidogenesis. 35,36 Smoking can trigger the recruitment of leukocytes to the genital tract leading to the presence of elevated Journal of Young Pharmacists,Vol 15, Issue 1, Jan-Mar, 2023 ROS in the seminal fluid. 37,38 Consumption of excess alcohol promotes ROS production and interferes with body's antioxidant defence mechanism. Acetaldehyde is a by–product of ethanol interacts with proteins and lipids leading to ROS production and a decrease in antioxidants. 39 CONCLUSION The reactive oxygen species in sperm can cause DNA damage while also interfering with physiological processes and high ROS levels limit the sperm motility. Males with high levels of ROS who receive assisted reproductive technology therapy are at a higher risk of fertilisation failure or failing to produce healthy babies. Oxidative stress in semen is a serious health issue was not studied clearly to understand its mechanism and incidence. The outcome of future therapeutic trials with antioxidants target and individuals with moderate to severe sperm oxidative stress may aid the physicians to increase the fertility potential in male infertile patients. CONFLICT OF INTEREST The authors declare no conflict of interest. REFERENCES 1. De Kretser DM. Male infertility. 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Infections in the male genital tract and reactive oxygen species. Hum Reprod Update. 1999;5(5):399-420. doi: 10.1093/humupd/5.5.399, PMID 10582780. 32. Sharma RK, Pasqualotto AE, Nelson DR, Thomas AJ, Agarwal A. Relationship between seminal white blood cell counts and oxidative stress in men treated at an infertility clinic. J Androl. 2001;22(4):575-83. PMID 11451354. 33. Whittington K, Harrison SC, Williams KM, Day JL, McLaughlin EA, Hull MG, et al. Reactive oxygen species (ROS) production and the outcome of diagnostic tests of sperm function. Int J Androl. 1999;22(4):236-42. doi: 10.1046/j.1365-2605.1999.001 74.x, PMID 10442296. 34. Gomez E, Buckingham DW, James J. Development of an image analysis system to monitor the retention of residual cytoplasm by human spermatozoa: Correlation with biochemical markers of the cytoplasmic space, oxidative stress, and sperm function. American society of Andrology; 1996. 35. Queiroz EK, Waissmann W. Occupational exposure and effects on the male reproductive system. Cad Saude Publica. 2006;22(3):485-93. doi: 10.1590/ s0102-311x2006000300003, PMID 16583092. 36. Saleh RA, Agarwal A, Kandirali E, Sharma RK, Thomas AJ, Nada EA, et al. Leukocytospermia is associated with increased reactive oxygen species production by human spermatozoa. Fertil Steril. 2002;78(6):1215-24. doi: 10.1016/ s0015-0282(02)04237-1, PMID 12477515. 37. Sharma R, Harlev A, Agarwal A, Esteves SC. Cigarette smoking and semen quality: A new meta-analysis examining the effect of the 2010 World Health Organization Laboratory Methods for the Examination of Human Semen. Eur Urol. 2016;70(4):635-45. doi: 10.1016/j.eururo.2016.04.010, PMID 27113031. 27. Sanocka-Maciejewska D, Ciupińska M, Kurpisz M. Bacterial infection and semen quality. J Reprod Immunol. 2005;67(1-2):51-6. doi: 10.1016/j.jri.2005.06.003, PMID 16112738. 38. Agarwal A, Virk G, Ong C, Du Plessis SS. Effect of oxidative stress on male reproduction. World J Mens Health. 2014;32(1):1-17. doi: 10.5534/wjmh.2014.32.1.1, PMID 24872947. Cite this article: Vembu R, Ragesh G, Reddy UM, Chandrasekar A. Seminal Oxidative Stress Biochemistry in Male Infertile Patients–An Overview. J Young Pharm. 2023;15(1):37-40. 40 Journal of Young Pharmacists,Vol 15, Issue 1, Jan-Mar, 2023	<urn:uuid:9820926a-9733-4ab6-b919-fe73ad77f16b>	CC-MAIN-2023-06	https://cdn.emanuscript.tech/jyp/v15/i1/JYoungPharm-15-1-37.pdf	2023-01-27T20:44:29+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-06/subset=warc/part-00202-b5ddf469-bf28-43c4-9c36-5b5ccc3b2bf1.c000.gz.parquet	172,584,851	6,130	eng_Latn	eng_Latn	0.791205	eng_Latn	0.948519	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 5066, 11358, 18375, 23547 ]
Gender Role Transformation in the Oil Mining Industry in Kenya: a Case Study of Lokichar, Turkana Caroline Khasoha Shikuku PHD Student Prof Edward Mburugu Dr Salim Nungari Dr Joseph Kabiru Department of Sociology and Social Work University of Nairobi, Nairobi Kenya Abstract The mining industry presents opportunities for economic development not only in Kenya but the entire world. There is hence need to involve women more to realize this development. The purpose of this paper is to analyze gender role transformation in the oil mining industry in Kenya. This paper is anchored on three theories; gender relations theory as the anchor theory, conflict theory and diffusion innovation theory. Desk review and various studies done in Kenya on Extractive Industry will inform this paper while anchoring on a recent study by the author of this paper. The study findings show that gender roles have been transformed as a result of oil mining. Additionally, oil mining has influenced changes in livelihoods for women but locals not aware of laws and policies dealing with gender in the oil mining industry. The paper recommends good will in implementation of gender policies and Affirmative Action. Keywords: Gender, Role, Affirmative Action, Mining Industry, Extractive Industry, Gender Relations, Gender Role Transformation. 1. Introduction 1.1 Background Africa has 30 percent of the world‟s mineral reserves including huge reserves of oil and gas (Berman et al., 2017). This presents Africa with a window of opportunity to exploit these resources in development and improving livelihoods. Gender roles are a critical component in measuring how advanced a community is in respect to economic changes. Policies on controlling mining industries have been associated with changes in gender gap that is extremely unbalanced in oil mining industry. Countries including South Africa, India, Nigeria and other known mining countries have enacted Acts of Parliaments, laws or frameworks to guide and control the process of mining in terms of embracing gender balance (Nadeau et al., 2013). Through focusing on improving livelihoods, gender inclusion becomes part of the overall process of empowering the local community. Improving processes such as record keeping and increased production relations knowledge together with process as well as tracking the change process by using gender-based data collection and also analysis will serve as the first measure towards establishing pro-poor aspects that will succeed at the grassroots level (Bahn, 2013). With the education system trenched into the patriarchal attitude, women were deliberately streamed into other occupations not termed as "technical" thus limiting those who could work on mines. Rules in mining industry and other highly physical occupations discouraged women workers from participating, including conditions like women having to be married to get considered, or being discharged of their duties based on divorces or pregnancies. Mpagi et al (2017) on a study on the artisanal gold mining in Uganda noted that both women and men were active participants and were involved in the core activity of drilling and digging for gold. The study alludes to the dwindling line on gender roles in mining as men and women engage in mining without factoring in gender perceptions. The case of women participating in mining describes their changing perception and willingness to adopt any work done by the other gender. The same view is shared by Bashwira et al (2014) who points out that women have adopted the traditionally-perceived men‟s roles in mining than men have adopted the women‟s perceived roles. Extensive researches have depicted how women have been aggressive in their involvement in the mining sector with the main goal of challenging the hegemonic notion that mining is meant for men (Eveline & Booth 2002; Mercier & Gier 2006; Lahiri-Dutt & Robinson 2008; Lahiri-Dutt & Macintyre, 2006; Moretti, 2006). Male dominance in mining industry across the world is adequately documented. For example, in the Ugandan Coltan mines, women represent less than 5 percent of the labour force (Ngendanzi, 2012).In Kenya, the Mining Bill 2014 lacks gendered aspects while the Kenyan Constitution, 2010, Article 27 (8) supports for Affirmative Action, which requires the government to legislate and take other measures in ensuring that at least one-third of the appointed or elected members are from either gender. Consistent to this view is Dessler (2005), who opine that Affirmative Action entails measures established to eliminate the existing impacts of discrimination in the past; Affirmative Action in the oil mining sector is a move that will ensure more women get to participate and are adequately represented in the oil mining sector. With the coming of oil industries, Turkanas now engage in alternative livelihood for example working in oil industries, business, farming and charcoal burning. Remittances from family and relatives, merry go rounds and currently Saving and Credit Co-Operative (SACCOs) are playing a critical role in their lives. Additionally, due to loss of cattle, men and women are currently involved in diversified income generating activities and are moving from the traditional role of pastoralism (Barrow and Mogaka, 2007). 1.1 Problem Statement According to Mususi (2015) about 30% of the African population is poor, most of who are women. The mining activities are thus mostly done by poor persons among them women. The mining sector is a key pillar of wealth among countries world over, and women make a tremendous contribution of the world‟s work force. Mining has empowered women by giving them an opportunity to improve their livelihoods through enterprise development even though various studies have reported that this sector is male dominated (Dlamini, 2018). Turkana County of Northern Kenya is predominantly a pastoralist community. Power structures in the community are predominantly patriarchal. Land related disputes and negotiations for example are dealt with by a council of elders comprised of men only. Women and youth are seldom involved in these meetings (Omolo, 2014). Additionally, the Mining Bill (2014) acknowledges use of natural resources for national development; it fails to highlight its gendered effects particularly on resource extraction and management of natural resources. As it stands, women are disadvantaged since they have been excluded from this value chain and their involvement in benefiting from available opportunities is limited (Ndzwayiba, 2017). The discovery of oil in Turkana County, therefore, calls for a better understanding of the challenges impacting each gender. It has been noted that in the mining industry men are more advantaged due to the nature of work and compensation while costs, such as social disruption, and environmental degradation mainly affect women (Omia, 2015; Ndzwayiba, 2017; and Dlamini, 2018). It is therefore important to evaluate the transformation in gender roles in the lens of the challenges/ changes that oil mining has impacted on this sector. Kenya has enacted legislations geared toward ensuring gender equality including the third-gender rule that requires either gender to have at least a third of their representation in employment and other government positions. Oil mining is a current development venture in Kenya and it has been under researched more so aspects of gender. It is in the light of this that this paper evaluates changes in gender roles and livelihood brought about by oil mining and also assesses ways of empowering men and women in gender role transformation in the same sector. There is a gap in existing knowledge that is necessary for informed decision making to ensure gender participation and empowerment in the process of oil mining in the region by understanding the challenges that negate this process. This has also been elevated by limited research that are gendered in the oil mining in Kenya. The study provides scientific findings thus contributing to evidence on how oil mining can lead to social and economic empowerment including poverty reduction.Thus, the general objective of this paper is to analyze the transformation of gender roles in the oil mining industry. Specifically the paper sought to; i. Assess challenges caused by oil mining affecting transformation of gender roles ii. Evaluate changes in gender roles for men and women. iii. Evaluate changes of livelihood for both genders due to oil mining. iv. Assess ways of empowering men and women in gender role transformation in the oil mining sector. 2.Theoretical and Literature Review 2.1 Literature Review 2.1.1 Livelihoods and Gender in Oil Mining Several studies have shown that oil mining leads to changes in the livelihoods for the locals and other players. Oil mining is associated with increased opportunities for businesses and employment as well as challenges to the local community. Lahiri-Dutt and Mahy (2016) pointed that studies of mining and gender have consistently focused on the negative effects of mining on women‟s wellbeing and livelihoods, beginning with the lack of employment opportunities in mining for women and their being forced to find employment in socially humiliating and unprotected positions such as prostitution. These studies often describe the loss of agricultural land and livelihood resources for those people living at subsistence level, and the decreased ability of women to work on remaining land due to male absenteeism. Detrimental environmental effects often fall more heavily on women with few documented detrimental effects on men (Mayes & Pini, 2010). Increase in employment opportunities and access to trainings was associated with changed livelihoods of the locals in the mining towns. Those who have experienced positive changes due to oil mining were those with higher education, better economic power and adequate experiencing (Knobblock, 2013). It was further felt that specific to women, there were increased economic opportunities, more jobs in the mines, and businesses including catering. The youthful women were particularly associated with the increased changes to their economic status. 2.1.2 General Changes in Gender Roles Due To Mining Activities Studies have positively identified changes in gender roles as influenced by mining activities. Lahiri-Dutt and Mahy (2015) identified the area of Sangatta in Indonesia to have been sparsely populated as well as "completely undeveloped zone." The area was only accessible through the river, using boats and or helicopters for the oil exploring companies. The area changed significantly with large number of migrants coming to the area searching for employment, signifying the start of urbanization. Mining projects led to expansion of the area into a district with government offices and thus attracting many development projects. The oil mining firm keeps the villagers in anticipation of great developments like road projects, health facilities, and other development related projects (Buxton, 2012). Many studies have identified several economic effects like increasing cost of living associated with changes in prices of goods (Bryant & Jaworski, 2012). Purchasing power of the locals can either be boosted if they increase the amount of income they earn from the mining activities. Similarly, if the locals are not employed to earn some income, then they will have a reduced purchasing power that will translate to a high cost of living. Women are mostly the custodians of the old customs as experienced in most cultures and when rapid transformations such as the ones caused by mining are likely to put women at a disadvantage (Nygren, 2013). Men were associated with the most economic gains from mining activities but were also subjected to most of the negative social outcomes including squandering the cash in drugs, alcohol, prostitution, and adding other girlfriends or wives (Stenbacka, 2011). 2.1.3 Oil Mining and Gender Equality Some of the suggested economic empowerent programs for women include bettering women to compete efficiently in the new market economy, and also ensuring the market has structures that suits women (Knobblock, 2013). Studies have also identified resitance by the local communities where tools like gender sensitization seminars and workshops become part of the solution to such challenges (Laplonge, 2014). Trainings using "gender role plays" and also engaging women in leadership and strong communication ability were also quoted to be key tools of creasting sensitization among the community in the form of embracing both women and men working in mines. The image presented by mining sector is that of "masculinity" where women feel sidelined. Mining companies should work to provide a competitive ground where women feel appreciated and embraced as other gender of men (Ely & Meyerson, 2010). An image of gender tolerance should also be presented in the mining companies where women are embraced in many departments including exploitation, management and logistics. The role women play at the family and community level should be recognized at the company level through appreciating them with maternity leaves and periods for handling children and family matters. Subjects or courses like Gender and Development (GAD) need to be introduced into company level management where both men and women are taught the approaches of mainstraiming gender in oil mining activities (Knobblock, 2013). In-company gender audits were also recommended to expose how women were performing in relation to men within the mining roles. Such audits need to be followed by a set of gender equity and diversity policies and principles while including all other orgaization staff. Community development initiatives, interventions and projects are often run by mining engineers with less awareness of social, cultural and economic welfare issues than project management (Jakobsson & King, 2011). Kenya has legislations that include the one third gender rule as instilled in the Constitution of Kenya 2010. It allows not more than one gender to hold more than two-thirds of gender roles in an employment positions in both public and private sector. Since the Kenyan status of oil mining has not been in existence for long, actions towards promoting gender divesity through campaigns involving gender empowerments in mining sector partly target issues like safety, security of female workers, and sexual harassment that are commonly targeted to women in strenous jobs like mining. Other aspect of focus of gender mainstreaming in the Kenyan mining sector is the genderbased attitudes and the patriarchial culture/societal beliefs that hinder women from participating in oil mining sector (Ahmad & Lahiri-Dutt, 2007). 2.2Theoretical Review Three theories have informed this study; the gender relations theory, conflict theory and diffusions of innovation theory.The gender relations theory predicts that all activities carried out in the society must conform to the social roles and interactions of men and women (Johansson, & Ringblom, 2017). The theory holds that a role is the expected behaviour that is connected to a certain status. Roles must be in line with social norms, shared rules that guide the behaviour of people in various circumstances. Social norms define the responsibilities and freedoms; it enables people to have a certain level of flexibility in their roles. As compared to the male counterparts, for instance, females are likely to occupy status within and beyond their homes which are associated with little power, less prestige and limited pay or no pay (Dominelli, 2017). Proponents of gender relations theory, such as Messerschmidt et al. (2018) argue that women have been relegated to performing reproductive and undervalued roles within the households. This theory explains the observed labor patterns between males and females in the society and its association of these roles with social status/ privileges in the society while alluding to cultural transmission of roles across generations more so in the mining sector in Lokichar. The gender relations theory has been important in explaining the societal norms and practices toward gender division of labor in the society (Booth & Erskine, 2016). According to Burrell (2017) the conflict theory assumes that the fact that the society always competes over scarce resources affects social relationships. Among the areas where conflict theory has been applicable, include explanation of oppression of women by men, and non-economic conflicts in regions such as Turkana County. The theory was useful in explaining the cultural conflicts between men and women as influenced by culture. According to Evans and Aceves (2016) diffusion entails communicating innovations to the members of social system through given channels over years. Based on the definition, it is evident that the main components of diffusion of innovation include time, communication channels, social systems, and innovation. This theory fits well to the Turkana context as the coming of oil industry has brought many changes in the lives of the people of Turkana who were initially pastoralists. With industrialization and urbanization this has somehow led to changes in gender roles and livelihood. All the three theories help us in understanding gender transformation in the oil mining sector in Lokichar. More so how gender roles have been transformed by oil mining and cultural values in this area. 2.3Hypothesis Testing The following hypothesis were tested; i. H0: Gender roles have not been transformed as a result of oil mining in Lokichar. H1: Gender roles have been transformed as a result of oil mining in Lokichar. ii. H0: Oil mining has not influenced change in livelihood for women and men in Lokichar community. H1: Oil mining has influenced change of livelihood for women and men in Lokichar community. 3.Research Methodology This paper capitalizes on the findings from other studies and from a recent study by the authors which adopted the use of a descriptive survey design. Lokichar was selected as the study site because of the Oil mining activity in the area. The active labour force aged between 15 years to 64 years was the target population. Lokichar has an approximate population of 2,000 people (Turkana County Government, 2016). Out of the population, the Active labour force is approximated at 67.5% which is 1350 people, comprising both males and females.The calculation to find out the sample size for this paper assumed a confidence level of 95%. The paper adopted the following formula to compute the size of the sample (Creative Research Systems, 2012). The Z-score (Z) used was 1.96, with a margin of error (e) of 0.05. Distribution (P) was 0.5, and the population size represented by N. Given the Population size (N) as 1350, the following was calculated; n=299.05 which is rounded off to the nearest whole number and thus; n= 300 The sample size for the study was 300 people. The study adopted Systematic random sampling in selecting the main respondents for interviewing in the survey. A listing of the population of 1350 people was prepared from which men and women were separated. Random numbers were generated for this listing, that is, from 1 to 1350. Considering systematic random sampling, Sampling fraction = Actual Sample Size /Total Population. This implied that the sampling fraction for this study was 300/1350= 0.22. From this, every third person (homestead) from the starting point was interviewed beginning with the first person. This was done until the whole population was interviewed. Purposive sampling was used for focus group discussion and key informant interviews. Six key informant interviews were conducted and one focus group comprising of young men, young women elderly men and elderly women was done. With this regard Questionnaires, Key informant interviews and Focus Group Discussion guides were adopted as tools. Hypotheses were also tested. Chi Square test was used and Tabulation and charts were presented to show a comparison between the various categories. 4. Research Findings 4.1Challenges/ Changes caused by oil mining affecting transformation of gender roles The study established that the male respondents suggested the challenge of loss of land at 57.1% and health hazards at 42.9% as the major challenges caused by oil mining while their female counterparts were at 55.3% and 25.5 % respectively. Other changes mentioned by both gender were displacement at 35.7%, Loss of livelihood at 1.3%, degradation of environment at 21.3, limited access to food and water at 10.7%, changes in livelihood at 7% and immorality and sexual transmitted diseases at 5.3%. Looking at the differences across gender the study established that the females mentioned challenges like immorality/ sexually transmitted diseases (8.5%), limited access to water. Food and firewood ((17%) and loss of livelihood (2.1%) which was not mentioned by their male counterparts. Similarly, other studies note that in the mining industry men are more advantaged due to the nature of work and compensation while costs, such as social disruption, and environmental degradation mainly affect women (Omia, 2015; Ndzwayiba, 2017; and Dlamini, 2018). Some of the positive changes identified include availability of jobs, increasing incomes and changing livelihoods for the locals. Some other changes witnessed included development of the local areas where schools, dispensaries and roads. One of the respondents indicated that, "There were job creations especially for the VLOs (village liaison officers) and CLOs (community liaison officers). There was also physical development where there was construction of infrastructure like tarmacking of roads, building of two classrooms (one at Muharal and another at Lomokmal schools), one dispensary, and one dormitory at Uhuru High School." In terms of education, there were bursaries given for secondary schools and colleges thus improving education levels of the locals. It was also noted that a Memorandum of Understanding (MoU) was signed to allow the workers to return to work from the one-month strike with 5% going to the community. The assistant chief who has served as the acting chief since 2007, stated, "The locals want the 5% was to be channeled to development, with 1% for personal consumption, 1% for bursary for education, 1% for health of the people, 1% for the health of livestock and 1% for food production." Some of the negative changes identified by the key informants include increased prostitution as the administrator of the healthcare facility indicated, "There was increase in prostitution (sex working)." There are also increased displacements of people (local community) with the loss being lack of grazing lands. There has been an increased rate of insecurity with attacks and potential risks on the tracks transporting oil. On the psychological front, majority of the locals who have lost jobs have slipped into depression owing to the fact that they lost their livelihoods, and the money they got did not get into good use but was wasted since they believed that the jobs would continue for their lifetime (Elmhirst, Siscawati, Basnett, & Ekowati, 2017). The area chief supported by the facility administrator and two other key informants pointed out that there was increase in crimes as well as diseases. A study by Macdonald (2003) on the impacts of oil production on the local people points out that there are mixed results since there are positive and negative effects. For instance, there were instances of environmental contamination with oil spills, destruction of oil during excavation, and pollution through production of poisonous gases and other substances. The findings further relate to the diffusion for innovation theory where upon the discovery of oil, sociocultural factors had to change to feature the influx of immigrants. 4.2 Changes in gender roles for men and women brought by oil mining 4.2.1 Traditional Roles for Men The study identified traditional roles for both men and women of the Lokichar community before the entry of Oil Company in the area. Traditional roles of men included herding the cattle, sheep and goats, protecting the homes, hunting and providing for their families. The FGD members also quoted that men were tasked with helping women where necessary to ensure their wives were not overwhelmed with the work they were doing. Men were also tasked with maintaining boundaries and ensuring there is peace and harmony within the community boundaries. Men also played important roles in community including circulating information gathered from the elders. It was a duty of the senior men to go and have elders‟ meeting to collect outside information then share it with their wives to help in making decisions. One of the respondents stated that, "Through having information, men were able to give directions and solutions to the issues affecting the community including the decisions to move animals to newer grazing lands." 4.2.2 Changed Roles for Men The study also sought to seek the whether there were changed roles for men. It is expected that with new opportunities, people were likely to change and adapt new roles, making changes to the traditional roles perceived to be for men and for women. A key informant mentioned that upon joining the oil mining company, the males were engaged as engineers, machine operators, drivers, plumbers, field workers, storekeepers, security officers, cleaners and cooks. Others were engaged as supervisorors and managers. Some chose to do businesses that served those in the mining company. Men have been traditionally associated with manual work that needs to be accorded extra energy that make women feel sidelined. The focus group discussion (FGD) pointed out that men had changed to performing women-perceived chores including washing clothes, cooking and serving foods to the employees at Tullow Oil Company. It was observed that technical jobs required educated people and thus irrespective of gender, qualified persons were likely to be taken. 4.2.3 Traditional Roles for Women Turkana women were charged with taking care of the homes and the children, doing household chores such as cleaning and cooking, collecting firewood, fetching water among other roles. Women in Turkana were traditionally tasked with making animals‟ kraals. They also needed to dig seasonal water boreholes. Maintaining cleanliness at the homesteads was also women‟s affair. A key informant argued that women were managers of the households as they implemented the household works. Women also delegate works to other members of the family. They also do construct houses and repair them. 4.2.4 Changed Roles for Women The study conducted by the authors further sought to establish whether there were changed roles for Women. One of the key informants indicated that, "Women are driving big lorries but I have not yet witnessed any woman operating machines" in support of the fact that women have started doing the traditionally men chores. Women have also secured security jobs working as security guards manning gates of the oil mines, a work description traditionally spared for men. There were new jobs that women also joined making the change from the traditionally strict community to adapt to new changes. One of the respondents indicated, "There are women who are community liaison officer (CLO‟s) who create awareness to the community on what to be done." Women also started doing businesses where traditionally they were home attenders, indicating a shift from the traditionalism to modernism. One key informant indicated that women were able to participate in land negotiations but they were voiceless since the decisions were made somewhere else before being imposed on them. One of the respondents in FGD indicated, "Women can do what men do especially for single women who are forced to, due to their nature of needs, take care of their children and meet basic needs. Men do work together with women in order to achieve common goal of life. It was also observed that, "People working with Tullow Oil Company assume all roles regardless of gender as long as they have important skills of assuming the assigned roles." One of the challenges identified for women getting employment at the oil mining companies was the compromising needs for sexual favors by the senior people in management. All the six key informants indicated, "One is required to give some favors before they are employed especially women exchange sexual favors for jobs." Another one mentioned that it was not just sexual favors but also money. The findings on changes on gender roles support a study by Scanlan (2015), women were disadvantaged in getting employment especially in marginalized communities where illiteracy levels were high. 4.2.5 Hypothesis Testing on Transformation of Gender Roles The hypothesis for testing whether there was any gender transformation among the locals was tested using the chisquare tests to establish the p-value of the results. The summary of the results are shown on table 4.26; H0: Gender roles have not been transformed as a result of oil mining in Lokichar. H1: Gender roles have been transformed as a result of oil mining in Lokichar. To ascertain the association above, a chi-square test was done to determine whether the respondents involvement in oil mining had transformed their gender roles. The tests were carried out with a confidence level of 95% (α=0.05). The summary of the cross tabulations and the chi-square are depicted on tables 4.1; Table 4.1 Cross Tabulation and Chi Square Test Results for Traditional transformation of Gender Roles vs Gender \| Have traditional gender roles changed \| Respondent gender \| \| \| \| Total \| \| \|---\|---\|---\|---\|---\|---\|---\| \| \| Male \| \| Female \| \| \| \| \| \| N \| % \| N \| % \| N \| % \| \| Yes \| 52 \| 47.3 \| 109 \| 61.9 \| 161 \| 56.3 \| \| No \| 58 \| 52.7 \| 67 \| 38.1 \| 125 \| 43.7 \| \| Totals \| 110 \| 100.0 \| 176 \| 100.0 \| 286 \| 100.0 \| \| Chi- Square Tests \| \| \| \| \| \| \| \| Statistics \| \| Value \| \| Df \| Asymp. Sig. (2-sided) \| \| \| Pearson Chi-Square \| \| 5.845a \| \| 1 \| 0.016 \| \| A chi-square of 5.845 with degree of freedom = 1 and the p-value (Asymp. Sig) = 0.016 was obtained. The difference between the two values shows that gender roles have been transformed as a result of mining. Therefore, we rejected the null hypothesis and accepted the alternative hypothesis that Gender roles have been transformed as a result of oil mining in Lokichar. More women are predicted to take up more skilled and semi-skilled roles in the oil company just like the male companions. The findings of the study were similar to the findings by Fatusin, Afolabi, and Adetula, (2010) who pointed out that community where a large-scale project was based, and where locals were able to participate, there was a significant change on the livelihood of the locals. The community was likely to benefit from large scale projects due to investments in the local areas, benefits from the corporate social responsibilities (CSRs) from the companies, and businesses growing and increasing income for the locals. 4.3 Changes of livelihood for both genders due to oil mining Through the traditional lens of culturally-accepted roles, it is expected that the gender roles would remain the same, with women sticking to their traditional roles and men the same. With the introduction of oil mining companies in Lokichar, there are likelihood of having changes in the traditional livelihoods into new livelihoods as dictated by the availability of new job opportunities. It was observed that over 47.3% (for males) and 61.9% (for females) of the respondents believed that oil mining in Lokichar has changed the traditional livelihoods of men while 43.7% disagreed. The percentage can be related to increased income among the locals, performing businesses, and increased employment opportunities among the locals. From the key informants and the FGD, it was observed that men got more opportunities than women thus having some significant changes in their livelihoods. One of the key informant indicated that men had a tendency to share increased income with other women, with options like marrying another woman, or having concubines. The theory of gender relations as well as conflict theory were applicable with the changes in the traditional roles. The new roles adopted by men were likely to cause a conflict between different genders. 4.3.1 Changes in Traditional Livelihoods for Women Traditional livelihoods have been associated with the traditional roles for women that centered on managing the homesteads and ensuring the family had enough to eat. It was observed that the respondents associated women with less economic activities in the traditional arrangement of gender roles. The study found that around 47.3% (males) and 67.5% (females) of the respondents had experienced changes on traditional livelihoods for women. Women were seen to have experienced changes in their livelihoods due to the changes in their incomes and the employment opportunities arising from the oil mining in Lokichar. The changes in livelihoods were as a result of women being employed into the oil mining firms where they were able to substitute their incomes from the traditional roles. The FGD members also suggested that women had experienced changes in their livelihoods since they were able to get employed and earn from the proceeds from the oil mining. The findings also relate to the diffusion of innovations theory where women changed their traditional roles to new roles where women were seen doing menial work. 4.3.2 Hypothesis testing for change in livelihoods Chi- square test was used to test if the change in the livelihoods for men and women brought about by oil mining, the null and alternative hypotheses are shown here; H0: Oil mining has not influenced change in livelihood for women and men in Lokichar community. H1: Oil mining has influenced change of livelihood for women and men in Lokichar community. The information is depicted on table 4.2; Table 4.2 Cross tabulations and Chi- Square Test Result on Changes in traditional livelihoods of men and women From the findings shown on table 4.2, the null hypothesis was rejected (p-value = 0.015, significance level = 0.05) and conclude that Oil mining has influenced change of livelihood for women in Lokichar community. The findings can be supported by the FGD members and the key informant interviews who observed that there was a sharp change in the first phase of 2010 to 2013 where those employed were able to have changes in their earnings leading to changes in the form of houses they had, and others opening businesses at the local town of Lokichar. All the key informants also supported the assertion that there were significant changes in their livelihoods courtesy of oil mining in Lokichar. The study confirmed the findings by Lozeva, and Marinova, (2010) who argued that women were beneficiaries of oil mining activities, whether they were working in the mines, or their husbands were employed in mines or they were benefiting indirectly from the money coming from mining. 4.4 Ways of empowering men and women in gender role transformation in the oil mining sector The study was also expected to identify approaches on how to increase participation among the respondents and the locals in Lokichar, Turkana County. Through participation, it becomes easy for the locals to be empowered and to increase their capacity to improve livelihoods and empower both genders. The study also sought to identify ways in which men and women had been empowered through participation. The aspects that were considered in the study were the available laws and policies that were applied to ensure participation of women and men in oil mining activities. 4.4.1 Law and/or Policy Dealing with Gender in Oil Mining Laws and policies dealing with gender in oil mining have the capacity to determine the level and context to which women and men can be empowered. Policies help in guiding companies in having both men and women participate in many opportunities created for empowering the locals. The study asked the respondents whether they were aware of any law or policy that deals with gender in the oil mining sector in Kenya. The respondents were mostly referring to the gender rule, popular in Kenya for ensuring there is gender balance in all public positions. The responses are captured in table 4.3 as depicted, Table 4.3 Aware of Laws and Policies dealing with gender in oil mining in Kenya \| \| Male \| \| Female \| \| \| \|---\|---\|---\|---\|---\|---\| \| \| N \| % \| N \| % \| N \| \| Yes \| 24 \| 24.0 \| 56 \| 35.0 \| 80 \| \| No \| 76 \| 76.0 \| 104 \| 65.0 \| 180 \| \| Totals \| 100 \| 100.0 \| 160 \| 100.0 \| 260 \| When asked if they are aware of any law or policy that deals with gender issues in the oil mining sector in Kenya, only 24% (males) and 35% (females) of the respondents were aware while 76% (males) and 65% (females) were not aware of any policy or law concerning gender issues in the oil mining sector. It was interesting to note that there were over 69.2% of the respondents who were not aware of any policy or law on gender empowerment. It indicates that the majority of the locals in Lokichar are not aware of any policy to deal with their empowerment, and especially women as they formed the majority of the 69%. The findings in this study reflected similar findings by Akintola and Chikoko, (2016) who indicated that majority of the marginalized areas were lagging behind in having information, especially of opportunities for their socioeconomic and cultural empowerment. 4.4.2 Practical mechanisms for improving women's capacity to cope with mining effects Members suggested several platforms and mechanisms to implement gender policies. One of the key informant opined that, "There is need to engage women in capacity building platforms like training on skills that they can use to empower themselves. Activities like workshops and seminars are recommended." The observation was supported by four other Key informants who also indicated that women needed to be taken out for benchmarking with other women groups and establishment to experience the feeling of empowerment. Women taken for exposure trips are likely to embrace leadership roles in the community. Women also need to be exposed to media to see other women who are empowered. "Women need to be included in management functions like being in school committees and assigning them roles for the purpose of building their capacity," one of the respondent indicated. 5.Recommendations and Conclusion 5.1Conclusions Oil Mining has brought with it changes; that there was transformation in gender roles with men taking roles that were previously perceived to be women roles and women were taking jobs that were previously termed as men roles. The established policies on gender lack good will and implementation despite of them being excellent in promoting gender equality in the oil mining sector. 5.2Recommendations The paper presents the following recommendations. It was recommends that the oil mining companies spend resources including time and finances on training the locals to improve their capacities to participate in oil mining processes. Seminars, workshops and capacity building forums to help improve the participation of women, and men in economic activities within the oil mining sector in Lokichar. Additionally, gender roles could be changed through the locals picking the available job opportunities with the oil mining. Forums should be created to educate the locals that picking any job opportunity was beneficial to the society. The locals should not to dwell on the cultural perceptions of the traditional roles and how the society looks at the workers executing roles perceived not to be theirs. Consequently, due to high illiteracy levels among the locals, focusing on education for the locals would help them achieve better employment opportunities irrespective of the roles they acquire. Finally, there is also need for oil companies and government in general implementing set policies and conducting regular gender audits. More emphasis should be placed on goodwill to implement the policies. 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Doing human differently: a critical study of of appraised diversity discourses in corporate South Africa (Doctoral dissertation). Ngendanzi, E. (2012). A New Attempt to Crack Open Africa‟s Mining Industry to Women. World Crunch International Newsfeed. Nygren, M. (2013). Veckopendlingen i Malmfälten. Luleå: Luleå University of Technology. Omia, Dalmas Ochieng. (2015). "Gender Dimensions and Implications of Coal Mining in the Mui Basin of Kitui County, Kenya." Centre for Governance and Development.www.daogewe.org/index.php/publications/reports/23-mining-report-updated Omolo, M. W. (2014). Gender, Value Chain and Women Participation in the Emerging Extractive Industry in Kenya. Scanlan, S. J. (2015). Gender, development and the environment: female empowerment and the creation of sustainable societies. In Development in Crisis (pp. 129-147). Routledge. Stenbacka, S (2011). 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Plan Overview A Data Management Plan created using DMPonline Title: 3mE-PhD-Magnetometers for refined localization of equipment for underwater applications Creator: Frida Viset Principal Investigator: Frida Viset, Frida Marie Viset Data Manager: Frida Viset Affiliation: Delft University of Technology Template: TU Delft Data Management Questions (old version, do not use) Project abstract: In this project we will use an array of magnetometers measuring the magnetic field combined with inertial sensors and barometers to perform the underwater localization. The barometers provide information about the depth, roll and pitch of the sensor setup. Roll and pitch information can be obtained from the accelerometer. Integration of the accelerometer data to position is highly susceptible to errors, resulting in a drift between the estimated and actual position. Accurate estimation of the remaining three degrees of freedom, surge, sway and yaw, is therefore significantly more challenging and we will focus on using an array of magnetometers to overcome this challenge. ID: 67948 Last modified: 20-04-2021 Copyright information: The above plan creator(s) have agreed that others may use as much of the text of this plan as they would like in their own plans, and customise it as necessary. You do not need to credit the creator(s) as the source of the language used, but using any of the plan's text does not imply that the creator(s) endorse, or have any relationship to, your project or proposal 3mE-PhD-Magnetometers for refined localization of equipment for underwater applications General TU Delft data management questions Name of data management support staff consulted during the preparation of this plan Yasemin van der Velden, the Data steward of 3mE Date of consultation with support staff [YYYY-MM-DD] 09-12-2020 1. Is TU Delft the lead institution for this project? Yes, the only institution involved 2. If you leave TU Delft (or are unavailable), who is going to be responsible for the data resulting from this project? Manon Kok ([email protected]) 3. Where will the data (and code, if applicable) be stored and backed-up during the project lifetime? Another storage system - please explain below, including provided safety measures Dropbox. Dropbox makes sure there are always redundant copies of the data; data is automatically backed up and synced across devices and has version control. 4. How much data storage will you require during the project lifetime? < 250 GB 5. What data will be shared in a research data repository? All data (and code) underlying published articles / reports / theses 6. How much of your data will be shared in a research data repository? < 100 GB 7. How will you share your research data (and code)? I will share my data and code via git(lab)/subversion and also create a snapshot in a repository 8. Does your research involve human subjects? No 9. Will you process any personal data? Tick all that apply No personal data TU Delft questions about management of personal research data 1. Please detail what type of personal data you will collect, for what purpose, how you will store and protect that data, and who has access to the data. Question not answered. 2. Will you be sharing personal data with individuals/organisations outside of the EEA (European Economic Area)? Question not answered. 3. What is the legal ground for personal data processing? Question not answered. 4. Will the personal data be shared with others after the end of the research project, and if so, how and for what purpose? Question not answered. 5. Does the processing of the personal data results in a high risk to the data subjects? If the processing of the personal data results in a high risk to the data subjects, it is required to perform a Data Protection Impact Assessment (DPIA). In order to determine if there is a high risk for the data subjects, please check if any of the options below that are applicable to the processing of the personal data during your research (check all that apply). If two or more of the options listed below apply, you will have to complete the DPIA. Please get in touch with the privacy team: [email protected] to receive support with DPIA. If only one of the options listed below applies, your project might need a DPIA. Please get in touch with the privacy team: [email protected] to get advice as to whether DPIA is necessary. If you have any additional comments, please add them in the box below. Question not answered.	<urn:uuid:f1eba7bc-9bdf-47ba-b672-f6fcaec34a1a>	CC-MAIN-2025-08	https://miun.dmponline.dcc.ac.uk/plans/67948/export.pdf?export%5Bquestion_headings%5D=true	2025-02-08T23:07:15+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2025-08/subset=warc/part-00033-b184e832-acd1-425a-bab7-895830f2748a.c000.gz.parquet	357,298,344	984	eng_Latn	eng_Latn	0.995572	eng_Latn	0.996156	[ "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1511, 2879, 4552 ]
Colors and Materials Hood R65 G49 B52 Tunic Leather R73 G48 B32 Chain Mail R133 G124 B118 Tunic Trim R159 G152 B137 Glove Detail R113 G95 B60 Plate Leg Guards R75 G72 B69 Chain Mail Leliana Character Guide BioWare™ A DIVISION OF EA WHISPERS AND SECRETS. THESE ARE the preferred weapons of Leliana, the Inquisition’s spymaster. A cunning strategist with eyes and ears across Thedas, Leliana’s armor is a reflection of her need to remain both unassuming and unnoticed. She dons a leather tunic lined with chainmail, affording added protection without compromising mobility. Plate greaves and leg guards ensure she can’t be struck down by low swinging blows, while an ashen purple hood conceals her face when anonymity is key. The heraldry of the Inquisition rests squarely on the front of her tunic, the eye serving to remind opponents that their secrets are never safe.	2677691a-0b08-414c-80c1-aed4c462b9d6	CC-MAIN-2021-04	https://blog.bioware.com/wp-content/uploads/2015/03/Leliana_kit-a.pdf	2021-01-22T12:11:59+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2021-04/subset=warc/part-00177-364a895c-5e5c-46bb-846e-75ec7de82b3b.c000.gz.parquet	255,297,411	228	eng_Latn	eng_Latn	0.529894	eng_Latn	0.989057	[ "dag_Latn", "eng_Latn" ]	true	docling	[ 240, 878 ]
BOARD EMPLOYEE COMMUNICATIONS The Board desires to maintain open channels of communication between itself and the staff. The basic line of communication will, however, be through the Superintendent of Schools. Board Communication to Staff All official communication, policies, and directives of staff interest and concern will be communicated to staff members through the Superintendent, and the Superintendent will employ all such media as are appropriate to keep staff fully informed of the Board's concerns and actions. Staff Communications to the Board A request to appear before the School Board shall be made in writing and filed with the Superintendent of Schools. No issue may be raised before the School Board outside of public input that has not been previously identified and presented to the Superintendent. If warranted, the Superintendent shall notify the parties in writing of the date, time, and place of the Board meeting having the matter listed on the agenda. Visits to Schools Individual Board members interested in visiting schools or classrooms should inform the Superintendent of such visits and make arrangements for visitations through the Principals of the various schools. Such visits shall be regarded as informal expressions of interest in school affairs and not as "inspections" or visits for supervisory or administrative purposes. Official visits by Board members will be carried on only under Board authorization and with the full knowledge of the Superintendent and Principals. Social Interactions Staff and Board members share a keen interest in the Schools and in education generally, and it is to be expected that, when they meet at social affairs and other functions, they will informally discuss such matters as educational trends, issues, and innovations and general District problems. However, individual Board members have no special authority excepting when they are convened at a legal meeting of the Board or vested with special authority by Board action. Therefore, discussions by either party of personalities or personnel grievances will be considered as evidence of unethical conduct. Legal Reference: RSA Chapter 98-E Public Employee Freedom of Expression Adopted: 12/19/05 Reaffirmed: 4/06/09 Revised: 5/06/2024	<urn:uuid:b83fe1bb-23c5-4dbf-b253-97f8509f3bfb>	CC-MAIN-2024-42	https://resources.finalsite.net/images/v1715103884/gwrsdorg/lbfhigti7idr9yhtnzx6/GBD.pdf	2024-10-14T23:48:16+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-42/subset=warc/part-00141-0c083cf2-c0ed-42ad-af5c-44f7548e96a0.c000.gz.parquet	440,645,739	420	eng_Latn	eng_Latn	0.99717	eng_Latn	0.99717	[ "eng_Latn" ]	false	rolmOCR	[ 2281 ]
Dust Oﬀ Your DISC By Robert Verzi Few people know of the tax rule that could be saving your manufacturing or distribution company millions of dollars each year. Despite it being the oldest tax beneﬁt available for exporters, many companies are missing out. "What is this tax beneﬁt," you ask? It is the use of Domestic International Sales Corporations, or DISC. The use of a DISC has the potential to reduce your company's tax rate on exports between 50 and 100 percent, meaning huge savings for you and your shareholders. How? A DISC avoids C corporation tax on export proﬁts, are tax-exempt entities and any dividend paid to a shareholder is taxed at only 15 percent, compared to the typical rate of 35 percent. WHAT IS A DISC? A DISC is a tax-exempt entity that has little or no business activities, yet receives tax beneﬁts that allow companies in certain industries to re-categorize some of their ordinary income into qualiﬁed dividend income within the DISC on qualifying export property. Overall, the beneﬁts of using a DISC exist around the percent of tax paid by shareholders on their dividends. For example, a company with a net export proﬁt of $1 million can save $100,000 in Federal income tax per year, just by setting up a DISC. Moreover, State income taxes can be saved by using the DISC structure. The savings is unlimited and the more your business exports, the more the potential savings. HOW IT WORKS A DISC acts as a separate, legal, tax-exempt entity from its parent company, that doesn't pay tax on commission income. Therefore, using a DISC, a U.S. company pays "commission" to DISC based on its proﬁts from the sale of qualifying export products (explained below). This commission is deductible by the parent company. In return, the DISC pays a dividend to its shareholders. That dividend that is paid is treated as a qualifying dividend under the law and is taxed at 15 percent, under current law. There are, however, certain requirements that must be met before a company can qualify to use a DISC. These include being a U.S. manufacturer or distributer that exports U.S. manufacturing goods, or architectural and engineering ﬁrms that oversee non-U.S. construction projects. An Independent Member of Baker Tilly International QUALIFYING EXPORT PROPERTY: Export property must be: Used, consumed or disposed of outside the U.S. However, they CANNOT fall into any of the categories below: Property leased or rented to related person Income from intangibles Unprocessed softwood timber Export controlled products No more than 50 percent of the value related to imported components Certain oil, gas, coal and uranium products in short supply Products Robert is an International Tax Partner with more than 27 years of experience providing international tax solutions to publicly and privately held corporations on an array of international tax matters, such as foreign tax credit management and utilization, structuring foreign and domestic operations, international mergers and acquisitions, and export tax incentives. He also has many years of experience serving foreign-owned U.S. businesses. Robert Verzi, CPA Tax Partner Oﬃce: 404-898-8486 Cell: 404-200-2984 Email: [email protected] To Learn more about how using a DISC can save you or your company money, contact Robert Verzi at [email protected] or call him at 404-898-8486.	<urn:uuid:9b1c092b-a5e7-43b4-b89d-ce1d2dcac29a>	CC-MAIN-2016-50	http://www.hawcpa.com/docs/bio-articles/dust-off-your-disc.pdf?sfvrsn=2	2016-12-08T14:18:19Z	s3://commoncrawl/crawl-data/CC-MAIN-2016-50/segments/1480698541529.0/warc/CC-MAIN-20161202170901-00269-ip-10-31-129-80.ec2.internal.warc.gz	491,819,688	768	eng_Latn	eng_Latn	0.991343	eng_Latn	0.997083	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2269, 3400 ]
Minimizing Warp in Laminated Particleboard and Medium Density Fiberboard technical BULLETIN Introduction Industrial grade particleboard (PB) and medium density fiberboard (MDF) are widely recognized as ideal substrates for laminated panel products. Their properties - smooth surface, uniform density and thickness, dimensional stability, strength, stiffness, flatness, screw holding strength, and machinability - contribute to the ease of fabrication and to the ultimate performance of laminated panel products such as table tops, countertops, kitchen cabinets, and stereo and television cabinets. These applications require laminated panels to remain flat. Warp is defined as the "deviation of the geometry of a panel from an initial state of flatness." This document outlines some factors (balanced construction; material handling and storage; and proper laminating, fabricating, and installation techniques) that affect warp, and steps a laminator or fabricator can take to minimize it. Two other useful documents are "CPA Standard Method for Measuring Warp in Particleboard and Medium Density Fiberboard," which describes the test method used to measure warp, and "ASTM Test Method D-1037," which describes the test method used to measure moisture content. Balanced Construction One of the most common causes of warp in laminated panel products is unbalanced panel construction. As different materials are rigidly bonded together, moisture content changes may occur. In response to the changes in moisture content, the materials attempt to change dimensions. When that happens, stresses can accumulate. Warp results when these stresses become excessive and are no longer balanced on the two surfaces. This imbalance may be caused by a number of factors, including selection of laminate, laminating environment, component conditioning, product design, installation, and application. Selection of laminates and balanced construction go hand-in-hand. The laminates and/or coatings applied to each side of a PB or MDF substrate should be similar in properties. Generally, this is best achieved by using the same material to cover both sides of a substrate. Unusually moist or dry conditions should be avoided in the laminating and storage environments. The moisture content of wood-based materials and laminates is dependent on the amount of moisture in the air. When these materials are moved from one environment to another, the moisture content changes. Resulting dimensional changes can be substantial. Once assembled, differences in the expansion or shrinkage characteristics of the laminate and substrate can produce stresses which cause warped panels. Ideally, laminates and substrates should be stored and assembled in conditions similar to the finished product application environment. It is unlikely that the moisture content of the laminate and the substrate will be in equilibrium with the laminating environment when they are delivered. Allow sufficient time for the laminate and the substrate to adapt to the laminating environment. It can take two or more weeks to reach a satisfactory equilibrium. Seasonal changes and air circulation around the materials will influence the time it takes. Laminates at one equilibrium moisture content (EMC) condition should not be applied to PB/MDF of a different EMC condition. If they are, as the moisture content equalizes, the PB/MDF substrate may expand or contract while the laminate seeks the opposite. When bonded with rigid adhesives, the components cannot move in relation to each other. This creates stresses at the substrate/laminate interface which can result in a warped panel. Service Environment Even with a perfectly balanced panel, installation and application conditions can cause moisture unbalance that results in warp. The laminated panel should not be exposed to extreme variations in humidity during final installation. Changes in humidity at the installation site can result in stresses that cause warp as the entire panel equalizes to the new service environment. The information in this document is believed to be reliable. However, the determination of suitability of this information for any use or application remains the sole responsibility of the user. No guarantees, representations or express or implied warranties are made regarding the accuracy and completeness of this information, and the Composite Panel Association (CPA) assumes no responsibility or liability for any loss or damage through reliance upon it. Panel conditioning prior to final installation improves reliability. The design of laminated panel applications must also consider the service environment. Applications that expose one surface of a panel to a warm humid atmosphere and the other to a dry atmosphere will result in moisture unbalance that can cause warp. Long expanses of panels, such as display cases or walls, may warp if they do not include expansion joints or other design considerations allowing for dimensional changes resulting from seasonal variations in the environment. Panels that are butted edge-to-edge and rigidly fastened may buckle (a form of restrained warping) due to expansion stresses as moisture content increases. A balanced laminated panel is one that will not warp when subjected to forces induced by uniformly distributed moisture changes. Balanced panel construction and subsequent dimensional stability in service are best achieved when: * The moisture content of the PB/MDF substrate and laminate materials are similar at the time of lamination. * Materials with similar expansion/ shrinkage coefficients are utilized. * The moisture content of the finished product is similar to the moisture content to be encountered in service. A well-balanced laminated panel can exhibit temporary warp due to unequal rates of moisture gain or loss by the face and back laminates. However, as soon as the laminates equalize, these stresses diminish, and the panel returns to its flat condition. This ability to equalize and return to the flat condition at any humidity is an important attribute of the balanced panel. Substrates Approximate equilibrium moisture content zones in the United States for wood-based products. Values may vary with local and seasonal conditions. Selection of PB/MDF for laminating applications s h o u l d f o l l o w b a s i c guidelines. Always select flat panels for substrates. Flatness indicates that the substrate is balanced and free of stress. Consider the s u b s t r a t e p r o p e r t i e s , including stiffness (MOE), thickness, linear expansion, and uniformity. These can be evaluated from the manufacturer's specifications or standards. The greater the MOE or thickness of the material, the better it will resist moisture related expansion stresses. Measure the panel moisture content and set guidelines of acceptability. Evaluate all of these properties with respect to laminates that will be applied. Storage and Handling applied to PB/MDF substrates by the laminator. Rules for substrate and laminate handling and storage are generally the same. Materials should be stored flat and kept dry. For best performance: 1. Do not store materials outside or in locations where they may be exposed to water or high humidity. 2. Keep material off the floor, use bolsters of the same thickness, and allow adequate space between units. 3. Avoid storage conditions where extremes of temperature and humidity can occur. 4. Before final assembly, allow materials satisfactory conditioning period to equalize. a Laminates High-pressure laminates, resin-saturated papers, vinyl films, heat transfer foils, decorative papers, and wood veneers comprise types of overlay materials commonly High-Pressure Laminates (HPL) High-pressure laminates consist of multiple layers of kraft paper saturated with phenolic resin, a decorative layer of paper saturated with melamine resin, and a very thin top sheet of paper heavily saturated with melamine resin. As does any wood-based product, HPLs expand and contract with changes in moisture content. The HPL and the substrate materials should be brought to equilibrium at the same humidity and temperature before laminating. This conditioning period may be two weeks or even longer. If laminated panels are fabricated from materials conditioned at radically different humidities, warp will most likely occur when the finished panel comes to equilibrium with the surrounding environment. The key factors for obtaining balanced HPL panels are: 1. Proper conditioning of component materials before laminating. 2. Selection of HPL faces and backer sheets with similar linear expansion, stiffness and thickness properties. when using different papers. 3. Lamination of HPL face and backer sheets with machine directions parallel. 4. Following the adhesive manufacturer's recommendations for storage, method of application, spread rates and end use. In some applications, such as countertops, it may be appropriate to use a face laminate without a backer sheet. In these cases, using an elastic adhesive (for example, rubber-based contact cement) reduces the amount of stress transferred to the substrate by the face laminate and thereby reduces the tendency to warp. Attached countertop installations further reduce the tendency to warp by restraining residual stresses that may be transferred to the substrate. Saturated Papers Saturated papers, or low-pressure laminates (LPL), are preprinted or solid color decorative papers that have been saturated with either a melamine, a phenolic, or a polyester resin. LPLs, like HPLs, are wood-based products and will shrink and expand with changes in moisture content. In addition to the key factors listed for the successful use of HPLs, the following should be kept in mind: 1. During assembly, load and close the press as quickly as possible. Use a cool caul on the bottom, when cauls are used for panel insertion. 2. Hot boards should be stacked flat and be well supported while cooling. Units with fewer pieces cool more evenly. Avoid cooling panels too rapidly. Cool panels uniformly on both sides. 3. Follow manufacturer's instructions for storing papers. Do not use papers that are overaged or dried out. 4. Be sure that press platen temperature and conditions are set to properly cure both sides 5. Avoid degradation of the substrate when using phenolic papers with elevated press temperatures and extended press times. Proper cooling of the panels is critical. 6. The linear expansion properties of resinsaturated papers are often greater than that of particleboard and MDF under the same conditions. 7. Use as few press openings as possible: too many openings tend to increase precure by slowing closing time. Wood Veneers A major application of wood veneer is as a decorative laminate material over PB/MDF substrates. The general handling and storage requirements discussed previously also apply to veneer and PB / MDF combinations. In addition, the materials should be laminated with their moisture content in the 6-9 percent range. And, since balanced panel construction is essential to prevent warp, the same thickness and grade veneer should be used on both sides. Composite Panel Association Different veneer species can be used, but they must have similar strength properties and dimensional behavior patterns. Problem areas, such as tension wood, burls, and knots, and their effect on stress must be specifically considered. Finally, the glue spread rate should be uniform. Other Overlays Vinyl films, low-basis-weight papers, and foils should all be applied using good balancedlamination practices. Generally, the application of a film or paper to one side only, or different overlays on each side of a PB/MDF substrate will not result in warp. However, one-sided application of any laminate may act as a moisture barrier creating a transitory imbalance which can result in warp over time. Composite Panel Association Summary An imbalance in moisture-related expansion or contraction frequently causes warping of laminated panels. Such an imbalance is activated by changes in moisture content. A change might be temporary, as in the case of wetting one side of a flat panel. The resulting "transient warping" is beyond the c o n t r o l o f t h e l a m i n a t e d - p a n e l manufacturer. In theory, "structural warp" resulting from a built-in imbalance can sometimes be prevented. natural variability of the laminate and substrate properties is a common cause of warping, particularly in the case of a thin substrate with relatively thick laminate faces. Controlling the variability between the laminates can effectively reduce warp in laminated panels. Balanced lamination is the key to consistently manufacturing flat panels. The The concept of balance does not end with the manufacture of a balanced panel. The installation and the end-use environments can also be sources of moisture imbalance that create internal stresses resulting in warp. To ensure acceptable laminated product performance, design and engineering must consider the product application and environment. REFERENCES Medium Density Fiberboard From Start to Finish. Composite Panel Association, Gaithersburg, Maryland. 1998. Particleboard From Start to Finish C o m p o s i t e P a n e l A s s o c i a t i o n , Gaithersburg, Maryland. 1996 Standard Method for Measurement of Warp in Particleboard and MDF. C o m p o s i t e P a n e l A s s o c i a t i o n , Gaithersburg, Maryland. Suchsland, Otto and Hong Xu, The Linear Expansion of Commercial Particleboard and its Measurement. Composite Panel Association, Gaithersburg, Maryland. Suchsland, Otto, and J.D. McNatt, Computer Simulation of Laminated Wood Panel Warping. Forest Products Journal, 36 (11/12):16-23, 1986. Suchsland, Otto, and J.D. McNatt, On the Warping of Laminated Wood Panels Michigan State University, East Lansing, Michigan. 1985 Forest Products Laboratory, Wood Handbook: Wood as an Engineering Material. A.H. 72, Washington, DC. 1987 Heebink, B.G. Importance of Balanced Construction in Plastic-Faced Wood Panels. U.S. Forest Service Research Note FPL-021. 1963 Composite Panel Association Main Office 18922 Premiere Court Gaithersburg, Maryland 20879-1574 301-670-0604 ▪ Fax 301-840-1252 99 Bank Street, Suite 701 Ottawa, Ontario K1P 6B9 613-232-6782 ▪ Fax 613-232-8386 Toll Free 1-866-4COMPOSITES www.pbmdf.com Composite Panel Association The Composite Panel Association (CPA), founded in 1960, represents the North American composite panel industry on technical, regulatory, quality assurance and product acceptance issues. CPA General Members include 38 of the leading manufacturers of particleboard, medium density fiberboard and hardboard and other compatible products. Together they represent nearly 95% of the total manufacturing capacity throughout North America. CPA also brings together the complete value chain affiliated with the composite panel industry. CPA's 200 members worldwide, primarily in the US and Canada, are committed to product advancement and industry competitiveness. Associate Members include manufacturers of furniture, cabinets, decorative surfaces and equipment as well as laminators and distributors. CPA is a vital resource for both producers and users of industry products. As an accredited standards developer, CPA writes and publishes industry product standards. It also participates in the standards development work of ANSI, ASTM and others, sponsors product acceptance activities and works with federal and state agencies and model building code bodies. In addition, CPA conducts product testing and third-party certification programs, while helping manufacturers create in-plant quality control programs. Outreach and education are also focal points of the CPA. The Association publishes industry performance data and conducts seminars to assist specifiers, manufacturers and other users of composite panels. CPA produces a series of technical bulletins and develops publications, videos, and other materials to inform key audiences about the attributes of industry products.	<urn:uuid:7da091f1-5cc5-4e80-9f6a-e26c92c5be33>	CC-MAIN-2021-43	https://www.compositepanel.org/wp-content/uploads/Minimizing-Warp-TB.pdf	2021-10-18T14:45:16+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2021-43/subset=warc/part-00031-16202947-a809-4711-8221-79ab0a79d5b1.c000.gz.parquet	880,456,811	3,235	eng_Latn	eng_Latn	0.957476	eng_Latn	0.991036	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2174, 6140, 8625, 11993, 13200, 16213 ]
ROTO 40.18 EVS - 40.21 EVS ### DIMENSIONS \| \| ROTO 40.18 \| ROTO 40.21 \| \|---\|------------\|------------\| \| A mm \| 6085 \| 6600 \| \| C mm \| 2970 \| 2970 \| \| E mm \| 5030 \| 5030 \| \| F mm \| 360 \| 360 \| \| G mm \| 410 \| 410 \| \| H mm \| 2400 \| 2400 \| \| L mm \| 4285 \| 4285 \| \| M mm \| 940 \| 940 \| \| N mm \| 2390 \| 2505 \| \| P mm \| 2950 \| 2950 \| \| R mm \| 4050 \| 4050 \| \| S mm \| 5150 \| 6100 \| \| Z mm \| 850 \| 850 \| ### OUTSTANDING MANOEUVRABILITY - Internal width: 4285 mm - : 65 mm. Shown at suspension mid point --- ### ROTO 40.18 EVS Lift capacities at 500 mm load centre* --- ### ROTO 40.21 EVS --- ### WEIGHTS \| \| 40.18 EVS \| 40.21 EVS \| \|----------------------\|-----------\|-----------\| \| Machine weights with forks kg \| 14300 \| 14500 \| ### PERFORMANCES ON STABILISERS \| Performance \| 40.18 EVS \| 40.21 EVS \| \|------------------------------\|-----------\|-----------\| \| Max. lift capacity kg \| 4000 \| 4000 \| \| Max. lift height mm \| 17800 \| 20800 \| \| Max. reach mm \| 15000 \| 18000 \| \| Max. height at full capacity mm \| 13000 \| 13300 \| \| Max. reach at full capacity mm \| 6000 \| 7000 \| \| Max. capacity at full height kg \| 3000 \| 2500 \| \| Max. capacity at full reach kg \| 600 \| 500 \| \| Tear-out force with 800 l bucket kg \| 4230 \| 4230 \| \| Drawbar pull kg \| 7800 \| 7800 \| \| Carriage rotation deg \| 140° \| 140° \| ### Slewing - continuous ### OPERATING TIMES \| Operation \| 40.18 EVS \| 40.21 EVS \| \|----------------------------\|-----------\|-----------\| \| Turret rotation sec/round \| 12 \| 12 \| \| Boom lift sec \| 14 \| 14 \| \| Boom lower sec \| 11 \| 11 \| \| Boom extend sec \| 25 \| 30 \| \| Boom retract sec \| 20 \| 25 \| \| Carriage tilt (full rotation) sec \| 5 \| 5 \| \| Bucket dump (800 l bucket) sec \| 1.5 \| 1.5 \| ### TRAVEL SPEED \| Gear \| 40.18 EVS \| 40.21 EVS \| \|------\|-----------\|-----------\| \| 1st gear kph \| 11 \| 11 \| \| 2nd gear kph \| 40 \| 40 \| --- ### OPERATOR’S CAB Cab dimension complies with norms EN 23411. Boom and carriage services are controlled by 5 in 1 electronic joystick. Instrumentation includes: combined speedometer/tachometer, hour meter, fuse box, fuel level gauge, engine coolant temperature gauge, warning light annunciator panel combining warnings for blocked air filter, hydrostatic oil level and temperature, engine oil pressure, engine coolant temperature, parking brake operation. ### SAFETY SYSTEMS The Merlo safety warning system activates both audible and visual warning signals, simultaneously applying a lock to the hydraulic system to prevent further overloading motion. The Computerised Slew Safety system (CSS) continually monitors each outrigger cylinder, ensuring that ROTO machines can be used to maximum advantage while retaining complete safety. Anti-hose burst check valves are fitted in all hydraulic cylinders. Cab mounted fire extinguisher fitting brackets. Safety belts Standard audible reversing warning. ### BOOM ASSEMBLY The four section boom is fabricated from high yield strength steel and extends upon low friction pads, which can be externally adjusted. The extension ram is internally mounted for increased protection against site damage. ### INDEPENDENT OUTRIGGERS The four independently controlled outriggers permit chassis levelling in rough site conditions. ### HYDROPNEUMATIC LEVELLING SUSPENSION Each wheel is equipped with a hydro-pneumatic suspension. The system will correct slopes of up to 9° (16%) laterally or 5° (9%) longitudinally. ### PALLET FORKS Standard 1200mm forks, 130 x 45mm Centre to centre spacing 450-1050mm, manually adjustable. ### ENGINE ROTO 40.18 EVS: Low emission six cylinder, naturally aspirated engine, direct injection, water cooled, output 88.4 kW (120 HP) at 2200rpm (ECE 80/1269). ROTO 40.21 EVS: Low emission six cylinder turbo charged engine, direct injection, water cooled, output 95 kW (129 HP) at 2400rpm (ECE 80/1269). ### TRANSMISSION Closed circuit hydrostatic system with variable displacement pump and motor. Stepless speed control through two range gearbox, providing travel speeds of 0-11kph (low range) and 0-40kph (high range). Permanent four wheel drive. ### HYDRAULICS Single, variable displacement axial piston pump, with ‘Load-Sensing’ control system. Maximum displacement: 120lpm Operating pressure: 210 bar 125 micron ‘For Life’ suction line strainer 25 micron return line filter ### ELECTRICAL SYSTEM 12 Volt system with 155 Ah battery and 65 A alternator. ### SERVICE CAPACITIES Hydraulic system: 130 l - Diesel fuel: 155 l Hydrostatic oil: 12 l - Engine oil: 8.5 l Engine coolant: 12 l ### TYRES 18-22.5 16 PR on both axles, 8 stud rims (DIN 74361). ### OPTIONS - Rear axle differential lock - Roof window wiper - Front screen guard - Pre-arrangement for special attachments --- MERLO UK LTD Paddocka Headlands Business Park - Salisbury Road RINGWOOD - HAMPSHIRE - BH24 3PB - ENGLAND Tel. (01425) 480806/470701 - Fax (01425) 477478 - www.merlo.co.uk MERLO SPA Industria Metalmeccanica 12020 S.DEFENDENTE Di CERVASCA (CN) - ITALY Tel. +39 0171-614111 - Fax +39 0171-614100 Telex 220236 Merlo I - www.merlo.com - E-mail: [email protected]	<urn:uuid:1ccaf9ff-ec6b-44c9-b136-89eb87913b09>	CC-MAIN-2019-22	http://www.totalaccess.co.nz/files/5114/1798/4992/merlo_roto_40.18.pdf	2019-05-27T01:02:00Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-22/segments/1558232260358.69/warc/CC-MAIN-20190527005538-20190527031538-00264.warc.gz	335,223,455	1,571	eng_Latn	eng_Latn	0.893586	eng_Latn	0.889238	[ "unknown", "eng_Latn" ]	false	docling	[ 26, 5629 ]
Comprehension Strategy The following preview shows all of the comprehension strategy resources for Locomotive by Brian Floca Lesson Plans and Practice Pages Asking Questions Lesson Plan Practice Pages and Answer Keys Activate Prior Knowledge Key Vocabulary Guided Reading Level Page by Page Guide and Strategy Questions Turn, Talk, and Reflect Explanation of Strategy Asking Questions Lesson Plan Author's Purpose Writing About Reading with Optional CCSS Alignment Common Core State Standard "I Can" Statement Strategy and Text Based Reader's Response Prompt Common Core Free Option 5 Comprehension Strategy Graphic Organizers Retelling and Making Author's Visualizing Asking Questions Summarizing Predictions Purpose	<urn:uuid:3cddab23-aadc-403a-89c3-b06157012c49>	CC-MAIN-2023-50	https://h5q5b5r2.rocketcdn.me/wp-content/uploads/preview/Locomotive/LocomotiveComprehensionStrategiesPreview.pdf	2023-11-29T03:10:12+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-50/subset=warc/part-00008-e565b809-b335-4c1d-90fd-54a9a2b7113d.c000.gz.parquet	344,160,209	157	eng_Latn	eng_Latn	0.764741	eng_Latn	0.77444	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 418, 734 ]
City Parish News Interesting Budget of Happenings Gathered by Our City Reporter BY MUNICHA Last Tuesday morning regular school commenced at 7 o'clock for the reception of the children of Mrs. John McCabe and last Wednesday morning at 9 o'clock for Mrs. Tracy and mothers. As Sunday is the third Sunday of the month it will be communion day for the Young Ladies' Sodality. On Sunday evening, April 14, at 8 o'clock in the Knights of St. John was organized in St. Monica's parish. The officers elected were: President, by Mrs. Theresa Ranner; the Supreme Council, composed of: Spiritual adviser, Rev. John P. Brophy; Pres. Mrs. Win. H. Holman; Sec'y Mrs. Josephine Intrau; Fin. Sec'y., Miss Helen Tanneney; Fin. Sec'y., Mrs. Agnes Treanor; Fin. Sec'y., Mrs. Mary Marshall; Mrs. Sarah Feller; secretary, Mrs. Geo. Frey; guard, Josephine Intrau; Mrs. John Schreiber, Mrs. Frank Horn, Mrs. Thomas Gastrman, Mrs. D. Meier, Mrs. Henry Daugher. SUNDAY MASS. Sunday at all the masses the monthly extra collection will be taken up. The penitential masses for the week were for Felix and Catharine Fein, Tom, Brennan, Alex Doherty, and William O'Brien. The annual banquets of the Women's Auxiliary will be held on Tuesday evening, April 23rd. All members are requested to be present. A fine musical program will be rendered. The cleaning parties will meet on Saturday afternoon at 2 o'clock. Miss Clara Walter, 87, Scranton St.; Fr. James, 100, Young St.; Mrs. Bingham, 105, and Miss John Kauach. The next hostess will be Miss Eleanor Wengenden of Ross St. The bans of matrimony were announced Sunday between Mr. Al Franz and Miss Josephine Wittman. Sunday afternoon after vespers there will be regular meeting of the Women's Sodality. All members are requested to be present. Blessed Sacrament. The girls and young women are invited to receive holy communion this Sunday. School collection will be taken up Sunday. A high mass of requiem was offered on Thursday for Mr. T. Sullivan. First rent is due Sunday, the first Sunday of the quarter. A meeting of the Young Ladies Sodality will be held in the church hall Sunday afternoon at 4 o'clock. A very instructive lecture was given by Rev. A. O'Neill, D.D., secretary of Canisius college before the memorial of the Holy Name Society last Tuesday evening in Holyland. It was illustrated with several pictures. There was a large attendance. Plans are also being made for the second social to be held on May 1st, after the slating of a smoker, supper and entertainment within the next few weeks. Members of Br. 238, of the C.M.B.A., will receive holy communion at the 7 o'clock mass of Sunday. The marriage of Margaret Conway, James Kelly, was celebrated on Wednesday morning with a nuptial mass at 8 o'clock. Mrs. Kelly is a well known young woman of the parish. A large number of tickets have been sold for the benefit of the poor "Ellen in the Land of Yesterday" that is to be given on Thursday and Friday evenings, April 24th and 25th in the old church. Very likely this will be the last time the old church auditorium will be used for such a purpose, it is expected that the new auditorium will be ready for both evenings. It is being given under the direction of Miss Katherine Burns. St. Bridget's Notes. The fathers of the congregation are preparing for the welfare of Mr. Deacon and for the repose of the soul of Mrs. Edward Hanley. The Confirmation class will receive confirmation on Sunday, May 26th. The first communion class will receive their first communion on Sunday, May 19th. By Rev. G. M. B. A., and the Holy Name Society. Immaculate Conception Parish. Joseph M. Dolan and Mary A. Kelly were married Tuesday morning at 12 o'clock. Jeremiah Murphy and Hannah Driscoll were married Wednesday morning at 10 o'clock. Lynch and Alice McGrath at 8:30. Arrangements are nearly complete for the annual benefit ball and dance of the school which will be held in the hall on Tuesday, May 13. Wm. G. Hughes was buried from this church Thursday morning at 9 o'clock. The second in the series of luncheons given by the several branches of the Royal Sodality of the Holy Name Society was held at the school hall on Thursday evening and was a most highly attended affair. The regular monthly meeting of the Young Ladies Sodality will be held next Tuesday at 4 o'clock. All regularly the leaders are requested to be present. A report on the report on the reunion that will be held next Tuesday evening. Emmet Guards The marriage of Miss Delia Hurley and Michael Murphy of 61 Center St. was celebrated yesterday afternoon at 1 o'clock at the Cathedral. The ceremony was performed by Rev. J. O'Hara. The bride was a blue traveling suit and a white picture hat and the groom a blue suit. She was attended by her sister Anna Hurley who was in blue and the bridegroom's sister in blue. After the ceremony the wedding dinner was served in the home of the bride's parents. Mr. and Mrs. Murphy will spend their honeymoon in New York visiting friends and old friends instead. It will be a trip never to be forgotten because of the beauty spots of the Emerald Isle, principally the Lakes of Killarney, the mountains of Dublin and Cork, the vales of Wicklow and many other places of interest. They will go to Ireland to this place where they make their home. The Emmet Guards wish the happy couple and extend to them their best wishes for a fair voyage, a pleasant honeymoon and a long and happy life. Personal Mr. and Mrs. Weidemiller of Malville St., entertained the Emmet Guard at a dinner party. Mrs. E. J. Ryan and Mr. A. J. Buchanan won the octette rendered by the Emmet Guards. Mrs. August Wirth of Detroit, Michigan, is visiting relatives in this city. Mr. and Mrs. C. Plant of New York are here on their wedding trip. The Forty Hours Devotion will open in this church after the 11:45 mass Sunday. In the event of rain the devotion will be held in the chapel. Miss Teresa Fitzpatrick of Cynon St. is dangerously ill with pneumonia. Rev. S. Fitzsimons presided over the opening of the Forty Hours Devotion at Corpus Christi church last Sunday. The regular monthly meeting of the Holy Name of Mary will be held in the church hall Sunday afternoon at 4 o'clock. The 7 o'clock mass the society will give holy communion in a special and Benediction will be reserved for them. The funeral of Joseph D. Trodt, 100, Young St., was held on Saturday, was held from this church Monday morning at 9:30 o'clock. Solemn requiem was celebrated by Rev. Jos. B. Cameron. He was a member of Does your baking powder contain alum? - Look upon the label. Use only a powder whose label shows it to be made with cream of tartar. NOTE.—Safety lies in buying always the Royal Baking Powder, which is the only baking powder made from Royal grape cream of tartar. Next Sunday being the third Sunday of the month is the time appointed for the taking up of the monthly school collection and the distribution of the gifts of the communion of the ladies of the parish. 68. Peter and Paul. Sunday will be communion day for the members of the Young Ladies' Sodality and the young women of the parish. School collection will be taken up at all the masses on Sunday. The April Sale for the benefit of the church will be held next Thursday, April 24th, 25th, and 26th, at 10 o'clock, at the school, the proceeds to be used for the support of the Young Ladies. A pedlar's garage for the benefit of the church will be held on May 14th, in the basement of the school. The auxiliary No. 44, Knights of St. John, Tickets can be had from the pedlar. The pedlar is Miss Bertha Brayer of Reynolds St., and Mr. Geo. Stand of 100, Young St. Our Lady of Perpetual Help. The requiem mass this week will be for Joseph Wilson, Ed. Gottell, E. Knapp, Joseph Keatley, and the Poor Souls. The funeral of the late Joseph Keller took place from this church Sunday afternoon at 3 o'clock. He was a member of the Knights of St. Michael. Interred at Holy Sepulchre Cemetery. Next Sunday, April 20th, is general election day. The election will be held at the church hall of the John's Beneficent Society at the 7:30 high mass. Every year a solemnly looking ward to the Mission, which is to be conducted by the Capuchin Fathers, second ones given by this order of priests, will be held in this city from the 4th day of May, Sunday, to and including May 17th. Sunday May 4th, will be first communion day for the eligible children of the parish. ST. MARY'S. The Forty Hours Devotion will open in this church after the 11:45 mass Sunday. In the event of rain the devotion will be held in the chapel. Miss Teresa Fitzpatrick of Cynon St. is dangerously ill with pneumonia. Rev. S. Fitzsimons presided over the opening of the Forty Hours Devotion at Corpus Christi church last Sunday. The regular monthly meeting of the Holy Name of Mary will be held in the church hall Sunday afternoon at 4 o'clock. The 7 o'clock mass the society will give holy communion in a special and Benediction will be reserved for them. The funeral of Joseph D. Trodt, 100, Young St., was held on Saturday, was held from this church Monday morning at 9:30 o'clock. Solemn requiem was celebrated by Rev. Jos. B. Cameron. He was a member of Men's Overalls Men's Furnishing Section. Business is booming over excellent sales in men's clothing. Strong blue denim, creased, $1.50; wide leg, detachable suspenders, $1.50; straps, seven pockets, faded jeans, $1.50; tones. Coats to match, with five pockets and double buttons, close-fitting collar, and suitable garments may also be had in dark grey. Sizes 32 to 42, for $1.50 each. Sizes 44 to 52, for $1.25 a garment. We have some very good overalls in plain blue, black and white, and in hickory and striped patterns. They are all double stitched, cut very full—splendid value at 59c each. DURING ALTERATIONS BUSINESS WILL GO ON AS USUAL. When "Alterations" are completed we will have a greater store of material to meet the demands for the Guggenheim's services, quality hair goods and ornaments. Guggenheim's Hair Store 17 Clinton Avenue South Opposite Hotel Seneca Standard Bicycles Every name stands for quality and recognized value. Columbia, Chicago, Excelsior, Rambler, Prince, $25 to $75. Boys' and Girls', $15 to $35. Everything in supplies for bicycles and motorcycles. The Geo. L. Miner Co. Clinton Ave. S., cor. Court St. Home 1288. Bell 3171. UNDERWEAR April's here and it's time to change. Our stock includes the best makes. Yale and Coopers UNION SUITS in light and medium weights. Price range from $1 to $4.50 a suit. Every suit...we sell...will give satisfaction whatever price you pay for it. WILCOX & YOUNGS INC. 63 East Main Street Use Best East of Democrat & Chronicle Do You Want to Look Old? Of course you do not, then why wear old-fashioned gowns. We have all the latest styles in Lenses and Mountings and invite your call. TWO STORES E. E. BAUSCH & SON Opticians Optometrists 6 MAIN STREET EAST and 17 EAST AVENUE H. W. MILKE High Grade Bicycles and Supplies Automobile and Bicycle Repairing and Supplies. Original Doll Hospital 312 Clinton Ave. Good Tailoring is in Good Making, it needs no fancy workmanship. We have a large stock of materials and can supply any order. We take orders for suits, coats, overcoats, etc., and can make any size. We also make collars, cuffs, vests, etc., and can supply any order. We also make collars, cuffs, vests, etc., and can supply any order. Savoy Tailor 2 Central Avenue, three doors toward the West. We have a large stock of materials and can supply any order. We also make collars, cuffs, vests, etc., and can supply any order. We also make collars, cuffs, vests, etc., and can supply any order. 230 West Ave. MUNICH'S Special Offer to First Communicants With the purchase of each 5¢ Prayer Book we give a Scapular Medal and Chain or a Pearl Rosary. Call and see the line of Prayer Books, Gold and Silver Chain Rosaries, Pins, Brooches, Medallions, Locks, etc., etc., suitable for First Communion Gifts at Trant's Catholic Supply Store 10 Clinton Ave. South, Upstairs. LET US TAKE YOUR BABY Our Ground Floor Studio is beautifully equipped and is the most perfect at lowest prices. We take your baby pictures and give an 8x10 enlargement with one-half dozen prints. If your portrait on a post card you will save 2 for free. Sizes, 5x7, 6x8, 8x10, 10x12, 12x16, 16x20. We also take mouldings, sheet and framed art pictures, post cards, the above sizes, and canvas paintings. We also take portraits of pets, children, and cannot supply any order. Pictures framed in sizes. 230 West Ave. MUNICH'S	<urn:uuid:2bb182b9-9124-4dc7-af6d-259a7198be36>	CC-MAIN-2017-30	http://lib.catholiccourier.com/1911-december-1915-august-catholic-journal/catholic-journal-1911-december-1915-august%20-%200565.pdf	2017-07-28T02:50:20Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-30/segments/1500549436321.71/warc/CC-MAIN-20170728022449-20170728042449-00540.warc.gz	195,926,990	3,088	eng_Latn	eng_Latn	0.998272	eng_Latn	0.998272	[ "eng_Latn" ]	false	docling	[ 12673 ]
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APPLICATION FORM FOR BURSARY AND HOSTEL ACCOMMODATION GRADES 10, 11 AND 12 Please note the following regarding applications: * Applications are welcomed from Grade 9 students ONLY for Grade 10 the following year. You cannot apply to enter the programme in any other grade as this is a three year programme which starts in Grade 10. * All applicants for boarding are required to take all three maritime subjects – Maritime Economics, Marine Sciences and Nautical Sciences, as well as both Mathematics and Physical Science. * The Centre is totally non-racial and the courses are available to young South Africans who meet the entry requirements (space permitting). - The applicant must also be of the appropriate age for Grade 10, i.e. between 14 and 16 years on 1 January of the year that he/she will enter Grade 10. - A minimum 60% pass in Mathematics, Physical Science and English in Grade 9 is required. * A certified copy of the student's Grade 9 Term Two report needs to be provided ASAP. * Foreign students (eg Namibian) should preferably have English and Afrikaans as their two main languages. - Because of the high standards of discipline at the STS Lawhill Maritime Centre, the applicant must provide a behavioural and academic reference from his/her present school principal. 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I/We also agree to abide by the conditions of the bursary should one be awarded. ________________________ _______________________ Signature (Father/Guardian) Signature (Mother/Guardian) Date of Application: _______________________ ATTACHMENTS - COMPULSORY The following MUST BE provided in order for this BURSARY application to be processed – INCOMPLETE APPLICATIONS WILL NOT BE CONSIDERED: - a certified copy of student's ID/Unabridged birth certificate - a certified copy of the student's Term 2 school report (and term 1 if results not shown on Term 2 report) - a behavioural and academic reference from the School Principal - Proof of student's community involvement (eg sports clubs; church clubs; youth clubs) - Proof of income ie most recent salary slip (if both parents employed, need both salary slips). If unemployed, proof of unemployment/grant income to be provided. All proof needs to be certified. - A recent, passport sized photograph of the student/applicant PLEASE NOTE – THESE DOCUMENTS MAY ALSO BE REQUIRED FOR THE SIMONS TOWN SCHOOL APPLICATION – PLEASE PROVIDE DUPLICATES AS A DUPLICATE SET OF RECORDS ARE KEPT Enquiries: Email: [email protected] Phone: 021 – 786 2106 (from 08H00-15H00 daily)/Fax: 086 551 7095.	<urn:uuid:1286298f-e159-4a96-a6ba-811b5ba285f0>	CC-MAIN-2024-33	http://www.lawhill.org/wp-content/uploads/2014/09/2020-form-hostel-and-bursary-application.pdf	2024-08-11T13:12:05+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-33/subset=warc/part-00062-4f628544-3cdf-4526-86aa-bdfa0b33cdc9.c000.gz.parquet	47,786,288	1,790	eng_Latn	eng_Latn	0.805846	eng_Latn	0.986474	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 3000, 5527, 8337, 10562 ]
Differential Impact of Uncertainty on Exporting Decision in Risk-averse and Risk-taking Firms: Evidence from Korean Firms 1 Haeng-Sun Kim Most existing literature examining the links between firm heterogeneity and entry into exporting assumes that firms are risk neutral. In this study, we relax this strict assumption that firms are risk neutral and introduce different attitudes of firms toward risk as an additional source of firm heterogeneity. In particular, we examine how risk attitude changes the effect of uncertainty on the decision of a firm to export considering the different types of uncertainty faced by the firm, namely, firm-specific and macroeconomic. Our analysis yields two interesting findings. First, firm-specific uncertainty discourages risk-averse firms from participating in foreign markets more than risk-taking firms. One possible explanation for this finding is that risk-averse firms are more cautious in export market participation when firm-specific uncertainty increases. Second, we find that riskaverse firms are less likely to decrease their export market participation when responding to macroeconomic uncertainty. Thus, risk-averse firms are more likely to diversify their domestic risk by participating in foreign markets in responding to macroeconomic uncertainty. Keywords: Exports, Risk aversion, Uncertainty, Firm heterogeneity JEL Classification: D81, F14, G32 Haeng-Sun Kim, Associate Research Fellow, Korea Institute of Local Finance, Seoul, South Korea. (E-mail): [email protected], (Tel): 02-2071-2753, (Fax): 02-2071-2777. The author acknowledges the support from INCAS project funded by RISE Marie Sklodowska-Curie Actions under the European commission's H2020 Programme. [Seoul Journal of Economics 2016, Vol. 29, No. 3] I. Introduction As the presence of firm heterogeneity is introduced as a new channel to understand international trade, empirical research investigating links between firm heterogeneity and decision to export at the microeconomic level has prominently grown in recent decades. Some of these studies have explored differences in firms' export market participation across firms by combining fixed costs and the presence of firm heterogeneity (Melitz 2003; Greenaway et al. 2007; Chaney 2013). Melitz (2003) has theoretically proved that the presence of firm heterogeneity in terms of productivity and sunk entry costs explains why all firms do not engage in international trading activity. According to his framework, a firm forms expectations about the profitability of entry into exporting when deciding to enter or not. Thus, if expected profits of entry into exporting are high enough to cover its entry cost, then a firm chooses to serve a foreign market on a Melitz-type heterogeneous firm model. If we assume that firms are risk neutral while holding others constant, firms will enter into exporting until expected profits are equal to the entry costs, as shown in Melitz (2003). In reality, however, firms have different attitudes toward risk under uncertainty. Therefore, considering risk attitude of a firm could result in disparity from Melitz's (2003) finding, that is, firms enter into exporting as long as their expected profits are high enough to cover entry costs. For example, risk-averse firms are willing to accept lower expected profits in exchange for less exposure to risk. Conversely, risk-taking firms are willing to have more exposure to risk in exchange for higher expected profits. Greenaway et al. (2007) and Chaney (2013) consider financial dimension as an additional source of firm heterogeneity to understand export market participation. In particular, Chaney (2013) introduces financial constraints into a Melitz-type heterogeneous firm model. He proves that as participation in the international market incurs substantial start-up costs, liquidity-constrained firms face difficulty in financing such costs and consequently are less likely to export. Greenaway et al. (2007) explore the effect of financial health of UK manufacturing firms on their export market participation. Exporting firms in the United Kingdom show better financial health than non-exporting firms. However, as the degree of risk aversion of firms affects heterogeneity in the financial characteristics and exporting decision, direct and indirect effects should be analyzed. Most empirical literature that has examined the links between firm heterogeneity and entry into exporting assumes that firms are risk neutral. This assumption is criticized by Sandmo (1971), who argues that a firm's risk attitude is an important factor affecting its decision making. In particular, he points out that the results derived under the assumption that firms are risk neutral can be less informative. For example, Creusen, and Lejour (2011) find the negative effect of uncertainty on exporting decisions of firms, but they do not consider the risk attitudes of firms in their analysis. However, if a higher (lower) degree of risk aversion of firms negatively affects the exporting decisions of firms under uncertainty, the risk attitudes of firms will ruin the effect of uncertainty on exporting decisions of firms. For this reason, Creusen, and Lejour's (2011) finding in which the effect of uncertainty on the exporting decisions of firms is negative is not that convincing. In this study, we relax the strict assumption that firms are risk neutral and introduce different attitudes of firms toward risk as an additional source of firm heterogeneity. In particular, we examine how risk attitude changes the effect of uncertainty on the decision of a firm to export considering the different types of uncertainty faced by the firm, namely, firm-specific and macroeconomic. For this, we use a panel of 36,530 firm-year observations representing 5,386 Korean firms for the 1991-2011 period. Our basic analysis yields two interesting findings. First, on average, Korean manufacturing firms were risk taking before the Asian financial crisis of 1997 but became risk-averse after the crisis. Second, the effect of uncertainty on a firm's decision to export is negative. This negative effect of uncertainty is consistent with the findings of Creusen, and Lejour (2011). However, unlike Creusen, and Lejour (2011), we explore the relevance of risk attitudes of firms to the export-uncertainty relation. As a result, we obtain evidence that the degree of the negative effect of uncertainty on a firm's exporting decision varies depending on whether the firm is risk averse or risk taking and whether the firm faces firmspecific or macroeconomic uncertainty. For example, we find that the negative effect of firm-specific uncertainty on a firm's export decision is relatively greater in risk-averse firms than in risk-taking firms. Hence, firm-specific uncertainty discourages risk-averse firms from participating in foreign markets more than risk-taking firms. This observation implies that risk-averse firms are more reluctant to begin exporting when firmspecific uncertainty increases. Further, our results show that the degree of the negative effect of macroeconomic uncertainty on a firm's exporting decision is lower in risk-averse firms than in risk-taking firms. That is, risk-averse firms are less likely to decrease their export market participation when macroeconomic uncertainty increases. This empirical evidence suggests that under macroeconomic uncertainty, risk-averse firms are more likely to follow a strategy of market spreading by participating in foreign markets than risk taking firms. The rest of this study is organized as follows. In the following section, we briefly introduce the theoretical background of our empirical analysis. In Section III, we provide details on the data used in this study, the measurement of uncertainty faced by firms, and the measurement of the risk attitude of firms. In Section IV, we present the empirical results. In particular, we examine in Section IV-A how risk attitude changes the effect of uncertainty on the decision of firms to export considering the different types of uncertainty faced by firms. In Section IV-B, we further check the robustness of the results. Finally, Section V concludes. II. Related Literature Review The relationship between firms' different attitudes toward risk and exporting decisions under uncertainty is built on two different strands of literature. The first strand of literature concerns the relationship between investment and uncertainty, particularly how the degree of risk aversion of firms affects the relationship between investment and uncertainty. The second strand is the literature on the relationship between exporting decision and uncertainty of firms. A. Investment and Uncertainty Many studies have attempted to investigate the investment decision of firms under uncertainty. The literature survey in Lensink et al. (2001) shows that although most of the analyses (e.g., 17 papers among 20 empirical studies) find a negative effect of uncertainty on investment, some report a positive effect or even a mixed one. For example, Hartman (1972) and Abel (1983) indicate that the relationship between uncertainty and investment will be positive if the marginal product of capital is convex in the output price. By contrast, Leahy, and Whited (1996) present that greater uncertainty exerts a negative effect on investment. Similar conclusions are drawn from Ghosal, and Loungani (2000), who also find that the effect of uncertainty on investment is negative. In particular, they find the effect to be relatively greater in industries dominated by small firms. Interestingly, Huizinga (1993) reveals mixed results that price uncertainty is a negative determinant of investment, whereas wage and material cost uncertainty have a positive effect. To sum up, no explicit conclusions can be derived on whether the effect of uncertainty on investment is negative or positive. Moreover, these studies do not clearly agree on which channel uncertainty affects investment. Different channels are identified, namely, (1) convexity of the marginal product of capital (Hartman 1972; Abel 1983), (2) substitutability of production factors (Leahy, and Whited 1996), (3) financial constraints (Ghosal, and Loungani 2000), and (4) firms' attitudes toward risk (Zeira 1990; Nakamura 1999). Many of these studies share a common trait: they assume that a firm is risk neutral except the last case. As this study focuses on exploring how risk attitude changes the effect of uncertainty on firms' decision to export, we review the related literature. Zeira (1990), Nakamura (1999), and Bo, and Sterken (2007) investigate the effects of the degree of risk aversion on the relationship between investment and uncertainty. Zeira (1990) analyzes how the degree of risk aversion of firms affects the investment decision of a firm under wage rate uncertainty. His framework proves that uncertainty has a different effect on investment. On the one hand, uncertainty decreases investment through the concavity of the utility function representing the degree of risk aversion of the firm; on the other hand, uncertainty increases investment through the convexity of the profit function. Thus, the net effect of uncertainty on investment depends on the trade-off between the degree of risk aversion of the firm and the convexity of the profit function. Similar to Zeira (1990), Nakamura (1999) finds that the effect of output price uncertainty on investment changes depending on the degree of risk aversion of firms and the elasticity of output to labor in a production function. Bo, and Sterken (2007) examine how firms' risk attitude affects the impact of demand uncertainty on fixed investment. They find that risk-averse firms decrease investment in the presence of demand uncertainty, whereas risk-taking firms increase investment in the same situation. B. Exporting Decisions and Uncertainty The discussion is limited to investment studies. The export decision is akin to an investment decision in some aspects. These two decisions are independent of firm behavior in the domestic market and require a firm to bear the sunk costs regarding their decisions. Thus, we can regard export decision as an investment decision. The second strand is drawn from the literature on firms' exporting decision under uncertainty (e.g., Creusen, and Lejour 2011; Greenaway et al. 2010; Segura-Cayuela, and Vilarrubia 2008). Creusen, and Lejour (2011) investigate the exporting decisions of firms under uncertainty by using Dutch firm-level data. They find that more uncertainty reduces the probability of firms entering the export market. Segura-Cayuela, and Vilarrubia (2008) reveal that the most productive firms do not always enter the export market in the presence of market size uncertainty. Most studies have focused on export market entry and exit decisions under different kinds of uncertainty. However, Greenaway et al. (2010) explore the effect of exchange rate uncertainty on export market participation and export intensity of UK manufacturing firms. They find that exchange rate uncertainty is insignificant in explaining entry into export markets but is positively associated with export intensity. The above mentioned studies have introduced different kinds of uncertainties and have identified the relationship between firms' exporting decision and uncertainty. However, the channels through which uncertainty can affect a firm's exporting decision have not been analyzed much in these studies. Thus, we introduce firms' different attitudes toward risk as a channel through which uncertainty can affect exporting decision. Then, we examine how risk attitude changes the effect of uncertainty on a firm's decision to export by considering firm-specific and macroeconomic uncertainty. Before initiating the empirical analysis, we hypothesize the following: Hypothesis 1. The effect of uncertainty on firms' exporting decision is negative. Hypothesis 2. Risk attitude changes the effect of uncertainty on firms' exporting decision. Hypothesis 3. Firm-specific or macroeconomic uncertainty has a different role in firms' exporting decision between risk-averse and risk-taking firms. To the best of our knowledge, no study has investigated the relationship between risk attitudes and export market participation under uncertainty. Thus, this paper contributes to the literature on firms' exporting decision under uncertainty. III. Data and Methodology In this section, we provide details on the data used in this study and the measurement of uncertainty and risk attitude of the firm. A. Data Description Our main source of data is the KIS database compiled by the Korea Information Service, Inc. (KIS), which is one of Korea's major credit-rating agencies. The KIS database provides corporate and financial information on all publicly listed Korean firms or on those with a total asset of 7 billion won 1 or more. However, this study only uses manufacturing firm data with a December fiscal year end. We restrict our analysis to surviving firms 2 only because the KIS database does not provide information on closed firms. We focus on the 1991-2011 sample period as we consider the effect of the Asian financial crisis of 1997. To control for the potential influence of outliers, we exclude firms that declared negative values for total assets and total sales. 3 We also exclude observations in the top and bottom 1 percent of the sample in terms of total assets, total sales, and number of employees. These cut-offs aim to eliminate coding errors or extraordinary firm shocks. In addition, we drop from the analysis firms that have any missing observations for our variables of interest. Accordingly, the final data set we obtain is an unbalanced panel structure of 36,530 firm-year observations representing 5,386 Korean firms for the 1991-2011 period (See Appendix Table 1 for details about the structure of our unbalanced panel). All values utilized in the analysis have been converted into real values using the aggregate gross domestic product (GDP) deflator with a base year of 2005. Table 1 provides descriptive statistics for the relevant variables by export status. 4 In particular, the table reports the mean, median, 1 For a better understanding of the threshold of 7 billion won, we introduce the criteria of Korean small and medium enterprises (SMEs). According to "Article 2 of Framework Act on SMEs" and "Article 3 of Enforcement Decree of the Act," Korean SMEs in the manufacturing industry are defined as firms with a capital of 8 billion won or less or with a number of employees of fewer than 300. 2 Surviving firms are those that exist as of the date we obtained the data (April 13, 2013) after the entry into the market. 3 We drop one observation for total assets and two observations for total sales. standard deviation, minimum and maximum for each variable. Exporters are on average larger than non-exporters in terms of total assets, total sales, and number of employees (e.g., Bernard, and Jensen (2001) for the United States; Greenaway et al. (2007) for the United Kingdom). The same pattern also holds true in our results. We observe that exporting firms are on average larger than firms producing only for domestic markets over the whole-period sample (1991-2011), pre-crisis sample (1991-1997), and post-crisis sample (1998-2011). Moreover, total assets, total sales, and number of employees, which are generally used as indicators of size in the literature, are more volatile for exporting firms than for non-exporting firms. Labor productivity is defined as the ratio of total sales to the number of employees. Our results show that productivity of exporting firms is higher and less volatile for exporting firms than for non-exporting firms. Firm profit is calculated as the difference between sales and cost of goods sold. Exporting firms are on average more profitable than non-exporting firms. In addition, profits of exporting firms are more variable than those of non-exporting firms during the whole-period (1991-2011), pre-crisis (1991-1997), and postcrisis sample (1998-2011). Panels B and C of Table 1 compare various firm characteristics between exporters and non-exporters during the periods before and after the Korean financial crisis. Overall, our findings show that labor productivity of Korean manufacturing firms improved after the 1997 financial crisis. However, against our expectation, firms are on average larger and more profitable before the Asian financial crisis of 1997 than after the crisis. However, the decrease in the mean of firm size or firm profitability over time is not surprising given that this study is based on information only for surviving firms. Firms surviving in the long-term are likely to be larger or more profitable on average, and the inclusion of relatively small firms over time will obviously decrease the mean of firm size or firm profitability. Finally, the extent to which our sample of firms is representative of the Korean manufacturing firms should be considered. As our empirical work pertains mainly to firm heterogeneity at the micro level, findings from this study may not be generalizable if our sample of firms does not exhibit the entire manufacturing firms in South Korea. To address 4 Based on the export sales, firms are classified into exporting and nonexporting. We define a firm that shows a positive export sale as an exporting firm. this concern, Appendix Figure B.1-(a) compares the sales growth of our sample of firms with that 5 of aggregate manufacturing firms in South Korea. Appendix Figure B.1-(b) compares the employment growth of our sample of firms with that 6 of all Korean manufacturing firms with more than 10 employees. We observe similar patterns for sales and employment growth as shown in Appendix Figures 1-(a) and (b). This result suggests that our sample of firms is reflective of aggregate manufacturing firms in South Korea. B. Measuring Uncertainty Bo, and Sterken (2007) empirically analyze the effect of the risk attitudes of firms on the investment-uncertainty relationship. In this study, we investigate how risk attitude changes the effect of uncertainty on decision to export by extending the model of Bo, and Sterken (2007). Our specification is largely similar to that of Bo, and Sterken (2007), but we consider two sources of uncertainty, namely, firm-specific and macroeconomic. In the following section, we describe the construction of empirical proxies for firm-specific and macroeconomic uncertainties. Identifying Firm-specific Uncertainty Several studies analyzing the effects of uncertainty on firm behavior implement different approaches to construct a proxy for firm-specific uncertainty. For example, Leahy, and Whited (1996), Bloom et al. (2001), Bond, and Cummins (2004), and Lee (2005) measure firm-level uncertainty by computing the standard deviation of individual daily stock returns. Baum et al. (2009) proxy for firm-specific uncertainty from the volatility of closing price for firms' shares. However, most studies cited above have focused only on publicly listed firms. Given that the focus of this study is on both publicly listed and unlisted firms, we measure firm-specific uncertainty by regressing firm sales on the firm effect (φ i) and the time effect (φ t): where Salesi,t is the firm sales scaled by total assets, and φ i,t is the error term. φ i and φ t represent firm and year fixed-effects, respectively. We estimate Equation (1) firm by firm based on the original data set for the 1991-2011 period. The absolute value of residuals from this regres- 5 Data come from the aggregate balance sheet of manufacturing firms reported in the Bank of Korea, Financial Statement Analysis. 6 Obtained from the Korea National Statistics Office. sion, σ i,t firm =\|φ i,t\|, is used to measure firm-specific uncertainty. This procedure is similar to that of Morgan et al. (2004) and Caglay, and Rashid (2014). Identifying Macroeconomic Uncertainty One can employ different methodologies to construct a proxy for macroeconomic uncertainty. For instance, Driver et al. (2005), Baum et al. (2009), and Baum et al. (2012) use conditional variance obtained from a GARCH model to measure macroeconomic uncertainty. Federer (1993) and Huizinga (1993) obtain a measure of macroeconomic uncertainty from moving standard deviations of past changes in inflation. Graham, and Harvey (2001) and Kaufmann et al. (2005) use survey data for a measure of macroeconomic uncertainty. However, the disadvantages of the proxy for macroeconomic uncertainty from the moving standard deviations of the macroeconomic series or from the survey data are that the former may have a serial correlation problem and the latter is subject to measurement error. Thus, we build a GARCH (1, 1) model in which the mean equation is a first-order autoregression to proxy for macroeconomic uncertainty, following Driver et al. (2005), Baum et al. (2009), and Baum et al. (2012). For this, we use the quarterly series of real GDP growth 7 from the first quarter of 1971 to the fourth quarter of 2013 and the monthly series of changes in the index 8 of leading indicators from January 1990 to June 2014. The results of the GARCH (1,1) estimation for each series are reported in Table 2. The conditional variances obtained from this GRACH specification are annualized by averaging over 4 quarters for the GDP and over 12 months for the index of leading indicators and then used as proxies for macroeconomic uncertainty(e.g., σ i G ,t DP , σ i, L t I ). To ascertain that these measures (σ i G ,t DP , σ i, L t I ) are different from a proxy for firm-specific uncertainty, we examine the correlations between firm-specific and macroeconomic uncertainty. As shown in Table 3, correlation coefficients are very low. This observation implies that each measure captures different aspects of uncertainty faced by a firm. In addition, Appendix Figure 2 shows the evolution of macroeconomic and firm-specific uncertainty obtained by the analysis. Macroeconomic uncertainty has a similar trend to firm-specific uncertainty except in the 2003-2005 period. In particular, South Korea experienced substantial 7 Information comes from the Bank of Korea, and 2005 is used as the base year. 8 Obtained from Korea National Statistics Office. TABLE 2 GARCH (1, 1) PROXIES FOR MACROECONOMIC UNCERTAINTY Notes: OPG standard errors are reported in parentheses. * indicates significance at the 10% level. indicates significance at the 5% level. * indicates significance at the 1% level. TABLE 3 CORRELATIONS OF PROXIES FOR FIRM-SPECIFIC AND MACROECONOMIC UNCERTAINTY increases in both macroeconomic uncertainty and firm-specific uncertainty during the Asian financial crisis of 1997-1998 or during the global financial crisis of 2008-2009. However, macroeconomic uncertainty gradually decreased while firm-specific uncertainty suddenly increased in 2003. One possible explanation for this finding is that the credit card crisis that South Korea experienced in 2003 remarkably increased firmspecific uncertainty. C. Measuring Risk Attitude of Firms We have so far measured firm-specific and macroeconomic uncertainty. In this section, we present details on the measurement of the risk attitude of firms. Given that the empirical literature on the risk attitude of firms in decision making is relatively scant, the challenge for this study is to construct an appropriate proxy. Pattillo, and Soderbom (2000) measure the risk attitudes of firm managers using experimental data. These experimental data are obtained by asking firm managers to choose from lotteries with different expected returns and variances, in which higher returns can be traded off with higher variances. However, their findings from experimental data are somewhat less conclusive as the study does not control for other demographic factors that may affect decision making. Another alternative for measuring the risk attitudes of firms is to use survey data. However, as Binswanger (1980) points out, resurveying of respondents is subject to measurement error and unstable results. To alleviate such concerns, we apply an econometric procedure for the estimation of risk attitudes of firms by following Fisher, and Hall (1969), Arrow (1971), or Bo, and Sterken (2007). Fisher, and Hall (1969) show that the risk premium of the firm can be estimated by using the standard deviation and the skewness of distribution of firms' profit. The theoretical work of Arrow (1971) indicates that the risk attitude of firms can be measured if the risk premium of firms is estimated. To measure the risk premium of firms, we first follow the framework of Fisher, and Hall (1969) and estimate the following form: where γ i,t＝observed profit scaled by total assets for firm i, year t; σ i,t＝standard deviation of the profit rate for firm i, year t; and ω i,t＝skewness of the profit rate for firm i, year t. The standard deviation (σ i,t) and the skewness (ω i,t) of the profit rate are calculated from the previous three years of profit rate. Thus, the standard deviation and the skewness of the profit rate are saved for the 1993-2011 period. The intercept, γ 0, is referred to as the risk-adjusted profit rate that reflects all influences on firms' profit not explained by the standard deviation and the skewness. In the analytical framework of Fisher, and Hall (1969), the risk premium of firms is computed as the difference between the observed profit and the risk-adjusted profit rate. To compute the time-varying measures of the risk premium of firms, we estimate Equation (2) over three-year rolling time periods for each firm. Thus, two observations are lost in each firm, and the longest time TABLE 4 MEAN OF RISK ATTITUDES ACROSS FIRMS Notes: Fractions of risk-averse and risk-taking firms are reported in parentheses. Firms are classified as large-sized (small- and medium-sized) firms if their number of employees is more (fewer) than 300. series of the risk premium of the firm is 1995-2011. This estimation is based on the data set excluding the outliers of the upper and lower 1 percent of profits. If the risk premium of firms is obtained from Equation (2), we then measure the risk attitudes of firms following the framework of Bo, and Sterken (2007), which transforms the theoretical model of Arrow (1971) into an empirical model. Thus, we estimate 9 the risk premium regression of the following form: 9 To compute the time-varying measures of the risk attitude of firms, we estimate Equation (3) over three-year rolling time-periods for each firm. where γ i, * t ＝ risk premium firm i , year t ; η ＝risk aversion coefficient of the firm. σ i,t＝standard deviation of the profit rate for firm i, year t; and ω i,t＝skewness of the profit rate for firm i, year t. In Equation (3), the estimated coefficient of the standard deviation of the profit rate (η ) implies the measure of absolute risk aversion of firms. We employ the risk coefficient as a proxy for the risk attitude of firms. The utility theory of Arrow (1971) predicts that firms are more risk averse when the risk coefficient is higher, and that firms with a positive risk coefficient are risk averse (η ＞0) while firms with a negative risk coefficient are risk taking (η ＜0). To observe the change in risk attitude of firms before and after the Asian financial crisis, we compare the mean of the risk coefficients across firms and document the results in Table 4. Two patterns in particular stand out. First, Korean manufacturing firms before the Asian financial crisis of 1997 were on average risk taking but became risk averse after the crisis. The same pattern holds for exporting firms and non-exporting firms. This behavior is consistent with the evidence that after the crisis, the ratio of risk-averse firms to total firms is increased, while the ratio of risk-taking firms to total firms is decreased as shown in Panel B of Table 4. These findings imply that the financial crisis of 1997 affected the risk attitudes of firms. The second feature emerges in Panel C of Table 4. If we compare the mean of risk coefficients between large-sized firms and small- and medium-sized firms, large-sized firms during the sample period were on average risk averse, while small- and medium-sized firms changed from risk taking to risk averse during the periods before and after the financial crisis of 1997. Hence, a larger portion of the risk-taking firms before the crisis was small- and-medium-sized firms. Particularly, small and-medium-sized firms in South Korea tended to take more risks than large firms. Appendix Figure 3 presents the details on the distribution of risk coefficients during whole-period sample (1991-2011), pre-crisis sample (1991-1997), and post-crisis sample (1998-2011). IV. Empirical Results In this section, we explore how risk attitude changes the effect of uncertainty on the decision of firms to export by considering different types of uncertainty faced by the firm. For this aim, we first estimate a model by using dummy variables of risk attitudes of firms with full sample data. For robustness checks, we further divide the sample into risk-averse and risk-taking firms according to the risk coefficient sign and examine how firm-specific or macro-economic uncertainty plays a different role between risk-averse and risk-taking firms. A. Differential Effect of Uncertainty across Risk-Averse and RiskTaking Firms We test the hypothesis that both uncertainty and the risk attitudes of firms have important effects on firm decisions to export by extending the model of Bo, and Sterken (2007). Bo, and Sterken (2007) analyze the effect of risk attitudes of firms on the investment-uncertainty relationship, but they focus only on firm-specific uncertainty. However, our study simultaneously considers firm-specific and macroeconomic uncertainty. To examine how the effect of uncertainty on the decisions of firms to export varies with their risk attitudes, we set up two dummy variables for risk-averse firms (D risk-averse ) and risk-taking firms (D risk-taking ), and then interact all the proxies of uncertainty with these two dummy variables. The risk-averse dummy takes the value of 1 for firms with a positive risk coefficient and 0 otherwise. The risk-taking dummy takes the value of 1 for firms with a negative risk coefficient and 0 otherwise. Specifically, we estimate with the following pooled probit specification: The first subscript i denotes a firm, and the second subscript t denotes time. The dependent variable of this estimation is the exporting status of firms. Hence, EXPDUMit is a binary indicator variable equal to 1 for firms that are exporters. To control for firm characteristics, we include variables such as firm size and labor productivity. Firm size and labor productivity are measured as the log of the number of employees and the log of the ratio of total sales to the number of employees, respectively. σ firm and α macro indicate the measurement of firm-specific and macro-economic uncertainty faced by a firm. D risk-averse denotes a dummy variable for risk-averse firms, and D risk-taking denotes a dummy variable for risk-taking firms. Industry dummies 10 and time dummies are included to capture time- and industry-specific effects on the decision of firms to export. As for all control variables, we use values from one year before the firm decides to export. We consider the time difference between the export market participation decision and the actual participation by following previous studies (e.g., Bernard, and Jensen 2001; Greenaway et al., 2007). We also consider the effect of the Asian financial crisis of 1997 that significantly affected the South Korean economy and particularly the risk behavior of Korean firms. Consistent with the findings in Table 4, changes in the risk attitudes of Korean manufacturing firms are observed after the Asian financial crisis of 1997. Thus, to determine if the effect of risk attitudes on firms' exporting decision has changed since the Asian financial crisis of 1997, we divide the sample into two subsamples: pre-crisis sample of 1991-1997 and post-crisis sample of 19982011. The results for the whole sample period of 1991-2011 and for the two sub-periods of 1991-1997 and 1998-2011 are presented in Table 5. Table 5 also presents the results for models that use two proxies for macroeconomic uncertainty. These proxies are based on the GDP or on the leading indicators (e.g., σ i, G t DP , σ i, L t I ) during the whole sample period of 1991-2011 and during the two sub-periods of 1991-2011 (e.g., 1991-1997 and 1998-2011). Specifically, columns 1 and 2 of Table 5 report the results for the whole sample period. Our key findings indicate that the effect of uncertainty on the decision of firms to export is negative. Further, the degree of the negative effect of uncertainty on the exporting decision of firms varies depending on whether firms are risk averse or risk taking and whether firms face firm-specific or macroeconomic uncertainty. For example, if firms face firm-specific or macroeconomic uncertainty (measured by either proxy), then the uncertainty lowers the export market participation of firms. However, the negative effect of firm-specific uncertainty is greater in risk-averse firms, while the quantitative negative effect of macroeconomic uncertainty is lesser in risk-averse firms. The former means that firm-specific uncertainty discourages risk-averse firms from participating in foreign markets more than risk-taking firms. Hence, risk-averse firms are more cautious when responding to firm-specific 10 Industries are classified into 24 two-digit sectors based on the Korea Standard Industrial Classification (KSIC version 9). TABLE 5 RISK ATTITUDES AND EXPORT MARKET PARTICIPATION Notes: Robust standard errors are reported in parentheses In all specification, we include 21 yearly dummies and 24 industry dummies to capture time and industry effects, but they are not reported. * indicates significance at the 10% level. indicates significance at the 5% level. * indicates significance at the 1% level. uncertainty. The latter means that risk-averse firms are less likely to decrease their export market participation when responding to macroeconomic uncertainty. Therefore, risk-averse firms are more likely to diversify their domestic risk by participating in foreign markets in response to macroeconomic uncertainty. Columns 5 and 6 of Table 5 report the estimation results in the postcrisis sample. These results are broadly consistent with those in columns 1 and 2 of Table 5, that is, firm-specific or macroeconomic uncertainty has a statistically different effect on the exporting decision of firms depending on whether firms are risk averse or risk taking. However, in the pre-crisis sample, no significant coefficients are estimated regardless of whether proxies for macroeconomic uncertainty are based on the GDP or based on leading indicators. On the one hand, this behavior could imply that before the financial crisis, firms decide on exporting without sufficient risk consideration under uncertainty. On the other hand, we do not find any evidence that risk attitude changes the effect of uncertainty on the decision of firms to export before the financial crisis simply because of data limitation. 11 In addition, we examine how risk attitude changes the effect of uncertainty on export intensity of firms. The export intensity of firms is measured as the share of exports in total sales and is used as the log of the export intensity of firms in regression. As reported in Appendix Table 2, this result is generally consistent with that of Greenaway et al. (2010) that uncertainty has a significant positive effect on the export share of firms. B. Results for the Sub-samples of Firms: Risk-averse and Risk-taking Firms For robustness checks, we run the regression separately for the sample of risk-averse firms and risk-taking firms to examine if the effects of firm-specific uncertainty on the decision of firms to export differ across risk-averse and risk-taking firms. Thus, we divide the sample into risk-averse and risk-taking firms according to the sign of the risk coefficient in the whole, pre-crisis, and post-crisis periods. For example, firms with a positive risk coefficient are classified as risk-averse firms, as mentioned in Section Ⅲ-C. Likewise, firms with a negative risk coefficient are classified as risk-taking firms. As the first step, we estimate the following for the whole sample: The results for the whole sample are reported in Table 6. Specifically, 11 As stated in Section Ⅲ-C, the first two observations are lost for each firm in constructing the standard deviation and the skewness of the profit rate. The next two observations are lost for each firm to compute the time-varying measures of the risk attitudes of firms. Therefore, the longest time series of the risk at attitudes of firms is 1995-2011. TABLE 6 WHOLE SAMPLE Notes: Robust standard errors are reported in parentheses. In all specification, we include 21 yearly dummies and 24 industry dummies to capture the time and industry effects, but they are not reported. * indicates significance at the 10% level. indicates significance at the 5% level. * indicates significance at the 1% level. columns 1 and 2, columns 3 and 4, and columns 5 and 6 of Table 7 show that Korean manufacturing firms decrease their export market participation when firm-specific or macroeconomic uncertainty increases over the whole period and the two sub-periods of pre-crisis and postcrisis. This negative effect of uncertainty on the exporting decision of firms is consistent with the findings of Creusen, and Lejour (2011). Next, we examine how firm-specific or macroeconomic uncertainty plays a different role between risk-averse and risk-taking firms. For this purpose, we estimate the same regression equation for each sub-sample as in Table 6. The results for risk-averse firms and risk-taking firms are shown in columns 1-6 and columns 7-12 of Table 7, respectively. Consistent with our earlier findings, Table 7 shows that firm-specific uncertainty or macro-economic uncertainty lowers the export market participation of firms in the whole and post-crisis periods. Particularly, if we compare the negative effect of firm-specific uncertainty on firms' export decision between risk-averse and risk-taking firms, the negative effect is relatively more in risk-averse firms than in risk-taking firms (e.g., -0.214 vs. -0.200 for the whole period and -0.214 vs. -0.207 for the post-crisis period). This result implies that risk-averse firms are more cautious in export market participation when firm-specific uncertainty increases. Similarly, our results show that the degree of negative effect of macroeconomic uncertainty on firms' exporting decision is lower in risk-averse firms (e.g., -0.106 vs. -0.124 for the whole period and -0.105 vs. -0.123 for the post-crisis period) in the whole and post-crisis periods. This empirical evidence suggests that under macroeconomic uncertainty, riskaverse firms are more likely to follow a strategy of market spreading by participating in foreign markets than risk-taking firms. In addition, the coefficients on uncertainty for each sub-sample are statistically insignificant during the pre-crisis period. This evidence implies that either Korean firms decide on exporting without sufficient risk consideration before the financial crisis or that any significant evidence is not found because of data limitation. The insignificant relationship between risk attitudes and export market participation is possible during the pre-crisis sample because of data limitation. Nevertheless, a more convincing explanation for this result is that during the period of high economic growth before the financial crisis of 1997, Korean firms decided on exporting without sufficient risk consideration. In fact, before the financial crisis, the Korean government encouraged firms to invest more in export-oriented industries by providing loans at a low interest rate. Therefore, Korean firms before the financial crisis were generally viewed to have decided on exporting without sufficient risk consideration. However, the Asian financial crisis of 1997 significantly affected the South Korean economy, particularly the risk management of Korean firms. As Korean firms showed low risk-endurance ability under the currency crisis of 1997, the Korean government needed to reform the corporate governance system after the crisis. Thus, the Korean government introduced several measures to improve the corporate governance system (e.g., Cha 1999; Chang, and Shin 2002). As a result, corporate restructuring after the financial crisis could have led Korean firms to decide on exporting in a more risk-averse way. This claim is consistent with the finding that the relationship between uncertainty and firms' exporting decision is statistically significant for the post-crisis sample as shown in columns 5-6 and columns 11-12 of Table 7. V. Conclusions Most existing literature examining the links between firm heterogeneity and entry into exporting rests on the assumption that firms are risk neutral. In this study, we argue that previous studies neglect the effect of the risk attitude of firms on the export-uncertainty relationship, and that such risk attitude plays an important role in explaining this relationship. Thus, we relax this strict assumption and introduce firms' different attitudes toward risk as an additional source of firm heterogeneity. We examine the effects of uncertainty on exporting decisions of firms differing across risk-averse and risk-taking firms based on an unbalanced panel of 5,386 Korean manufacturing firms from 1991 to 2011. Our analysis yields interesting findings. First, we find that the effect of uncertainty on firms' decision to export is generally negative. This negative effect of uncertainty on a firm's exporting decision is consistent with the findings of Creusen, and Lejour (2011). However, different from Creusen, and Lejour (2011), we explore the export-uncertainty relation by considering the risk attitude of firms. The results show that the degree of the negative impact of uncertainty on a firm's exporting decision depends on whether the firm is risk averse or risk taking and whether the firm faces firm-specific or macroeconomic uncertainty. Specifically, we obtain evidence that firm-specific uncertainty discourages risk-averse firms from participating in foreign markets more than risk-taking firms. This finding implies that risk-averse firms are more reluctant to begin exporting when firm-specific uncertainty increases. We also find that risk-averse firms are less likely to decrease their export market participation when macroeconomic uncertainty increases. This empirical evidence suggests that risk-averse firms are more likely to diversify their domestic risk by participating in foreign markets when macroeconomic uncertainty increases. The results of this study should be interpreted with some caveats in mind. First, discussions on the different channels through which uncertainty can affect a firm's exporting decision remain scant. Therefore, an open question of whether these channels are adequately identified in the analysis remains. Second, the challenge for this study is to construct an appropriate proxy for the risk attitude of a firm. We measure risk attitude by applying an econometric procedure for the estimation of firms' risk attitude following Fisher, and Hall (1969), Arrow (1971), or Bo, and Sterken (2007). To obtain more complete and robust results, various criteria should be introduced to assess if a proxy for firms' risk attitude is appropriate. Despite these limitations, this study contributes to the literature in two ways. First, firms' risk attitude is introduced as an additional source of firm heterogeneity for the better understanding of the exporting decision of firms. Second, this study considers the firm-specific and macroeconomic uncertainty of firms. Given that firms simultaneously face internal and external uncertainty, this approach seems to be in reasonable accord with the real world. (Received 16 October 2015; Revised 25 January 2016; Accepted 3 February 2016) Appendix A. DATA SET PPENDIX A T ABLE 1 S TRUCTURE OF THE U NBALANCED P ANEL APPENDIX TABLE 2 RISK ATTITUDES AND EXPORT INTENSITY WITH GLS Notes: The dependent variable used in the regression analysis is the share of exports in total sales. We analyze it using the Generalized Least Squares (GLS). Robust standard errors are reported in parentheses. In all specification, we include 21 yearly dummies and 24 industry dummies to capture the time and industry effects, but they are not reported. * indicates significance at the 10% level. indicates significance at the 5% level. * indicates significance at the 1% level. B. Figures Source: Aggregate Data is from Bank of Korea and Firm-level Data is from KIS (a) Firm Sales Growth (Annual, %) Source: Aggregate Data is from the Korea National Statistics Office and Firmlevel Data is from KIS (b) Firm Employment Growth (Annual, %) APPENDIX FIGURE 1 AGGREGATE AND FIRM-LEVEL DATA UNCERTAINTY, RISK ATTITUDE, AND EXPORTING DECISION 405 Source: Firm-specific and Macroeconomic Uncertainty is from KIS; it is the author's calculations. APPENDIX FIGURE 2 IRM F -S PECIFIC AND M ACROECONOMIC U NCERTAINTY (a) Whole-Period Sample (1991-2011) (b) Pre-Crisis Sample (1991-1997) (c) Post-Crisis Sample (1998-2011) Notes: The dashed lines plot the results of the kernel density estimates using the Gaussian kernel functions. The solid lines graph the results of the normal density estimates. APPENDIX FIGURE 3 D ISTRIBUTION OF R ISK C OEFFICIENT References Abel, A. "Optimal Investment under Uncertainty." American Economic Review 73 (No. 1 1983): 228-33. Arrow, K. J. 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Mr. Ross Dyer of the Montrose community has been missing since April 15th. His old 1973 Chevrolet pickup was found stuck. He apparently got out and started walking. Helicopters searched the area without finding him. Mr. Dyer is 86 years old, described as being white male, 5'1½" tall and weighing approximately 150 lbs. He has blue eyes and gray hair. Around one hundred men from the Rose Hill area joined in the search with the National Guards on Sunday afternoon. The search was a total failure. No one has any clues as to where Mr. Dyer is. Get well wishes go to Mazie Varner, Florence Graham, Clyde Lewis, Eddie Lee Dearman and Lorene Lewis.	<urn:uuid:598196b5-08d2-401e-af5d-03eed685ff94>	CC-MAIN-2024-22	https://www.mmup.info/_files/ugd/6a1c14_f4f69c479cc047c2ac871eb09b14d4b4.pdf	2024-05-21T07:44:32+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-22/subset=warc/part-00137-4dd72944-e9c0-41a1-9026-dfd2d0615bf2.c000.gz.parquet	774,362,206	153	eng_Latn	eng_Latn	0.999667	eng_Latn	0.999667	[ "eng_Latn" ]	false	docling	[ 647 ]
Building 134 P.O. Box 5000 Upton, NY 11973-5000 Phone 631 344-2345 Fax 631 344-3368 www.bnl.gov managed for the U.S. Department of Energy by Brookhaven Science Associates, a company founded by Stony Brook University and Battelle News Release number: 03- For release: September , 2003 contact: Diane Greenberg, 631 344-2347, [email protected], or Mona S. Rowe, 631 344-5056, [email protected] Yvette Malavet-Blum Stars in 'Latin Rhythms' at Brookhaven Lab, October 3 UPTON, NY -- In honor of Hispanic Heritage Month, cabaret singer Yvette MalavetBlum, accompanied by Sam Carr on piano, will star in a concert titled "Latin Rhythms" at the U.S. Department of Energy's Brookhaven National Laboratory on Friday, October 3, at 8 p.m. The concert is open to the public. All visitors to the Laboratory age 16 and older must bring a photo ID. Yvette Malavet-Blum began singing cabaret at Manhattan's Triad Theater by showcasing with The Singing Experience, under the direction of Linda Amiel-Burns. In 2001, she opened a solo show at a popular cabaret theatre in Manhattan called "Don't Tell Mama." Since then she has performed extensively in Manhattan and Long Island. Malavet-Blum is a secretary at Brookhaven Lab. Sam Carr is a researcher at Brookhaven and a pianist and conductor who founded St. John's College orchestra in Oxford, England. Carr has performed with singers and choirs throughout Long Island. At the Brookhaven concert, Malavet-Blum will sing popular Spanish-language songs, her favorite English songs with a Latin beat, and Spanish songs with English lyrics. Tickets for the concert are $8 each, and they may be purchased at the door on the evening of the performance. They may also be purchased in advance at the Brookhaven Employees Recreation Association store in Berkner Hall on the Laboratory site. The store is open on weekdays, from 9 a.m. to 3 p.m. Only cash or checks are accepted for ticket purchases. Call 631 344-3846 for more information about the concert. The Laboratory is located on William Floyd Parkway (County Road 46), one-and-a-half miles north of Exit 68 of the Long Island Expressway. Visit Brookhaven Lab's electronic newsroom for links, news archives, graphics, and more: http://www.bnl.gov/newsroom. The U.S. Department of Energy's Brookhaven National Laboratory conducts research in the physical, biomedical, and environmental sciences, as well as in energy technologies. Brookhaven also builds and operates major facilities available to university, industrial, and government scientists. The Laboratory is managed by Brookhaven Science Associates, a limited liability company founded by Stony Brook University and Battelle, a nonprofit applied science and technology organization.	<urn:uuid:db30b764-4a3a-4c88-9f41-eada3a3c3e0c>	CC-MAIN-2024-30	http://yvettemalavet.com/shows/Brookhaven_Press_Release.pdf	2024-07-24T09:16:12+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-30/subset=warc/part-00068-65338ae2-db7f-48fa-a620-71777c40d854.c000.gz.parquet	55,154,980	647	eng_Latn	eng_Latn	0.993081	eng_Latn	0.993081	[ "eng_Latn" ]	false	rolmOCR	[ 2736 ]
So you think you'd like to be an Intimacy Coordinator? What is an Intimacy Coordinator? An Intimacy Coordinator (IC) works across multiple departments on a production to facilitate, manage and choreograph intimate content for screen. "Intimate content" is a wide umbrella term that includes: simulated sex, nudity & partial nudity, kissing, simulated sexual assault and non-consensual action, medical scenes, childbirth, bodily functions, and more. An IC works with a rigorous consent-based practice to help to ensure the wellbeing of creatives involved in the shooting of these scenes. An IC is a creative professional who collaborates with other members of the team from pre-production through to broadcast to realise moments that best serve the characters and the story. What does an Intimacy Coordinator's job entail? This vastly depends on the project, the scene, the team, and a host of other variables. An IC is attached to a project from start to finish as a Head of Department, and may be on set more or less frequently depending on the amount of intimate content. In any case, a great proportion of an IC's job occurs before they turn up on set. This includes: consulting with producers and casting, reading scripts and doing breakdowns of the intimate action, liaising with all relevant departments involved in these scenes, having discussions with the director(s) about what they imagine for these moments, having conversations with actors about their boundaries and expectations, rehearsals, liaising with production and legal over certain documentation, creating risk assessments and follow-up feedback forms. When the shooting day arrives, an IC's responsibilities typically include: continued check-ins with the actors, work with the AD team to ensure the Closed Set is being maintained effectively (if applicable), ongoing collaboration with Costume regarding modesty garments and robes, choreographing or revisiting any intimate action with the actors, collaborating with the director during filming and any other professionals as relevant. Myth Busting! * "The role of the IC was created in response to the Weinstein scandal and the #MeToo movement." - False! The first person to work on set under the title of 'Intimacy Coordinator' was Alicia Rodis in the spring of 2017. The role had existed years before this in theatre, with the term 'Intimacy Choreographer' coined by Tonia Sina in 2006. Safe practice has existed in various forms prior to this, though it was not uniform nor under a specifically-designated role. * "Intimacy Coordination is mainly getting to choreograph amazing sex scenes!" - False! A lot of the role happens before choreography and shaping intimate storytelling is more than simulated sex (e.g. kissing, familial touch, hyper-exposed content). * "Everyone will welcome you with open arms on set!" - Sometimes true, but not always! The role is part of a workplace culture-shift. As a new position, there is often a need for education and further understanding of the workflow, processes, and benefits to Production. The role may involve some tough conversations and challenges to the status quo and existing structures. * "ICs are there to stop any chance of sexual harassment!" - False! Everybody on set is responsible. ICs are not HR. ICs are not always present on set and only work with specific members of a Production, and sexual harassment can happen between anyone, at anytime. The Production should have a robust system for preventing sexual harassment, with clear reporting pathways, regardless of the IC. However the employment and presence of a prepared IC can mitigate risk in some situations. * "I can be an IC and direct/act at the same time!" - False! When you're an IC it's a full commitment to the production. You can't be an actor and IC in the same production. As a director, you hold implicit power that means you can't also be the IC. It's crucial that an IC is a third-party without responsibilities that clash with their ability to be as neutral as possible. Some ICs work as movement professionals, choreographers or stunt coordinators alongside Intimacy Coordination. Intimacy Coordinators' Recommended Skills There are certain skills that Intimacy Coordinators typically have that ensure best practice. Intimacy Coordinators having these skills allows them to engage in the work effectively. * Empathy * Active listener * Considerate * Emotional Literacy * An aptitude for collaboration * Ability to hold conflict * Creativity * Quick problem-solving * Self-reflective * Ability to interrogate own prejudices and assumptions * Ability to anticipate issues * A comfortability working with various types of intimate content * Ability to speak frankly about sex and bodies * A passion for working with physical, embodied storytelling * An enthusiasm for consent-work Intimacy Coordinators' Potential Backgrounds Current Intimacy Coordinators in the UK have come from a range of backgrounds, including: Movement Fight/Stunt Costume Advocacy Law Safer Spaces Training Wellbeing / Pastoral work Adult Entertainment Acting Directing Various Film/TV Crew roles (e.g. ADs, Gaffers etc.) Whatever your background, aspiring ICs are recommended to have a previous qualification and/or recognisable experience in movement, directing and/or acting or an equivalent creative role as well as knowledge and/or experience of on-set etiquette and processes. Other Pathways Intimacy Coordination is a niche and specific role. If you find you do not necessarily have the exact skills, experiences, interests or background to be able to work as an IC, there are other adjacent roles that may be more suited to you: * Wellbeing Practitioner - This could be right for you if: ■ You are passionate about wellbeing in the creative industries in general, and not just around Intimacy ■ You are passionate about advocating for best practice but don't have experience/interest in movement, acting, directing and/or other creative roles. * Access Coordinator - This could be right for you if: ■ You are particularly interested in advocating for actors and crew and coordinating their access needs. ■ You are interested in the pastoral side of screen production, and coordinating with multiple departments including actors, ADs, Directors and Producers ■ You have a passion for working with disabled and neurodivergent actors to work alongside an IC when filming intimate content. * LGBTQ+ consultant - This could be right for you if: ■ You are passionate about the representation of LGBTQ+ characters and themes on screen generally, and not just around representations of queer Intimacy. ■ You have experience and interest in advocacy but not in movement, acting, directing and/or other creative roles. * Other consultancy roles, e.g. fetish, BDSM, kink, erotic dance etc. - There are a range of specialist consultancy roles that can be brought into productions, sometimes working in collaboration with an IC, but also working more broadly on how these specialist topics are portrayed on screen. If you have particular experience or knowledge of a certain area and are largely interested in facilitating that type of content, these could be roles for you. Working with Intimacy practice If you are a creative professional who is excited about the rise in Intimacy Coordination, and are looking forward to working on scenes of Intimacy in your current role, it is possible to learn about Intimacy practice without committing to training as an IC. Directors, Actors, Choreographers and others, may want to attend some introductory workshops or do some reading so they are engaged in the practice and ready to work on Intimacy with an Intimacy Coordinator, without needing to change careers into the new role. You can always create safer spaces in the role you currently inhabit. How to train as an Intimacy Coordinator There have been barriers to providing training and a lack of training opportunities for Intimacy Coordinators in the UK over the past years. Bectu has established the Training Working Group to try to find remedies for this issue and to provide clear training pathways for potential ICs. Please watch this space. Why do you need to undergo training and/or mentorship to be an IC? An Intimacy Coordinator is a health and safety role, with significant responsibility and liability for what happens on set during the filming of intimate scenes. It is essential that anyone walking on set in this capacity is qualified to undertake those responsibilities. There are many areas of expertise an IC needs to have, and pathways to obtaining that training are evolving and varied – the one thing the entire industry agrees on is that ICs need to be properly trained. When someone who isn't properly trained works on set as an IC they put themselves at risk, as well as the actors and the production. By doing so, they also jeopardize the integrity and reputation of the role of the IC in the wider industry, leading to misconceptions about the work and a loss of respect for the role. The Bectu Intimacy Coordinator Registry (beginning 2023) "is designed to promote high safety standards and industry-wide competence" regarding Intimacy work. "There are a number of experience and qualification requirements" that ICs must have in order to be accepted onto the Registry. Preparation for training Before joining a training programme or mentorship scheme, you can begin self-led study and other preparation to put yourself in the best position possible to be accepted onto one of these pathways and to ready yourself for training as an Intimacy Coordinator: * Improve your understanding of: - Contracts, Union Agreements & Guidelines - UK law & resources on consent and harassment - Power dynamics - Trauma Awareness or Trauma-Informed Practice * Undertake training in all the following areas (e.g. via providers such as High Speed Training & iHasco): - Mental Health First Aid - Creative Industries Safety Passport - Anti-Harassment, Sexual Harassment and Bullying - Gender Identity and LGBTQIA+ Awareness - Equality, Diversity and Inclusivity - Conflict Resolution / Mediation - Bystander Intervention - Safeguarding Training for Working with Minors (e.g. NSPCC, PART). * Courses to supplement your existing knowledge and diversify your understanding of: - Directing - Acting - Movement - Camera - Filmmaking - Dramaturgy * Intro to Intimacy Coordination fundamentals / online courses Basic expectations from training providers Your course should include the following: * Opportunities for engagement with various Intimacy practitioners and related professionals. ICs have many different skills and backgrounds, so courses should embrace that there is no singular methodology or practice when it comes to Intimacy Coordination. * Courses should charge reasonable fees for training undertaken, or should ideally offer flexible payment options (e.g. installments). Financing should be transparent. * Courses should have a curriculum that is clearly sent out in advance. * Courses and/or training providers should have testimonials. * Courses should have a clear end-point, so trainees can see their roadmap for finishing their training. Reach out to Bectu if you have concerns.	<urn:uuid:1e3c5e15-9dc0-4d94-b8db-6ecb481c5326>	CC-MAIN-2025-08	https://www.intimacyinarts.co.uk/_files/ugd/ededaa_ff736dd2a69142b885c55d0c10a01042.pdf	2025-02-10T12:36:46+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2025-08/subset=warc/part-00014-b184e832-acd1-425a-bab7-895830f2748a.c000.gz.parquet	767,601,295	2,283	eng_Latn	eng_Latn	0.988874	eng_Latn	0.997726	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2063, 4143, 5170, 6774, 9071, 10475, 11270 ]
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And today, we'll trouble one touse analyzing Get Free Strategy In Nato Preparing For An Imperfect World LIT as among the material to perform. Although their apartments were above the garage, back to back, each was served by a separate exterior staircase. As often as either man entered the other's domain, they might as well have lived hundreds of miles apart..As though the blush were transmitted by a virus, Junior caught the primrose-pink contagion from the pianist..At the stream Serrenen, where it runs within the north wall of the city, the midwife gave Otter his true name, by which he is remembered in islands far from Havnor..She didn't have an appetite, anyway. Joey was too much on her mind. The safe birth of a healthy child was a blessing, but it wasn't compensation for her loss. Although by nature resistant to depression, she now had a darkness in her heart that would not relent before a thousand dawns or ten thousand. If a mere nurse had insisted that she eat, Agnes would not have been persuaded, but she couldn't hold out against the insistent importuning of one special seamstress..Scamp had fabulous legs, and her bralessness left no doubts about the lusciousness and authenticity of her chest, but after an hour of conversation about something or other, before suggesting that they leave together, Junior maneuvered her into a reasonably private corner and discreetly put a hand up her skirt, just to confirm that his gender suspicions were correct..Even in this soft light, Nolly could see that she was blushing like a young girl. She glanced around at the nearby tables..Shopping for fashion accessories relaxed Junior. He spent a few hours browsing for tie chains, silk pocket squares, and unusual belts. Riding the up escalator in a department store, between the second and.Convinced he was alone and unobserved, Junior leaned into the car and shifted it out of park. He released the hand brake..By this time, Vinton had finished, commercials had run, and the number-two song had started: "Come See About Me," by the Supremes..After a few racing steps, when the dog realized that Mary hadn't thrown the ball, it whipped around and sprinted back..Along the hall, every step measured, he stayed near the wall farthest from the staircase..So that my mind could move about among the years and centuries without getting things all out of order, and to keep contradictions and discrepancies at a minimum while I was writing these stories, I became (somewhat) more systematic and methodical, and put my knowledge of the peoples and their history together into "A Description of Earthsea." Its function is like that of the first big map I drew of all the Archipelago and the Reaches, when I began to work on A Wizard of Earthsea over thirty years ago: I needed to know where things are, and how to get from here to there-in time as well as in space.."It's chilly and foggy and late, and there might be villains afoot at this hour," he intoned with mock gravity. "The two of you are Lipscomb women now, or soon will be, and Lipscomb women never go unescorted through the dangerous urban night.".Indeed, even the distinct fragrance of pulp paper, yellow with age, was alone sufficient to start him fantasizing..While Junior had been hospitalized , Vanadium had searched his lace, with or without a warrant. Turnabout was satisfying..Of course, Seraphim's child would not have a telephone. He was just a baby, dangerous to Junior in a way that was not clear, but a baby nonetheless..Posing as a counselor with Catholic Family Services, he phoned each listed Bartholomew, with a question related to his or her recent adoption. Those who expressed bafflement, and who claimed not to have adopted a child, were generally stricken from his list..This was not a ghost. This was not a walking dead man. This was something else, but until he knew what it was, who it was, the only person he could possibly look for was Vanadium..Joey was not illuminated by the light of this world. Agnes realized that he was translucent, his skin like fine milk glass through which shone a light from elsewhere..Oblivious that she and Barty had become the center of attention, Angel said, "Does he ever get the quarters back?".As spectacularly busty as the not-yet-dead Jayne Mansfield, Frieda never wore a bra. In 1966, this free-swinging style was little seen. Initially, Junior didn't realize bralessness was a declaration of Frieda's liberation; he thought it meant she was a slut..From the floor, Junior snatched up the bottle of wine that had twice failed to shatter. His lucky Merlot.."Maybe it's not where the heart is," Wally corrected himself. "Maybe it's where the buffalo roam.".So the practice of their lore and the teaching of it had become perilous. Those who undertook it were often those already outcast, crippled, deranged, without family, old-women and men who had little to lose. The wise man and wise woman, trusted and held in reverence, gave way to the stock figures of the shuffling, impotent village sorcerer with his trickeries, the hag-witch with her potions used in aid of lust, jealousy, and malice. And a child's gift for magic became a thing to dread and hide..During the first months, the journeys were eight or ten miles: along the shoreline north and south of Bright Beach, and inland to the desert beyond the hills. He left home and returned the same day..There would be lots of aftermath with three at once, especially if he took them out with point-blank head shots, but Junior was pumped full of reliable antiemetics, antidiarrhetics, and antihistamines, so he felt adequately protected from his traitorous sensitive side. In fact, he wanted to see a significant quantity of aftermath this time, because it would be proof positive that the boy was dead and that all this torment had come at last to an end..Junior didn't believe in gods, devils, Heaven, Hell, life after death. He put his faith in one thing: himself..Dusk had arrived, strangling the day, and the throttled sky hung low, as blue-black as bruises. The streetlights had come on. Gouts of red light from pulsing emergency beacons alchemized the rain from teardrops into showers of blood..This Monday afternoon, he longed for the escape and solace of half-hour pulp adventure. But he decided that he ought to at last compose the letter he'd been meaning to write for at least ten days..Maybe the bright side was that the musician hadn't either wet his pants or taken a dump while in his death throes. Sometimes, during a comparatively slow death like strangulation, the victim lost control of all bodily functions. He'd read it in a novel, something from the Book-of-the-Month Club and therefore both life-enriching and reliable. Probably not Eudora Welty. Maybe Norman Mailer. Anyway, the men's room didn't smell as fresh as a flower shop, but it didn't reek, either..Anyway, the thing that scared her was not the monstrous father of this child. The fearsome thing was the decision that she had made a few minutes ago, in the unused hospital room on the seventh floor.."--and we're from different worlds, which I respect. I respect you and your wonderful family ... your centeredness, your certainty. I want to do this only because it's what I owe you.".Maria gathered up the four jacks and tore them in thirds. She put the twelve pieces in the breast pocket of her blouse. "I buy to you new cards, but no more ever can you to be having these.".The night was holding its breath again, the previous breeze now pent up in the breast of darkness..Hisscus, Nork, and Knacker exchanged sharp glances, nonplussed. Finally, one of them said, "We couldn't do that, Mr. Cain. Not until you've consulted an attorney.".No elevator. He didn't have to worry that with no more warning than a ding, doors might slide open, admitting witnesses into the hall..As if vengeful spirits weren't trouble enough, he had for three years been struggling unwittingly against the terrible power of the minister's curse, black Baptist voodoo that made his life miserable. He knew now why he had been plagued by violent nervous emesis, by epic diarrhea, by hideously disfiguring hives. The failure to find a heart mate, the humiliation with Renee Vivi, the two nasty cases of gonorrhea, the disastrous meditative catatonia, the inability to learn French and German, his loneliness, his emptiness, his thwarted attempts to find and kill the bastard boy born of Phimie's womb: All these things and more, much more, were the hateful consequences of the vicious, vindictive voodoo of that hypocritical Christian. As a highly self-improved, fully evolved, committed man who was comfortable with his raw instincts, Junior should be sailing through life on calm seas, under perpetually sunny sides, with his sails always full of wind, but instead he was constantly cruelly battered and storm-tossed through an unrelenting night, not because of any shortcomings of mind or heart, or character, but because of black magic..The possibility that he'd left a clear fingerprint on the watch crystal had to be judged remote. And the band had been too textured to take a print useful to the police..Granted that he was only three going on four, nevertheless Barty had never met anyone with as much cheerful imagination as Angel. He intended to marry her in, oh, maybe twenty years..In early May, he sought self-improvement by taking French lessons. The language of love..Evidently, Jacob had made a quick trip to his apartment over the garage and, with no thought for mice and dust, had not closed the back door. Junior said, "You've caused me a lot of trouble, you know." He'd been building a beautiful rage all night, thinking about what he'd been through because of the girl's temptress mother, whom he saw so clearly in this pint-size bitch. "So much trouble.".If either of them suspected that she was lying, it was Edom. He looked puzzled, but he didn't pursue the issue..dent? You do believe that? Because I don't see ... I don't know how could work with someone who thought I was capable of . . . ".Griskin, a former convict, had served eleven years for second-degree murder before the lobbying efforts of a coalition of artists and writers had won his parole. He possessed a huge talent. No one before Griskin had ever managed to express this degree of violence an rage in the medium of bronze, and Junior had long kept the artist's work on his short list of desired acquisitions.."Living high. When I wasn't on the road, I had a fine house here in Bright Beach, not this rental shack I'm in now, but a nice little place with an ocean view. You can guess what went wrong."."It seems it was his own idea, your majesty."."I really am sorry about this," Junior said, regretting the necessity to deny her the right to look good at her own funeral, "but it's got to appear to be a crime of passion.".Everyone confronted Agnes with expressions of puzzlement and expectation, and she looked from one to another. Paul. Maria. Francesca. Bonita. Grace. Edom. Jacob. Finally Celestina..The silence on the line was not merely that of a caller holding her tongue. It was abyssal and perfect, as no silence on a telephone ever can be, without the faintest hiss or crackle of static, no hint of breathing or.He might suspect, but he couldn't know. He would but would be left with at least a shred of doubt about Junior's.And now Cain was aware of her, interested in her. Informed of this development, Harrison would no doubt rethink his position..Returning his attention to his own shoes, Jacob said, "So ... what am I supposed to do about this?".Nolly, Kathleen, and Sparky had prepared him for Industrial Woman, but when the flashlight beam flared off her fork-and-fan-blade face, Vanadium twitched in fright. Without fully realizing what he was doing, he crossed himself.."Really, Angel," Barty said with genuine concern, "it might be scary. I got another one we could listen to, if you want.".Back in January, when he received the disappointing report from Nolly Wulfstan, Junior was not convinced that the private detective had exercised due diligence in his investigation. He suspected that Wulfstan's ugliness was matched by his laziness..When Agnes groaned, one of the shadows spread its wings, moved closer, to the right side of the bed, and resolved into a nurse. Agnes's vision had cleared. The nurse was a pretty young woman with black hair and indigo eyes..Retracing his path across the kitchen, he caught a faint whiff of jasmine from the backyard. Funny, jasmine here inside. Two paces later, he felt a draft..After carefully wiping her fingers on a paper napkin, Maria examined the garments with interest. She carried her living as the seamstress at Bright Beach Dry Cleaners. At the sight of each rent, popped button, and split seam she clucked her tongue..At 3:3 1 A.M., even the early-winter dawn wasn't near, yet Junior was too awake to return to bed. Though sweet, though melancholy, never ominous, the ghostly singing had left him feeling ... threatened. He considered taking a shower and getting an early start on the day. But he kept remembering Psycho: Anthony Perkins dressed in women's clothes and wielding a butcher knife.."Could you throw an Oreo someplace you weren't blind or maybe someplace Wally wasn't shot?".Ashamed and scared, she told no one. Although a victim, she blamed herself, and the prospect of being exposed to ridicule so horrified her that despair got the better of good judgment..She bit her lower lip, held her breath, repressed the sob that sought release, and said, "I know.".And so at the age of thirty-one, after more than twenty-eight years of blindness with a few short reprieves, Barty Lampion received the gift of sight from his ten-year-old daughter. 1996 through 2000: Day after day, the work was done in memory of Agnes Lampion, Joey Lampion, Harrison White, Seraphim White, Jacob Isaacson, Simon Magusson, Tom Vanadium, Grace White, and most recently Wally Lipscomb, in memory of all those who had given so much and, though perhaps still alive in other places, were gone from here..After supper in a roadside diner, Paul returned to his room and studied a tattered map of the western United States, the latest of several he'd worn out over the years. Depending on the weather and the steepness of the terrain, he might be able to reach Spruce Hills, Oregon, in ten days..Freed for the moment from the need to be strong for her sleeping Angel or for Wally, Celestina turned to Tom Vanadium, saw in his gray eyes both the sorrow of the world and a hope to match her own, saw in his ruined face the promise of triumph over evil, leaned against him for support, and finally dared to cry..In fact, though he strained hard to recall their conversations, he could dredge up nothing that Seraphim had said during therapy, as if he'd been stone-deaf in those days. The only things he retained were sensual impressions: the beauty of her face, the texture of her skin, the firmness of her flesh under his ministering hands..In the dark dumpster, tormented by ceaseless torrents of what-ifs, convinced that the spirit of Vanadium was going to slam the lid and lock him in with a revivified corpse, Junior had for a while been reduced to the condition of a helpless child. Paralyzed by fear, withdrawn to the corner of the dumpster farthest from the putrefying pianist, squatting in trash, he had shaken with such violence that his castanet teeth had chattered in a frenzied flamenco rhythm to which his bones seemed to knock, knock, like boot heels on a dance floor. He had heard himself whimpering but couldn't stop, had felt tears of shame burning down his cheeks but couldn't halt the flow, had felt his bladder ready to burst from the needle prick of terror but bad with heroic effort managed to refrain from wetting his pants..Of firm but pliable rubber, custom-formed to his disfigured foot, a shoe insert filled the void left by his missing toe. This simple aid ensured that virtually all footwear was comfortable, and by November, Junior walked with no discernible limp..Serving a formal dinner was Agnes's way of declaring-to herself more than to anyone else in attendance-that the time had come for her to get on with life for Bartholomew's sake, but also for her own..evening. She brought her daughters, seven-year-old Bonita and six year-old Francesca, who came with their newest Barbie dolls-Color Magic Barbie, the Barbie Beautiful Blues Gift Set, Barbie's friends.He woke several times that night, instantly alert for a ghostly serenade, but he heard no otherworldly crooning..The apartment had been furnished with only two padded folding chairs and a bare mattress in the living room. The mattress was on the floor, without benefit of a bed frame or box springs..The spectral singer didn't exhibit her blood-and-bone sisters' reluctance to pursue her man..He could have killed someone named Henry or Larry, without risk of creating a Bartholomew pattern that would prickle like a pungent scent in the hound-dog nostrils of Bay Area homicide detectives. But he restrained himself..Only Angel spoke, with nary a catch or quiver, fully confident in her Barty. "Anything he can teach me, I can learn, and anything I can see, he can know. Anything, Aunt Aggie."."You did just fine, Tom, just fine," Agnes said in a consoling tone that she might have used with a boy whose performance, at a piano recital, had been earnest but undistinguished. "We were all quite impressed."."It's even worse," Junior rasped, convinced that he was losing some indefinable advantage if the cop left without playing out this moment as it would usually unfold in an intellectual television crime drama like Perry Mason or Peter Gunn..Dinner was cooking in the upper of the two ovens. He switched the bottom oven, setting it at warm, and dropped open the door..Then the hero got in the sedan with his friends, and they drove away into the sun-splashed morning..He would have done it, too, and risked establishing a pattern that police might notice; but the still, small voice of Zedd guided him now, as so often before, and counseled calm, counseled focus..Beyond the window, Barty failed to do any of the things that Agnes expected of a boy not fully enough part of the day to share its rain: He didn't flicker like an image on a static-peppered TV screen; he didn't shimmer like a phantom figure in Sahara heat or blur like a reflection in a steam-clouded mirror..As if he'd been presented with many previous photos under these circumstances, Jonas Salk accepted the picture. "Your daughter?".Tom proved to be more useful than either a cop or a priest to Pie Lady Services, when he discovered a talent for money management that protected their funds from twelve percent inflation and in fact brought them a handsome return in real terms. The Light Inside: Welcome to the World of Spirit Gone from the Game: None Dead Last II Sammy Sleuth, Boy Detective The Goodbye Girl Wonders of Wythenshawe Rock Solid Christianity: Finding Solid Ground in a World of Shifting Values I Am a Grieved Ornamental Horticulturist Verlustabzug Bei Korperschaften ( 8c Kstg) Zum Verordnungsvorschlag Uber Ein Gemeinsames Europaisches Kaufrecht Erleben Der Kinder Und Eltern in Der Hilfeplanung, Das Frauenrechte Im Islam Offentlichkeit vs. Privatheit. Wahrnehmungsverschiebung Von Frauenoffentlichkeiten in Zeiten Moderner Medien Weltausstellungsarchitektur ALS Kommunikationsinstrument Unterrichtsstunde Das Gleichnis Vom Verlorenen Sohn (Religion Klasse 5) Russische Wirtschaft. Der Ausnahmefall Gazprom In Den Fustapfen Von Heinrich Roth Exegese Micha 4, 1-5 Verschworungstheorie Von Der Brunnenvergiftung Der Juden, Die Liebe Und Der Liebesbegriff in Goethes Die Leiden Des Jungen Werther Und Dostojewskis Weisse Nachte, Die Exegese Gen 11, 1-9 Auf Der Suche Nach Der Wirklichkeit in Der Digitalen Und Post-Modernen Fotografie Strategy and Policy Die Literarische Sichtbarmachung Flauberts in Seinem Roman Madame Bovary VOR Dem Hintergrund Des Realismus The Exhibitonary Complex Im Spaten 19. Jahrhundert Aus Der Perspektive Tony Bennetts	<urn:uuid:5b90c914-700d-432f-8e61-760484d6fcfd>	CC-MAIN-2019-18	http://communityclerks.com/str/strategy-in-nato-preparing-for-an-imperfect-world.pdf	2019-04-26T16:13:00Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-18/segments/1555578841544.98/warc/CC-MAIN-20190426153423-20190426175423-00188.warc.gz	38,441,443	7,172	eng_Latn	eng_Latn	0.984241	eng_Latn	0.998779	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 5895, 13106, 21615, 30102, 32522 ]
3 December 2021 Taranaki District Health Board Private Bag 2016 New Plymouth 4620 New Zealand Telephone 06 753 6139 Fax: 06 753 7770 Email: [email protected] www.tdhb.org.nz Taranaki Base Hospital Private Bag 2016 New Plymouth 4620 New Zealand Phone: 06 753 6139 Fax: 06 753 7710 Hāwera Hospital Post Office Box 98 Hāwera New Zealand Phone: 06 278-9929 Fax: 06 278 9910 Stratford Health Centre Phone: 06 765 7189 Opunake Medical Centre (CoastalCare) Phone: 06 761 7324 Pātea Health Centre Phone: 06 273 8088 Waitara Health Centre Phone: 06 754 7150 Mōkau Health Centre Phone: 06 752 9723 Re: Official Information Act I am responding on behalf of Taranaki District Health Board (DHB) to your OIA request of 8 November 2021. You have requested the following information: 1. Do you diagnose ADHD for those under the age of 18, and for those over 18? If so, what is the process to getting a diagnosis, and who does the diagnosis? If not, please explain why not. Child and Adolescent Mental Health Services (CAMHS) CAMHS provides diagnosis up to the age of 18, and afterwards, if there is a diagnostic query, it will be done via the Adult MH services. While under CAMHS, the process includes a clinical assessment completed by a child psychiatrist; obtaining collateral history from parents and school; at times we use standardised questionnaires and screening tools (CONORS for example). In a handful of cases, if the diagnosis cannot be resolved by means of clinical assessment, we will resort to a comprehensive cognitive assessment, which is completed by our psychologists. Paediatric Department We provide diagnosis for those under the age of 15. Referrals can come from the GP, school, or other organisations. The process includes obtaining information from home and school regarding the child's development, behaviour, and academic functioning. We also obtain standardised questionnaires for ADHD from home and school. The paediatrician does the diagnosis. Adult ADHD Pathways Yes, a person will be referred in to specialist mental health services for review and assessment of possible ADHD. The assessments are done by Taranaki DHB Adult Psychiatrists and occasionally Psychologist if the diagnosis is in doubt. They are screened by intake staff after a standard psychiatric assessment to rule out comorbid conditions, drug and alcohol use and then assessed and treated by a psychiatrist. 2. What is the waiting list/average time frame to be diagnosed over the last 12 months? (for under and over 18) Child and Adolescent Mental Health Services (CAMHS) For patients under the age of 18 the wait list has been around 3-4 weeks for a first appointment with a child psychiatrist. Now that we are experiencing a shortage in child psychiatry it can be delayed up to 3 months. Paediatric Department Our average waiting time for this is 62 days. Adult ADHD Pathways There is a general waiting time for 4 to 6 weeks but it is not diagnosis based. Urgency is based around risk and need. 3. What support do you provide once they are diagnosed? Child and Adolescent Mental Health Services (CAMHS) 1. Psychiatric follow ups until such time as the child is well stabilised and showing good outcomes. 2. Psychotherapy can be offered for cases where the ADHD is only a part of a bigger complex, such as behavioural issues, concomitant anxiety, Autism, etc. 3. Similarly, if indicated, we may offer parental guidance and therapy for parents who struggle with raising a child with ADHD. Paediatric Department The paediatrician will do paediatric follow up as required, and titration of medication schedule if medication is prescribed. Our child development nurse will support this process and sees many of these children for follow up at her own clinic. She will also liaise with school and other agencies as required. Adult ADHD Pathways The diagnosis is explained, treatment options discussed, medication discussed, and other comorbid conditions managed. They are referred to psychologist if needed. All clients have a key worker who follows them up. Patients are reviewed a week and then a month later. 4. Do you have the ability to cope with an ADHD person in crisis? What care is provided? * ADHD is not an acute condition, and there is no such things as ADHD-based crisis. * A clinic visit can be brought forward if required, or phone clinic arranged when acute assessment or treatment is required. I trust the above information answers your OIA request. Kind regards Gillian Campbell Chief Operating Officer	<urn:uuid:c639d596-ae5e-423f-be01-778cecef7a13>	CC-MAIN-2022-05	https://tdhb.org.nz/dhb/documents/OIA/2021/2021-12-03_ADHD-services.pdf	2022-01-21T14:08:56+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-05/subset=warc/part-00241-1e2959d8-5649-433a-b76e-f1b876a6479d.c000.gz.parquet	562,358,962	1,046	eng_Latn	eng_Latn	0.993255	eng_Latn	0.995426	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2825, 4571 ]
INTERPRETATION OF THE RESULT \| IgG Index Value \| Result \| Interpretation \| \|-----------------\|----------\|--------------------------------------------------------------------------------\| \| IgG Index value <0.90 \| Negative \| Indicates absence of prior exposure to Rubella (<13IU/ml) \| \| IgG Index value 0.91-0.99 \| Grey zone \| Sample should be re-tested, (13-15 IU/ml) \| \| IgG Index value >1.0 \| Positive \| Indicates prior exposure to Rubella virus (>15IU/ml) \| PERFORMANCE CHARACTERISTICS A total of 117 patient samples were used to evaluate specificity and sensitivity of the test. ELECTRA™ Rubella IgG test results were compared to a commercial available licensed ELISA kit: \| Reference CLIA \| N \| E \| P \| Total \| \|----------------\|---\|---\|---\|-------\| \| ELECTRA™ Rubella IgG CLIA \| N \| 71 (D) \| 0 \| 0 (B) \| 71 \| \| \| E \| 0 \| 3 \| 0 \| 4 \| \| \| P \| 0 (C) \| 1 \| 41 (A) \| 42 \| \| \| Total \| 71 \| 4 \| 41 \| 117 \| Sensitivity = 100% Specificity = 100% Important Note: 1. This assay is a temperature sensitive assay. The best temperature condition for this assay is 37°C. 2. The wash procedure is critical. Insufficient washing will result in poor precision and falsely elevated RLU readings. 3. It is recommended to use the multiple channel pipettes to avoid time effect. A full plate of 96 wells may be used if automated pipetting is available. 4. Duplication of Calibrators & samples is not mandatory but may provide information on reproducibility & application errors. LIMITATIONS OF THE ASSAY 1. Lipemic, hemolyzed, icteric or heat inactivated sera may cause erroneous results. 2. Rubella antibody is present in apparently normal subjects in certain populations or geographic groups. A single test is not diagnostic for an active infection. Obtain two specimens at an interval of two weeks and test them at the same time to give more meaningful information. 3. As with other serological assays, the results of these assays should be used in conjunction with information available from clinical evaluation and other diagnostic procedures. BIBLIOGRAPHY 1. Gravell, M., P.H. Dorcett, O. Gutenson, and A.C. Ley. Detection of antibody to rubella virus by enzyme-linked immunosorbent assay. J. Infect. Dis. 136:S300, 1977. 2. Hermann, K.L. Rubella virus. Manual of Clinical Microbiology, 3rd Edition. Lennette, Balows, Hausler, Truant (ed). Chap. 86:862. 1980. 3. Katz, S.L. Rubella (German measles). Zinssmer Microbiology, 18th Edition. Jolik, Willett, Amos (ed). Chap. 75:1067, 1985. --- INTENDED USE ELECTRA™ Rubella IgG is intended for the Quantitative detection of IgG antibody to rubella virus infection in human serum. For In Vitro Diagnostic Use only. INTRODUCTION Rubella is a herpes virus. Generally, rubella is considered a mild adolescence disease; however, a maternal infection could be transmitted through the placenta to the fetus, causing congenital rubella. Congenital rubella may result in chronic cardiac disease, growth retardation, hepatosplenomegaly, malformations, and other severe abnormalities. Children born asymptomatic may develop these abnormalities later in life. To reduce risk of such severe complications, accurate serological methods must be performed to determine the serologic status of childbearing-aged women. The presence of rubella specific IgG in the bloodstream attests immunity to rubella. An increase in rubella IgG denotes an acute infection and differentiates rubella from other exanthema’s diseases. PRINCIPLE ELECTRA™ Rubella IgG CLIA is for use on ELECTRA™ analyzers. ELECTRA™ Rubella IgG CLIA works on the principle of chemiluminescence wherein light is produced by a chemical reaction from a substance as it returns from an electronically excited state to the ground state. When catalyzed by HRP, the oxidation of luminol by hydrogen peroxide produces an electronically excited form of 3-aminothalate which on relaxation emits light with maximum intensity at λ=425nm. In this assay Purified rubella antigen is coated on the surface of microwells. Diluted patient serum is added to wells, and the rubella IgG specific antibody, if present, binds to the antigen. All unbound materials are washed away. A subsequent incubation with Anti-human IgG agglutinating sera conjugated with horseradish peroxidase binds to the antigen-antibody complex. Excess enzyme conjugate is washed off, and bound enzyme is detected by adding chemiluminescent substrate and Luminescence is measured in RLU. The intensity of the emitting light is directly proportional to the amount of enzymatic activity of the immunocomplex and hence to the amount of rubella IgG antibodies in the test samples. MATERIALS & COMPONENTS Materials provided with the test kits: 1. Coated Microwells: Purified Rubella antigen coated wells. 2. Sample Diluent. Ready to use. 3. Negative Calibrator: 0 IU/ml. 4. Positive Calibrator: 30 IU/ml. 5. Positive Calibrator: 100 IU/ml. 6. Negative Control. Range stated on the label. 7. Positive Control. Range stated on the label. 8. Wash Buffer Concentrate (20X). 9. Enzyme Conjugate. Ready to use. 10. Cut-off Calibrator: 15 IU/ml. Rubella G Index = 1.0 11. Substrate A: Chemiluminescent substrate containing enhanced luminol solution. 12. Substrate B: Chemiluminescent substrate containing stabilized peroxide solution. Materials required but not provided: 1. Precision pipettes: 10-100µl, 20-200µl, 100-1000µl 2. Disposable pipette tips 3. Distilled water 4. Disposable Gloves 5. Automated Washer 6. Avidity Buffer 7. ELECTRA™ Analyzer STORAGE AND STABILITY 1. ELECTRA™ Rubella IgG kit is stable at 2-8°C up to the expiry date printed on the label. 2. Coated Microwells should be used within one month upon opening the pouch provided that once opened, the pouch must be resealed to protect from moisture. If the color of the desiccant has changed from blue to white at the time of opening the pouch, another coated Microwells pouch should be used. 3. Diluted Wash Buffer is stable up to one week when stored at 2-8°C. 4. Working Substrate (A+B) must be used immediately. SPECIMEN COLLECTION 1. Collect blood specimen by venipuncture according to the standard procedure. 2. Only serum should be used. 3. Avoid grossly hemolytic, lipemic or turbid samples. 4. Preferably use fresh samples. However, specimens can be stored up to 48 hours at 2-8°C, for short duration. 5. For longer storage, specimens can be frozen at -20°C. Thawed samples must be mixed prior to testing. 6. Do not heat inactivate before use. 7. Specimen containing precipitate or particulate matter should be clarified by centrifugation prior to use. 8. Specimen should be free from particulate matter and microbial contamination. PRECAUTIONS 1. Bring all reagents and specimen to room temperature before use. 2. Do not pipette any material by mouth. 3. Do not eat, drink or smoke in the area where testing is done. 4. Use protective clothing and wear gloves when handling samples. 5. Use absorbent sheets to cover the working area. 6. Immediately clean up any spills with sodium hypochlorite. 7. All specimens and reagents should be considered potentially infectious and discarded appropriately. 8. Neutralize acid containing waste before adding hypochlorite. 9. Do not use kit after the expiry date. 10. Do not mix components of one kit with another. 11. Always use new tip for each specimen and reagent. 12. Do not allow liquid from one well to mix with other wells. 13. Do not let the strips dry in between the steps. REAGENT PREPARATION 1. All reagents should be brought to room temperature (18-25°C) and mixed by gently inverting or swirling prior to use. Do not induce foaming. 2. Dilute wash buffer 20 times (for example add 5ml concentrated buffer to 95ml of distilled or deionized water). 3. Prepare a working substrate by mixing substrate A and Substrate B in equal volume (1:1 ratio) before addition to the microwells. \| No. of Strips \| 1 \| 2 \| 3 \| 4 \| 5 \| 6 \| 7 \| 8 \| 9 \| 10 \| 11 \| 12 \| \|---------------\|-----\|-----\|-----\|-----\|-----\|-----\|-----\|-----\|-----\|-----\|-----\|-----\| \| Substrate- A µl \| 250 \| 450 \| 650 \| 850 \| 1050\| 1250\| 1450\| 1650\| 1850\| 2050\| 2250\| 2450\| \| Substrate- B µl \| 250 \| 450 \| 650 \| 850 \| 1050\| 1250\| 1450\| 1650\| 1850\| 2050\| 2250\| 2450\| TEST PROCEDURE 1. Place the desired number of coated strips into the holder. 2. Prepare 1:40 dilutions by adding 5µl of the test samples, negative control, positive control, and calibrators to 200 µl of sample diluent. Mix well. 3. Dispense 100µl of diluted serum samples, negative control, positive control, and calibrator into the appropriate wells. For the reagent blank, dispense 100µl of sample diluent in A1 well position. Tap the holder to remove air bubbles from the liquid and mix well. Incubate for 45 minutes at 37°C. 4. Wash each well three times by filling approximately 350µl diluted wash buffer & blot dry. 5. Dispense 100µl of enzyme conjugate to each well and incubate for 45 minutes 37°C. 6. Wash each well three times by filling approximately 350µl diluted wash buffer & blot dry. 7. Add 50 µl of working Substrate (A+B) in all the micro-wells. Keep away from direct light while adding the substrate. 8. Cover the ELECTRA™ microplate and incubate for 10 minutes at room temperature (18-25°C) in dark. 9. Read the ELECTRA™ micro-plate exactly at 10 minutes in ELECTRA™ Analyzer. If ELECTRA™ micro-plate is not read between 10-15 minutes the test results should be considered as invalid. RUN CRITERIA The test run may be considered valid provided the following criteria are met: 1. The Rubella IgG Index for Negative and Positive Control should be in the range stated on the labels. AVIDITY TESTING Avidity is a measure of antigen to antibody binding. Avidity Test helps in discriminating primary infection from secondary infection. Sometimes it is not sufficient to test for IgM antibodies, as the presence of this class may be due to the persistence of IgM antibodies due to past infection or asymptomatic re-infection without risk for the fetus. For this reason, it is useful to assay the avidity of IgG antibodies. The presence of low avidity is therefore an indication of recent or current infection. The avidity of IgG antibodies can be assayed with this same kit using an additional Buffer called Avidity Buffer (Cat No. 532010096) which is available on request. For Procedure and Interpretation of results, kindly refer Pack Insert of Avidity Buffer. CALCULATIONS Qualitative Determination of Rubella IgG 1. Rubella IgG index value can be calculated by dividing the mean absorbance of NC/PC/Sample by absorbance of Cut-Off calibrator (15 IU/ml). \[ \text{Rubella IgG Index of NC} = \frac{\text{RLU of NC}}{\text{RLU of Cut-Off calibrator}} \] \[ \text{Rubella IgG Index of PC} = \frac{\text{RLU of PC}}{\text{RLU of Cut-Off calibrator}} \] \[ \text{Rubella IgG Index of sample} = \frac{\text{RLU of Sample}}{\text{RLU of Cut-Off calibrator}} \] Quantitative Determination of Rubella IgG For a quantitative determination of anti-Rubella IgG levels of specimens in IU/ml unit, RLU of calibrators are plotted on the Y-axis in graph versus their corresponding anti-Toxoplasma IgG concentration 0, 15, 30, and 100 IU/ml on the X-axis. The estimates of levels in patient sera are read off the 4-parameter logistic regression curve using their individual RLU values. For example: For example: \| Rubella IgG Values (IU/ml) \| RLU's \| \|---------------------------\|-------\| \| A \| 53285 \| \| B \| 6670187 \| \| C \| 8974196 \| \| D \| 9976653 \|	4fe077e7-85b8-4d92-9982-2dd40814b114	CC-MAIN-2023-06	https://tulipgroup.com/PDFs/Elisa_Chemi/IFU/Electra-Rubella-IgG-IFU.pdf	2023-02-07T14:49:44+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-06/subset=warc/part-00160-b5ddf469-bf28-43c4-9c36-5b5ccc3b2bf1.c000.gz.parquet	603,129,154	2,977	eng_Latn	eng_Latn	0.982866	eng_Latn	0.983325	[ "eng_Latn", "eng_Latn" ]	true	docling	[ 6263, 11849 ]
Integrating print and digital resources in library collections. Ed. Audrey Fenner. New York: Haworth Information Press, 2006. 203p. ISBN: 0 7890 2834 4 (pbk.) Price: US$29.95 This publication is a collection of 13 papers that have been co-published simultaneously as The Acquisitions Librarian, Numbers 35/36, 2006. It is an interesting compilation of views on issues in managing print and electronic resources ranging from licensing and consortial purchasing to providing access to them via the library catalog and the web site. The articles in the book have been divided into three parts, namely, Issues and opinions, Research and analysis, and, Histories and projects. This assists the reader to separate the different aspects of the topic, such as the theoretical debates, the empirical research, and projects in libraries to fathom the problems of acquiring resources, providing access to them and managing the collections. The articles in this volume address the questions and concerns of acquiring one format over another; the decisions that are made in the process, such as the focus that predominates in selection (cost, librarian's preference, or, the needs of the library users?) and pricing model or the feasibility of adopting a certain technology. In Issues and opinions, David Ball is of the opinion that librarians are Singing away [their] (own insertion) freedom in the 'big deals' (the purchase of access to large quantities of materials in electronic format) as small publishers in the traditional hardcopy procurement arena will be forced out of business. Consortial purchasing and alternative publishing methods can continue to make printed materials an attractive library format. Bethany Levrault investigates the future directions of the academic reference collection in the shift from print to electronic sources. New technologies need to be addressed, but the traditional principles of library work apply to the selection of resources in all formats in the hybrid library. Levrault emphasizes the need to select appropriate content and to make it available without regard to format, and the need to ease the users' access. SA Jnl Libs & Info Sci 2006, 72(3) The section on Research and analysis highlights the research efforts of five teams at academic department libraries, academic libraries, research libraries and corporate libraries. In Canada's largest computer studies school, Seneca, the provision of access to large e-book collections has not caused a decline in the circulation statistics for print collections. An investigative report examines the way in which 114 Association of Research Libraries (ARL) arrange their electronic resources based on their home pages and catalogues. These libraries provide links to electronic resources in the catalogue, but this practice is not consistent among each other or within themselves. The other researchers focused on the catalogues and electronic holding lists of the ARL libraries to determine if core reference titles are held in duplicate formats in library collections in General Reference, Arts and Humanities, Social Sciences and Sciences. The trend is to cease receiving print versions of titles in lieu of electronic access. A longitudinal study of the use of print journals has provided statistics for purchasing decisions. Print journal use has fallen in titles both with and without electronic counterparts. The removal of print journals has led to an increased use of e-journals. The Histories and projects section contains the positive approaches of 6 projects that illustrate the attempts at integrating materials in different formats in the library collection. The Integrated Library System (ILS) is a flexible and highly developed database that can be used and adapted to solve many problems of providing access to library materials. This innovation allows the librarian to use the tools as efficiently as possible for the purpose of outstanding customer service. Two projects deal with serial acquisitions for both print and electronic journals, using process and workflow analysis and serial review respectively. Possibilities of ceasing the checking-in of print serials and the implications thereof for staff workflow and user satisfaction are discussed. The input by academic staff into the serials evaluation by asking for cancellations and additions was designed to allow effective evaluation by all parties. A serials cancellation project is used to discuss consortial agreements for online resources in budget cuts. The results show how consortial purchasing has lead to an increase in the number of journal titles made available online. One project details the user-centred arrangement of materials in a new library without regard to the format of materials to progress to an all-digital collection. Some materials remained in separate discrete collections, though due to the need for special equipment or assistance to use the collection, uncertainty exists regarding the long-term relevance of the collection to the general collection, and user behaviour. The last project in the book illustrates the reality that not everything in a library can or must be digitised, especially educational materials. Physical and tactile experiences are important in learning. The author stresses that format must never hinder access to the contents of library materials, and that it is the responsibility of the library professional to ensure that access is made easy, logical and convenient for the user. The various contributors to this publication have dealt with the different aspects of the topic in a language that is clear and easy to follow, whether the reader is a student or practitioner in Library and Information Science field. Concepts have been defined and clarified; advantages and disadvantages have been tabled, the reader has been sensitised to difficulties, and solutions have been offered based on research done and experiences in several projects. This publication can be recommended as suggested reading for library and information science students, especially those interested in serials management, collection development and academic librarianship. Library and information science workers that are confounded by the dilemmas of the print/digital mix will be able to relate to the issues raised, and will find the alternative viewpoints worthwhile to consider, to discuss and even to try. Reviewed by: Sally Witbooi, Lecturer, Department of Library and Information Science, University of the Western Cape, Bellville Tel.: +27 21 959 2437 (work) Email: [email protected]	<urn:uuid:76cf4323-ed12-4bf5-b0c1-83636cf282f6>	CC-MAIN-2020-24	https://sajlis.journals.ac.za/pub/article/download/1126/1062	2020-05-31T10:31:04+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-24/subset=warc/part-00299-b4a094ce-c3a1-4796-8c26-d927e48e4b4a.c000.gz.parquet	507,233,283	1,218	eng_Latn	eng_Latn	0.996968	eng_Latn	0.997447	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2192, 6610 ]
FirstCaribbean International Bank Limited Consolidated Financial Statements For the Quarter ended July 31, 2004 (expressed in US dollars) Chairman's Review CONSOLIDATED STATEMENT OF INCOME USD'000 * Cash earnings represent earnings before goodwill amortisation and integration charges Note: audited results have been converted to US$ at an exchange rate of US$1 = BBD$2 Note: audited results have been converted to US$ at an exchange rate of US$1 = BBD$2 The above information is also available at our website CONSOLIDATED BALANCE SHEET USD'000 CONSOLIDATED STATEMENT OF CASH FLOWS USD'000 Note: audited results have been converted to US$ at an exchange rate of US$1 = BBD$2 John Eaton, Director www.firstcaribbeanbank.com Charles Pink, Director	<urn:uuid:c394182f-11a5-4032-a4a9-155d7e7f3218>	CC-MAIN-2019-13	https://www.cibc.com/fcib/pdf/fcib-group-q3-2004.pdf	2019-03-19T21:08:43Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-13/segments/1552912202131.54/warc/CC-MAIN-20190319203912-20190319225912-00356.warc.gz	745,018,302	187	eng_Latn	eng_Latn	0.971937	eng_Latn	0.971937	[ "eng_Latn" ]	false	rolmOCR	[ 758 ]
Food networks, strategies and goals – Examples from SME networks Karen Hamann IFAU Institute for Food Studies & Agroindustrial Development Regfood Capacity Building Workshop Copenhagen, 2015 About IFAU * Founded in 1982 - a private company; * Core business: market research and strategic analysis within the international food value chain and food networks; * Collaborates with companies, NGOs, researchers in Denmark and abroad; * Comprehensive international network * My background: Master of Agric. - University of Copenhagen * More information: www.ifau.dk What do food SMEs expect from networks? * To meet other SMEs to learn and build selfconfidence * To find new marketing channels, new customers, and business contacts * Organisers have a professional knowledge level and activities match the need of the SME * The network's communication supports the SME * So: a hands-on approach in a professional business development forum designed to the needs of SMEs The challenges for networks * To provide a forum that supports the members' goals for the company AND the network participation * To remain dynamic by adjusting to changing internal and external conditions * To establish an organisation that supports the network's strategic development SMEs' expected output from joining network activities * Address the professional level of the SMEs; * Supply chain partners involved; * Involvement = way to results; * Outcome that benefits business; * Number of participants vs. critical mass; * Support increases outcome from activities Network activities for food SMEs * Facilitation of cross-border business development * Linking local foods to tourism * Promotional events targeted tourists or local consumers * Assistance in practical product development * Competence building and training activities Network activities – promoting local foods Developing the network * Establish an identity of the network * Have a clear goal for the network * Identify the key member (-groups) for achieving the vision * Establish something concrete that SMEs can understand and relate to – and is based on SMEs' needs. * Facilitate building of relationships Critical mass is important * Volume vs. core participants * Low numbers may drive dynamics (e.g. development work) * Large numbers provide impact (e.g. markets) * Satisfy funding agencies, the network's ambition or the members => dilemma? * Can be achieved within a network or by collaboration between networks Recruiting to the network Common goals and interests are the basis for creating a strong and coherent network * Consider which partners – Are beneficial for the network's development – For SMEs' development (as members or ad hoc); – Are needed for the network to achieve its goal; * Challenge: a diverse group of members may reduce SMEs' interest in participating "what is in it for me?..." Critical success factors – Management of networks * Network coordinator with strong social and professional skills; * Staffs with insights into members' business models and needs; * Board matches network strategy. Key stakeholders to be included; * Company involvement – if relevant; * Project organisation vs. network organisation Networks = relationships Coordinator's role changes Know Trust Collaborate Succeed Create relations and committment Facilitate collaboration Support implementation Communication is essential * Internal communication for committment – To keep members informed – To support flow of knowledge – To support relationship building * External communication for promotion – To promote the network as an organisation and the network's goal – To promote the members' business – To document results (funding agencies) SME statements about the coordinator * Sparringspartner for the SME * Visionary * Respects the SMEs at a professional level * Personal network is very helpful * Instant and professional problem solving * Facilitates finding the right persons and competences * Understands the SME's business model, challenges and provides advice accordingly Characterisation of successful networks: 2 + 2 = 5 Everybody else is here; The network, activities and contacts are useful; The network provides new and relevant knowledge; I can use the outcome for improving my business; The networks helps me to solve complex issues; We share knowledge and experiences openly; The more you give, the more you get; The network has a professional approach to our business; Thank you for your attention. Questions, please? Karen Hamann IFAU Institute for Food Studies & Agro Industrial Development [email protected] Tel +45 45 57 05 82 www.ifau.dk	<urn:uuid:5b61d229-1127-4e1e-b305-04b00b1f6369>	CC-MAIN-2018-22	http://regfood.eu/wp-content/uploads/2015/03/Food-network-strategies-and-goals-Karen-Hamann.pdf	2018-05-22T04:09:36Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-22/segments/1526794864624.7/warc/CC-MAIN-20180522034402-20180522054402-00606.warc.gz	251,151,459	948	eng_Latn	eng_Latn	0.854742	eng_Latn	0.987855	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 972, 1865, 3206, 4474, 4649 ]
Indian Institute of Science (IISc) Bangalore-560012 (India) भारतीयविज्ञानसंस्थानबैंगलोर- 560012(भारत) िेबसाइट/Website: www.iisc.ac.in ACADEMIC SECTION PROCEDURE FOR OBTAINING OFFICIAL TRANSCRIPTS & VERIFICATION OF ACADEMIC CERTIFICATES OFFICIAL TRANSCRIPTS: Alumni of Indian Institute of Science , requiring official Transcripts for the purpose of seeking Admission / Jobs , etc ., should furnish the following particulars : 1) Student Name 2) S.R Number 3) Program and Department 4) Degree Obtained 5) Details of the Transcripts 6) Number of Transcripts copies required 7) Address / University full address to whom the transcripts is / are to be sent (With contact Number) Fee for the official Transcripts : Attachments : 1. Copies of transcripts and degree certificates that need to be officially verified. 2. Payment Receipt VERIFICATION OF ACADEMIC CERTIFICATES: Fee for ex-student verification : Attachments : 1. Copy of documents that need to be verified 2. Payment Receipt Click here to register and pay	<urn:uuid:00afd849-37c4-4266-bf09-224b4e08c810>	CC-MAIN-2024-46	https://www.iisc.ac.in/wp-content/uploads/2024/05/Procedure-to-obtain-official-transcript.pdf	2024-11-07T05:53:34+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-46/subset=warc/part-00269-65a16d46-7179-4f3c-849a-3216b203b23b.c000.gz.parquet	776,230,323	256	eng_Latn	eng_Latn	0.609436	eng_Latn	0.609436	[ "eng_Latn" ]	false	rolmOCR	[ 1028 ]
Case Study: Regional Remuneration Framework Review Project Drivers A rural water organisation was finding they had to pay higher than their existing Rem framework guidelines to attract new people. And it was happening across a range of roles. Their board was reviewing recent appointments and Senior Management was asked to provide a quantifiable explanation for the increase in salary costs compared to their remuneration budget. Client Project Brief Management wanted to be sure that their existing Rem framework was comparing them against the right job market, ie: the actual market in which they were having to compete for talent. From experience, the HR Team found that paying at this level was not enough to attract people to their rural water organisation and they needed to pay more. Insightpay was engaged to quantify the adjustments (if any) that were required to the current remuneration framework to correct it. Then to redesign the current framework to better reflect the actual job market. The Aha Moments Insightpay's Approach Experience and gut feel had told the HR Team to pay at this level because candidates were voting with their feet. This benchmarking exercise confirmed their existing "talent pricelist" had been set well below actual market value. Perceived overpayments were not overpayments at all … they were actually referencing a discounted Rem framework. In recent times the HR Team had unconsciously competent, intuitively reading the talent market correctly. This process provided valid data and an updated remuneration structure to back up their recent decision. Insightpay found that the existing Rem framework had been set up by a large national provider using Australian-Wide non-industry-specific data. This provider suggested paying at the 25 th percentile was an indication of where the overall regional remuneration market sat. This was despite a range of industry and regional factors at play. Our team assessed and validated the existing framework compared to the water market data from the Insightpay Utilities Sector Salary Survey Given the mix of Regional and Metropolitan organisations Insightpay was able to compare the framework against relevant regional data. Jobscore TM also allowed Insightpay to use a comparison tool to align their structures to the relevant comparison points in the market. The Outcomes Confirmed pay rates now sit on the 50 th percentile of their specific industry market. The HR and Management Team was now able to explain to the Board that they are now paying at the appropriate level for their regional market. They now had a valid reference framework moving forward that was factbased and relevant to their industry. It was a very satisfying project for both the client and for Insightpay.	<urn:uuid:c431b8c6-44ae-47b4-98c5-447f9f349f2d>	CC-MAIN-2021-43	https://insightpay.net/wp-content/uploads/2021/08/Insightpay-Case-Study-Validating-a-Regional-Rem-Framework.pdf	2021-10-19T08:46:26+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2021-43/subset=warc/part-00060-16202947-a809-4711-8221-79ab0a79d5b1.c000.gz.parquet	436,681,053	516	eng_Latn	eng_Latn	0.998345	eng_Latn	0.998345	[ "eng_Latn" ]	false	rolmOCR	[ 2788 ]
Bishop Wood C of E Junior School Frogmore Street Tring HP23 5AU Tel: 01442 822024 Fax: 01442 382950 [email protected] www.bishopwood.herts.sch.uk Mr Gary Stanley, Headteacher Email Communication Date: 5 th March 2017 Subject: 4H Collective Worship – rescheduled ------------------------------------------------------------------------------------------------------------------------------------------ Dear Parents and Carers 4H will be taking their class collective worship at 9.15 on Monday 12th March. We hope to see you there. Many thanks Gary Stanley	<urn:uuid:51c137c6-0fae-4e31-8b7c-140a0229a95f>	CC-MAIN-2018-17	http://bishopwood.herts.sch.uk/pdfs/Letters%202017-2018/G-March%202018/Year%204%20-%204H%20Collective%20Worship.pdf	2018-04-22T06:27:01Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-17/segments/1524125945497.22/warc/CC-MAIN-20180422061121-20180422081121-00606.warc.gz	37,534,941	131	eng_Latn	eng_Latn	0.944314	eng_Latn	0.944314	[ "eng_Latn" ]	false	rolmOCR	[ 582 ]
Genealogical Giants Part 1 FamilySearch.org Hello everybody and welcome to another edition of Family Digging. Today we'd like to apologize for not being around for a while, but unfortunately, the pandemic had us down for a little bit. But we're back up again, and here we are today talking about the Genealogical Giants. This will be a series of podcasts on "Who are the Internet's Genealogical Giants?" And which one should you use? I'm here today with Carolyn Lancaster and I'm Paul Hendee. So Carolyn, tell me what's up today? We are going to spend several sessions exploring the four Genealogical Giants of the records database industry and those are Familysearch.org, Ancestry.com, MyHeritage.com, and Findmypast.com. We're going to talk about and emphasize what makes each of these companies unique. And we're going to start with FamilySearch, which is one of the oldest, if not the oldest company that exists of its kind. So what makes Familysearch.org so unique? Well, it's free for one thing, and it's the only one of the four Genealogical Giants that is free. Free is good (and you'll find out I like that word "free" and it's available to everyone from home. Second, it has an extraordinary number of records, many with images of the original records, and they are surely going to keep growing for many years to come. And why do I know that? Because even though they have tens of thousands of people (over 20,000 last I looked) who are digitizing records all over the world, they have only completed about 20% of their record base; and they are in a race against time, as are all the Giants to digitize all the world's records so they can prevent any further deterioration in the records now on paper and film. This is a worldwide problem for all our historic records: paper and film have a shelf life that's not very long. Our history is disappearing. FamilySearch is fighting back by aggressively ramping up the number of digitizers working on their records. In 2020 average monthly additions to their records were in excess of 25 million per month. And since then, since the beginning of 2021 in particular, they have been adding 30-38 million records a month to their online database. This is outstanding. Hey, can I just interject? Sure. Now these records, are they like PDFs? Books? Photographs? (Ans. All of the above.) Wow. Further in addition to working on their own records, most of which are not currently available to see, they are also one of the major organizations that digitize for others. Both familysearch.org and Ancestry.com, another one of the Giants, are digitizing partners for the National Archives of the United States (that would be NARA for short), just to give you one example. When they do a project for others, they often negotiate to have an exclusive right to publish those records on their own site, with the images attached, for a period of time. You know, Carolyn, we would probably be remiss if we didn't mention something that may be of significance to you and our listeners. This is meant as information, not judgment. The Church of Jesus Christ of the Latter Day Saints has several practices that are not common to other faiths, one of which in particular affects FamilySearch users; namely, they baptize for the dead, which is part of what they called Temple Work or Temple Ordinances. If you look on Family Search for those terms, or simply Google them with the churches name, you'll find a number of articles explaining these practices in further detail. We suggest you investigate this before deciding whether to add your family members to their worldwide tree. It is a primary place that the church members go to find the names of those who have not yet had temple ordinances administered. This doesn't mean anything to many people, but to others, it is very important. So if these practices are a problem for you, please do not add your information to their family tree. You do not have to have your information on their site in order to do your research there. You do need to register for a free account with them in order to access their records, and it's really a good deal. It's free. Since the image of the original record is your actual evidence of the facts, not the transcription, that agreement is quite valuable to anyone who is involved in genealogy. The transcription should back up the image to reduce errors from getting into the system and to help those majority of us (who cannot read Latin or old or foreign handwriting) to make the image useful to us. (I can't do that.) How well this works is a different issue and varies from company to company, but I can assure you that FamilySearch has extensive educational resources to teach their digitizers the things they need to know to do a good job. They also have a huge number of books, periodicals and genealogies to peruse on line, and way more to come. You know, I'd like to just annex our little discussion here on FamilySearch. One of the most important things that I have found in my genealogical research and my sharing of my genealogical research is a thing called GEDCOM. A gedcom is basically an anacronym that stands for GEnealogical Data COMmunications. It basically is like a little suitcase that you can take anything that you found on your genealogical family tree and put it into this little digital suitcase, and you send it to somebody else. It has all your ancestors' information in it: all of the resources, all the citations, all the images. It has everything to do with whatever you have found. The inventor of this was, believe it or not, FamilySearch. FamilySearch has so much technological background, and they have been the technological leader in genealogy. But there is a problem, they really aren't into, how should I say, utilizing the gedcom completely? Not so much. In essence, they do allow for uploading of a gedcom to a FamilySearch family tree. However, you can upload to a family tree, but I tried this and it really only allows you to upload something like 300 MB. Well, I have 8256 members in my family tree; that's kind of a large Gedcom - I think it's somewhere around 2 gigs of data, and that includes, of course, photos and and all kinds of other stuff that I have in there - PDFs and everything else I have in that gedcom. This might work for a beginning family tree, but not so much for somebody who had a lot of information in their family tree. So then we come to exporting a gedcom. Exporting a gedcom is very important because if you're going to take what you did on FamilySearch and you want to put it on your computer, into an application on your computer (say like Rootsmagic or MyHeritage or Mac Family Tree), now you're not going to be able to do it if you don't have a gedcom from your previous platform. So basically FamilySearch does not allow for direct exporting of your information from FamilySearch. If you do have an application, say Rootsmagic, you are able to export gedcom of the information that you collected from FamilySearch, but you know, the thing is you're also going to export all the other information that you got from other sources as well. So I just wanted to make a note about gedcoms. One of the most important things for any geologist, I think, is the gedcom - to preserve the information that you have collected. So, for things unique to familysearch.org are: 1. they are the only non-profit of the group – and therefore have a different motivation; 2. they have an abundance of learning opportunities - it's just terrific; 3. it is the only genealogical giant to be completely free to all users; but you must open an account with them so that they can know who they are dealing with. Fair is fair. 4. they have a seemingly endless supply of Records to search, with new stuff coming online everyday – and this will continue long into the future. So, I guess that's about it. You got anything else there? Carolyn: I have to trust you, you're the techie. Definitely not me. Paul: The editor in chief. We work well together. So everybody, we look forward to your being at our next presentation and that will be on Ancestry.com, one of the Genealogical Giants. As usual, if you want a copy of this transcript, go into our podcast transcription file (at http://www.familydigging.com) and pull out the source for yourself. We also have links and genealogical files. Paul will have a PDF in there on Gedcom in particular, and you're welcome to them and we hope you enjoy them. If you want to be notified when our next podcast is available, you need to subscribe so we can send you an email to say "We're up again." Also, just to make note, if you ever want to directly email us, we have a email address: [email protected]. Feel free to drop us, a line and add suggestions or whatever for future podcasts. So I guess that's it for this this podcast; we'll see you next time. Bye. 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Colored Ray Configurations Ruy Fabila-Monroy∗ Alfredo García† Ferran Hurtado‡ Rafał Jaume§ Pablo Pérez-Lantero¶ Maria Saumell∥ Rodrigo I. Silveira** Javier Tejel† Jorge Urrutia†† Abstract We study the cyclic sequences induced at infinity by pairwise-disjoint colored rays with apices on a given balanced bichromatic point set, where the color of a ray is inherited from the color of its apex. We derive a lower bound on the number of color sequences that can be realized from any fixed point set. We also examine sequences that can be realized regardless of the point set and exhibit negative examples as well. In addition, we provide algorithms to decide whether a sequence is realizable from a given point set on a line or in convex position. 1 Introduction Let $P = \{p_1, \ldots, p_n\}$ be a set of $n$ points in the plane and let $Q = \{q_1, \ldots, q_n\}$ be a set of $n$ pairwise-disjoint rays such that $q_i$ has apex $p_i$, for $i \in \{1, \ldots, n\}$. These rays induce at infinity a cyclic permutation of the numbers $\{1, 2, \ldots, n\}$, defined by the indices of the rays. If we assume that $P$ is in general position, how many different permutations can always be obtained disregarding the geometry of $P$? Is there an upper bound for their number for all sets of $n$ points? What happens in some particular configuration, for example when $P$ is in convex position? These problems—and several related questions—were introduced by García et al. [7]. A clear motivation for the research in [7] was the extensive investigation that has been going on counting the number of non-crossing geometric graphs of several families, such as spanning cycles, perfect matchings, triangulations and many more, and on estimating how large these numbers can get [1, 4, 9, 14, 15, 16]. On the other hand, arrangements of rays have appeared in graph representation: Ray Intersection Graphs are graphs in which there is a node for every ray in a given set and an adjacency when two of the rays intersect [3, 6, 17]. Finally, on the applied side, it is worth mentioning recent work on sensor networks in the plane in which each sensor coverage region is an arbitrary ray [12]. The rays act as barriers for detecting the movement between regions in the arrangement. In this paper we consider a natural variation on the problem in [7]: the point set consists now of red and blue points, and the ray we shoot from a point inherits its color. We investigate the binary circular sequences that the colored rays induce at infinity: We study how many different color patterns can always be obtained (in order of magnitude) and how many color alternations, depending on the generality of the position of the points (Section 3). We also investigate whether there are color patterns that are forbidden or universal, in the sense of their dependence on the point set (Section 4). In addition, we provide decision algorithms for some particular cases (Section 5) and include remarks on additional issues not developed in this short paper (Section 6). 2 Initial notation and definitions Henceforth, $\mathbb{N}$ will denote the positive integers. Given $k \in \mathbb{N}$, we denote by $[k]$ the set of integers $\{1, \ldots, k\}$. Let $S = R \cup B$ be a finite bichromatic point set, where $R$ is the set of red points and $B$ is the set of blue points. We require $S$ to be balanced ($\|R\| = \|B\|$), which is the variant that has received most attention in the family of problems on red-blue point sets [11]. Given any finite point set $X$ of $m$ points in the plane, and a set $H$ of $m$ pairwise-disjoint rays, each one having apex at a point in $X$, we say that $H$ is a set of rays from $X$. When $X$ is a colored point set, we assign to each ray the color $(r$ or $b)$ of its apex. Given a set $H$ of rays from $S$, let $C(S, H)$ denote the circular sequence of length $\|S\|$ in the alphabet $\{r, b\}$ induced by the rays at infinity, taken in clockwise order. Equivalently, we can take any circle large enough to enclose $S$ and think of $C(S, H)$ as the clockwise sequence... of the colored intersection points of the rays with the circle. Given a positive integer $ n $, we call any circular sequence of $ 2n $ elements in the alphabet $ \{r, b\} $ consisting of $ n $ red elements and $ n $ blue elements a configuration. We assume hereafter that any configuration $ C $ starts with a red element and ends with a blue one. Notice that $ C $ can be partitioned into $ 2k $ blocks $ c_1, c_2, \ldots, c_{2k} $ for some $ k \in \mathbb{N} $, where for $ i \in [2k] $ all elements of $ c_i $ are red if $ i $ is odd, and all elements are blue if $ i $ is even. We say that $ k $ is the alternation number of $ C $. Hence, $ C $ can be identified with the tuple $ (r_1, b_1, r_2, b_2, \ldots, r_k, b_k) $, where $ r_i $ is the number of (red) elements in $ c_{2i-1} $ and $ b_i $ the number of (blue) elements in $ c_{2i} $, for $ i \in [k] $. Let $ \Gamma(n) $ denote the number of configurations or, equivalently, the number of binary balanced necklaces. It holds that \[ \frac{1}{2n} \binom{2n}{n} \leq \Gamma(n) = \frac{1}{2n} \sum_{d\|n} \varphi(d) \binom{2n/d}{n/d} \leq \binom{2n}{n}, \] where $ \varphi $ is Euler’s totient function [13]. Consequently, we have $ \Gamma(n) = \Theta^(4^n) $.$^1$ Given $ S $ and a configuration $ C $, we say that $ C $ is realizable (or feasible) from $ S $ if there exists a set $ H $ of pairwise-disjoint rays from $ S $ such that $ C = C(S, H) $. We also say in this situation that $ C $ is realized by $ H $ (from $ S $). See Figure 1 for an example. We say that a configuration is universal if it is feasible from any point set of the corresponding size. ![Figure 1: A point set and a realization of the configurations $ rbrb $ (left) and $ rrbb $ (right).](image) Given a directed line $ \ell $, let $ \ell^+ $ and $ \ell^- $ denote the sets of points to the right and to the left of $ \ell $, respectively. Given a point $ p $ and a vector $ v $ in the plane, let $ h(p, v) $ denote the ray $ \{p + t \cdot v \mid t \in \mathbb{R}, t \geq 0\} $ with apex $ p $. Let $ H' $ be a set of rays such that for every pair $ h_1, h_2 \in H' $ the intersection $ h_1 \cap h_2 $ is either empty or contains an infinite number of points. In this case we say that $ H' $ is a set of non-crossing rays. For any such a set $ H' $ there exists a small enough angle $ \delta > 0 $, such that for all possible angles $ \varepsilon \in (0, \delta) $ the set $ H'_\varepsilon $ of rays—called a perturbation of $ H' $, and obtained by performing a counterclockwise rotation of angle $ \varepsilon $ on every ray of $ H' $ around its apex—is a set of pairwise-disjoint rays. Let $ \gamma(S) $ denote the number of different feasible configurations $ C(S, H) $ over all the sets $ H $ of rays from $ S $. Observe that this number can be just a constant: for example, placing $ n $ red points on the $ x $-axis followed by $ n $ blue points, we obtain a set $ T $ in which the only feasible configuration is $ (n, n) $, and hence $ \gamma(T) = 1 $. To avoid these trivial situations, we consider only point sets in general position, that is, without collinear triples. However, we obtain better bounds if we assume strong general position, in which we require that no two different pairs of points in $ S $ define parallel lines. Let $ \gamma_{sgp}^{\min}(n) $ and $ \gamma_{sgp}^{\max}(n) $ be the minimum and the maximum of $ \gamma(S) $, respectively, taken over all balanced bichromatic sets $ S $ of $ 2n $ points in the plane in strong general position. The notations $ \gamma_{sgp}^{\min}(n) $ and $ \gamma_{sgp}^{\max}(n) $ correspond mutatis mutandis to the case in which only general position is required. ### 3 Bounds on $ \gamma(S) $ and on the alternation number Theorem 1* For every bichromatic point set $ S = R \cup B $ in strong general position with $ \|R\| = \|B\| = n $, it holds $ \gamma(S) = \Omega(2\sqrt{n}/n) $. Hence, $ \gamma_{sgp}^{\min}(n) = \Omega(2\sqrt{n}/n) $. Proof. By the Ham-Sandwich Cut Theorem [8], there exists a (directed) line $ \ell $ such that $ \|R^+\| = \|B^-\| = \lfloor n/2 \rfloor $, where $ R^+ = R \cap \ell^+ $ and $ B^- = B \cap \ell^- $. Let $ m = \lfloor n/2 \rfloor $. We can assume, via a virtual rotation of the coordinate system, that $ \ell $ is the positively oriented $ x $-axis. Since $ \|R^+\| = \|B^-\| = m $, there exists a non-crossing geometric perfect matching on $ R^+ \cup B^- $, that is, $ m $ pairwise-disjoint straight-line segments $ e_1, e_2, \ldots, e_m $ such that $ e_i $ connects an element of $ R^+ $ with an element of $ B^- $ and also intersects $ \ell $, for $ i \in [m] $. Indeed, it is well-known that given $ t $ red points and $ t $ blue points in the plane in general position, there is always a crossing-free bichromatic perfect matching (since the bichromatic perfect matching minimizing the total edge length is necessarily crossing-free). Assume without loss of generality that the points $ e_1 \cap \ell, e_2 \cap \ell, \ldots, e_m \cap \ell $ are sorted from left to right. Using the Erdős-Szekeres Theorem on sequences [5], there exist $ k = \Omega(\sqrt{m}) = \Omega(\sqrt{n}) $ indices $ 1 \leq i_1 < i_2 < \ldots < i_k \leq m $ such that the clockwise angles from the segments $ e_{i_1}, e_{i_2}, \ldots, e_{i_k} $ to $ \ell $ are either monotonically increasing or monotonically decreasing. Assume without loss of generality that the angles are monotonically decreasing and observe that, because of the assumption of strong general position, they decrease strictly. Let $ p_j \in B^- $ and $ q_j \in R^+ $ denote the endpoints of $ e_{i_j} $, for $ j \in [k] $. Let $ H_R = \{h(q_j, p_j - q_j) \mid j \in [k]\} $ and $ H_B = \{h(q_j, p_j - q_j) \mid j \in [k]\} $, and observe that the elements of $ H_R $ (resp. $ H_B $) are pairwise disjoint. Let $ H_0 $ be a set of rays from $ S \setminus (\{p_j \mid j \in [k]\} \cup \{q_j \mid j \in [k]\}) $ such that every element of $ H_0 $ does not intersect, and is not parallel to, any element of $ H_R \cup H_B $; it is clear that such a set of rays $ H_0 $ always exists, and that $ H_R \cup H_B \cup H_0 $ is --- $^1$The * means that subexponential factors are omitted. a set of non-crossing rays. Furthermore, we can perturb the elements of $ H_p \cup H_g $ in $ 2^k $ different ways to obtain a set $ H $ of pairwise-disjoint rays from $ S $. The perturbation is as follows: For a small enough angle $ \varepsilon > 0 $ and $ j \in [k] $, rotate both $ h(q_j, p_j - q_j) $ and $ h(q_j, p_j - q_j) $ with angle $ \varepsilon $ around their apices, either clockwise or counterclockwise. Then, among all sets $ H $, the configuration $ C(S, H) $ is different for at least $ 2^k / 2n = \Omega(2^{1/3} / n) $ of them. The claim follows. Theorem 2 For every bichromatic point set $ S = R \cup B $ in strong general position with $ \|R\| = \|B\| = n $, there exists a set $ H $ of pairwise-disjoint rays from $ S $ such that the alternation number of $ C(S, H) $ is $ \Omega(\sqrt{n}) $. This bound is tight. Proof. Observe that the sets of rays from $ S $ generated in the proof of Theorem 1 yield $ \Omega(\sqrt{n}) $ color switches. To prove that this bound is tight, let $ n = k^2 $ for some $ k \in \mathbb{N} $ and $ R $ and $ B $ be defined as follows. For $ i \in [k] $, let $ B_i = \{(2(i-1) + j/n^2, 0) \mid j \in [k]\}, B = \bigcup_{i \in [k]} B_i $ and $ R = \{(j/n, 1) \mid j \in [n]\} $. Let $ s_i $ be the smallest segment covering $ B_i $, for $ i \in [k] $, and $ s' $ the smallest segment covering $ R $. Observe that no two rays from elements of $ R $ can intersect the same segment $ s_i $. Furthermore, no two rays from $ b_1 \in B_i $ and $ b_2 \in B_j $ with $ i, j \in [k], i \neq j $, can intersect $ s' $. Therefore, any set $ H $ of pairwise-disjoint rays from $ S = R \cup B $ is such that $ C(S, H) $ has $ O(k) = O(\sqrt{n}) $ alternations. Finally, observe that some infinitesimal perturbation of the points moves them to strong general position, and still yields the same upper bound construction. Without the assumption of strong general position many of the segments in the matching used in the proof of Theorem 1, or even all of them, might be parallel, which disables the construction in that proof. It is easy to see that given a set of $ n $ red points above the $ x $-axis and a set of $ n $ blue points below the $ x $-axis, whose union is in general position, one can always obtain a bichromatic matching of size at least $ \sqrt{n} $, such that the angles defined by the matched segments and the $ x $-axis are different. This combines with the technique of Theorem 1 to yield an $ \Omega(2^{1/4} / n) $ lower bound for the number of different configurations realizable from point sets in general position. We can do better with a related yet different approach. Theorem 3 For every bichromatic point set $ S = R \cup B $ in general position with $ \|R\| = \|B\| = n $, it holds $ \gamma(S) = \Omega(2^{n/3} / n) $. Hence, $ \gamma_{\text{BP}}^{\min}(n) = \Omega(2^{n/3} / n) $. Proof. We start as in the proof of Theorem 1 and obtain (after a virtual rotation) a bichromatic non-crossing geometric perfect matching of a set $ R^+ $ of $ m $ red points below the $ x $-axis, and a set $ B^- $ of $ m $ blue points above the $ x $-axis, with $ m = \Theta(n) $. Now, using a generalized version of the Erdős–Szekeres Theorem on sequences$^2$ [10], there exist $ k = \Omega(m^{1/3}) = \Omega(n^{1/3}) $ indices $ 1 \leq i_1 < i_2 < \ldots < i_k \leq m $ such that the clockwise angles from the segments $ e_{i_1}, e_{i_2}, \ldots, e_{i_k} $ to the $ x $-axis are either monotonically strictly increasing, or monotonically strictly decreasing, or all equal. Let $ S_e $ denote the set of endpoints of $ e_{i_j} $ for $ j \in [k] $. In the first two cases we apply entirely the technique in the proof of Theorem 1. When $ e_{i_1}, e_{i_2}, \ldots, e_{i_k} $ are all parallel, let us start with a line $ \ell_p $ through each $ p \in S $, in the direction of the segments, and rotate then $ \ell_p $ around $ p $ an infinitesimal angle $ \varepsilon $ for all $ p \in S_e $, in such a way that none of them contains two points. Rotating the whole construction if necessary, assume that the new lines $ \ell'_p $ are vertical. Observe that the lines corresponding to the endpoints of a segment $ e_{i_j} $ are now different and consecutive in the horizontal order, for $ j \in [k] $. Now shoot vertically a ray downwards from every point in $ S \setminus S_e $. For each $ e_{i_j} $ with $ j \in [k] $ we can independently decide for its endpoints whether we shoot a red ray upwards and a blue ray downwards, or reversely. This yields $ \Omega(2^{n/3} / n) $ different configurations, and the claim is proved. ### 4 Realizing configurations We study in this section point sets realizing many configurations, universal and non-universal configurations. Observe that, as a consequence of Theorem 2, configurations with $ \omega(\sqrt{n}) $ alternations are not realizable from every point set. Further note that given any point set $ S = R \cup B $ with $ \|R\| = \|B\| = n $, the configuration $(n, n)$ is always realizable: Draw from each red point a ray oriented to the right, and from each blue point a ray oriented to the left. The resulting rays are non-crossing and a perturbation $ H $ of them satisfies $ C(S, H) = (n, n) $. Theorem 4 There exist point sets $ S = R \cup B $ in strong general position with $ \|R\| = \|B\| = n $, such that every configuration is feasible. Hence, $ \gamma_{\text{sgp}}^{\max}(n) = \Gamma(n) $. Proof. Let point sets $ R = \{(1, 1), (2, 1), \ldots, (n, 1)\} $ and $ B = \{(1/n, 0), (2/n, 0), \ldots, (n/n, 0)\} $. Let $ C $ be any configuration $(r_1, b_1, r_2, b_2, \ldots, r_k, b_k)$ with $ k \in \mathbb{N} $. Observe that we can draw a set $ H_B $ of rays from $ B $ such that the elements of $ H_B $ are grouped into $ k $ groups, such that the $ i $th group for $ i \in [k] $ consists of $ b_i $ parallel rays, and the groups split $ R $ into $ k $ blocks such that the $ j $th block from left to right consists of $ r_j $ points, for $ j \in [k] $. Namely, let $ H_B = \{h((i/n, 0), (i, 1)) \mid i \in [n]\} $ where $^2$Let $ n > s \cdot r \cdot p $. Any sequence of $ n $ numbers contains a strictly increasing subsequence with at least $ s + 1 $ elements, a strictly decreasing subsequence with at least $ r + 1 $ elements or a constant subsequence of length greater than $ p $. $t_i = r_1 + \ldots + r_n$ for $$b_1 + \ldots + b_{n-1} < i \leq b_1 + \ldots + b_n.$$ Given $H_B$, we can draw a set $H_R$ of rays “upwards” from $R$ such that $H = H_R \cup H_B$ is a set of pairwise-disjoint rays from $S$. It holds $C(S, H) = C$. The constructed point set can be perturbed to lie in strong general position in a way that the proof carries out. Proposition 5 For every bichromatic point set $S = R \cup B$ in general position with $\|R\| = \|B\| = n$, the configuration $(\lfloor n/2 \rfloor, \lfloor n/2 \rfloor, \lceil n/2 \rceil, \lfloor n/2 \rfloor)$ is feasible. Proof. Assume $n$ to be odd. The case in which is even is similar. By the Ham-Sandwich Cut Theorem [8], there exists a (directed) line $\ell$ passing through a red point $p$ and a blue point $q$, and such that $$\|R \cap \ell^+\| = \|B \cap \ell^+\| = \|R \cap \ell^-\| = \|B \cap \ell^-\| = \lfloor n/2 \rfloor.$$ Suppose without loss of generality that $\ell$ is horizontal and that $p$ is to the right of $q$, and let $$H' = \{h(p, p - q), h(q, q - p)\}$$ $$\cup \{h(u, u - p) \mid u \in (R \cap \ell^+) \cup (B \cap \ell^-)\}$$ $$\cup \{h(u, u - q) \mid u \in (R \cap \ell^-) \cup (B \cap \ell^+)\}.$$ Observe that $H'$ is a set of non-crossing rays, and a perturbation $H$ of $H'$ is a set of pairwise-disjoint rays from $H$ such that $C(S, H)$ is $(\lfloor n/2 \rfloor, \lfloor n/2 \rfloor, \lceil n/2 \rceil, \lfloor n/2 \rfloor)$. Proposition 6 For every bichromatic point set $S = R \cup B$ in general position with $\|R\| = \|B\| = n$, and any $t \in [n-1]$, either the configuration $(n-1, n-t, t, 1, t)$ or the configuration $(n-t, 1, t, n-1)$ is feasible. Proof. Let $p \in S$ be a point of the convex hull of $S$. We now show that if $p \in R$, then $(n-1, n-t, 1, t)$ is feasible. If $p \in B$, it can be shown analogously that $(n-t, 1, t, n-1)$ is feasible. Assume then that $p \in R$, and let $q \in B$ be a point such that $\|B \cap \ell^-\| = t-1$, where $\ell$ is the line passing through $p$ and $q$. Let $$H' = \{h(p, p-q)\}$$ $$\cup \{h(u, q-p) \mid u \in R \setminus \{p\}\}$$ $$\cup \{h(u, p-q) \mid u \in B\},$$ which is a set of non-crossing rays. A perturbation $H$ of $H'$ is such that $C(S, H) = (n-1, n-t, 1, t)$. In contrast with some of the previous configurations having alternation number two, we next show an obstacle for several configurations with alternation number three to be universal. Proposition 7 Let $\mathcal{C}$ be an infinite family of configurations such that any configuration $C \in \mathcal{C}$ of length $n$ has alternation number at least three, every red block of $C$ has size at least $n/k$ and every blue block of $C$ has size at least $n/l$, where $k, l \in \mathbb{R}$. Then, there exists $n_0 \in \mathbb{N}$ such that any $C \in \mathcal{C}$ of size $n > n_0$ is not universal. In particular, the uniform configuration $(n/k, n/k, ..., n/k, n/k)$ with $k \geq 3$ and $n/k \in \mathbb{N}$ is not universal for big enough $n$. In order to prove the previous proposition, we use two technical lemmas, whose proof is omitted. Given a real number $\lambda > 0$, let $K_\lambda(n)$ be the set of $n$th (complex) roots of the unity, taken as points in the real plane, and scaled by a factor of $\lambda$. The width of a point set $T$ is the width of the thinnest slab (closed space between two parallel lines) enclosing $T$. Lemma 8 The width of any set $T \subset K_1(n)$ with $3 \leq t = \|T\| \leq \lfloor n/2 \rfloor$ is at least $$\cos \left( \frac{\pi}{n} \right) - \cos \left( \frac{(t-1)\pi}{n} \right).$$ Given a point $p$ outside the unit disk, we define $V_p$ to be the open wedge defined by the rays starting at $p$ and tangent to the unit circle, and containing the origin. Lemma 9 For any $p \in K_\lambda(n)$ with $\lambda > 1$, it holds $$\|(K_\lambda(n) \cap V_p)\| \leq \frac{2n}{\pi} \arcsin \left( \frac{1}{\lambda} \right) + 1.$$ We prove now Proposition 7; see Figure 2. Proof of Proposition 7. Note first that it must be $k, l \geq 3$ since there are at least three blocks of each color. In addition, we also have $n \geq 3k$ and $n \geq 3l$. Let $R = K_1(n)$ and $B = K_\lambda(n)$ with $\lambda > 1$, and $X_R$ and $X_B$ be the circles containing $R$ and $B$, respectively. Using Lemma 8, it is easy to see that if $\lambda$ is smaller than $$g(n) = \left[ \cos \left( \frac{\pi}{n} \right) - \cos \left( \frac{(\lceil \frac{n}{k} \rceil - 1)\pi}{n} \right) \right] \left[ 2 \sin \left( \frac{\pi}{n} \right) \right]^{-1},$$ the rays emanating from a subset $ R_1 \subset R $ realizing a block of the configuration will have to cross at least two arcs of $ X_B $ of between points of $ B $, since the first factor is a lower bound for the width of $ R_1 $ and the distance between two consecutive points of $ B $ is $ 2\lambda \sin(\pi/n) $. Therefore, the ray from at least one point $ b_1 \in B $ will have to intersect $ X_B $ because, otherwise, it would split the block of $ R_1 $. Let $ b_1, b_2, b_3 \in B $ be points trapped in three different sets $ R_1, R_2, R_3 \subset R $, each of the latter realizing a red block. Note now that it has to be $ b_2, b_3 \in V_{b_1} \cup V_{-b_1} $, where $-b_1$ indicates the point in $ X_B $ symmetric to $ b_1 $ with respect to the origin, since the rays $ q_2 $ placed at $ b_2 $ and $ q_3 $ placed at $ b_3 $ should split $ R $ and they should not intersect the ray $ q_1 $ placed at $ b_1 $. Observe that either $ V_{b_1} $ or $ V_{-b_1} $ must contain at least two of the points $ b_1, b_2 $ and $ b_3 $. Assume these to be $ b_1 $ and $ b_2 $. Note then that only the points from the two arcs of $ X_B $ between $ q_1 $ and $ q_2 $ can realize a blue block between $ R_1 $ and $ R_2 $. With the help of Lemma 9 to bound the number of points of $ B $ in these arcs, we have that if $ \lambda $ is larger than \[ f(n) = \left\lceil \sin \left( \frac{\pi}{4n} \left( \left\lfloor \frac{n}{\ell} \right\rfloor - 2 \right) \right) \right\rceil^{-1}, \] no block of $ B $ can be realized between $ R_1 $ and $ R_2 $. Thus, for $ n $ and $ \lambda $ such that $ 1 < f(n) < \lambda < g(n) $, the configuration is not feasible. Since $ g(n) \to \infty $ and $ f(n) \to [\sin(\pi/4\ell)]^{-1} > 1 $, the counterexample can be certainly constructed. 5 Deciding feasibility of configurations Proposition 10 Given a point set $ S = R \cup B $ on a line $ \ell $, with $ \|R\| = \|B\| = n $, and a configuration $ C $, it can be decided in $ O(n^2) $ time whether $ C $ is feasible for $ S $. Proof. Without loss of generality, assume that $ \ell $ is horizontal, and put $ S = \{p_1, \ldots, p_{2n}\} $, where the indices are taken from left to right. Note that any realization from $ S $ can be perturbed such that all the rays are vertical. The point $ p_1 $ must realize a position of its same color in $ C $. Then, $ p_2 $ will realize either the previous position of the configuration or the next one, depending on whether the corresponding ray is pointing downwards or upwards. One, two or none of the previous options will be valid depending on whether the color of the previous and next positions of $ C $ match the color of $ p_2 $. In this way, when we traverse $ S $ from left to right choosing the upwards ray or the downwards one for each point, we may be realizing a subsequence of consecutive elements in $ C $. Consider the directed graph having a node for each one of the $ O(n^2) $ subsequences of $ C $. Note that we consider as different two equal red-blue patterns if they start at different positions of $ C $. We add an arc from a node corresponding to a subsequence of length $ k \geq 0 $ to a node corresponding to a subsequence of length $ k + 1 $ if the second subsequence can be obtained from the first one by attaching the color of $ p_{k+1} $ before or after it. It is clear that a configuration is feasible for $ S $ if and only if there exists a path from the empty sequence to some of the $ 2n $ linear subsequences of $ C $ of length $ 2n $ in the aforementioned directed graph. Since the out-degree of every node is at most 2, the size of the graph is quadratic and the decision can be made in $ O(n^2) $ time. The preceding algorithm is an adaptation of the algorithm of Akiyama and Urrutia for deciding, given $ 2n $ points on a circle, $ n $ of them being red, and $ n $ blue, whether they admit a simple Hamiltonian polygonal path in which the colors of the vertices alternate [2]. Proposition 11 Given a set of points $ S = R \cup B $ in convex position, with $ \|R\| = \|B\| = n $, and a configuration $ C $, it can be decided in polynomial time whether $ C $ is feasible for $ S $. We present now some of the ideas of the omitted proof of the previous proposition. We derive a decision algorithm based on dynamic programming. First, the problem is discretized taking advantage of a perturbation argument appearing in [7], which ensures that to decide if a configuration is feasible it is enough to examine only the rays taking directions from a set of $ O(n^2) $ vectors. Next, we observe that if a ray $ q $ supported by a line $ \ell $ “crosses” the set $ S $, and neither $ S^+ = S \cap \ell^+ $ nor $ S^- = S \cap \ell^- $ is empty, then the position of the configuration realized by $ q $ must be “between” the positions realized from $ S^+ $ and the positions realized from $ S^- $. Therefore, the points in $ S^+ $ and the points in $ S^- $ must be able to realize the corresponding parts of the configuration. These subproblems are not completely independent. Indeed, even if all the rays are disjoint from $ q $, the rays from $ S^+ $ are pairwise disjoint and so are the rays from $ S^- $, it could be that a ray from $ S^+ $ intersects a ray from $ S^- $. In order to decide whether “compatible” realizations exist, we compute the (partial) realizations from $ S^+ $ and from $ S^- $ that minimize the “angle” with $ q $. If these realizations are not compatible, then no other pair of realizations are. Computing a minimal realization for each subproblem is easy if we assume that there is no other ray “crossing” the point set. Nonetheless, when we allow more than one ray to cross, the computation becomes more involved. More precisely, we need to calculate for any pair of rays and any pair of positions of the configuration, all the partial realizations of the points “between” them that are angularly minimal. Note though that there are two angles to be minimized (in the domination order) in this case and, thus, the number of such realizations is $ O(n^2) $. The corresponding angles (and a realization attaining each of them) can be constructed recursively using dynamic programming. The base case is when no ray crosses, in which case it is straightforward to compute all the realizations that are angularly minimal. 6 Remarks In addition to the results presented above, we also studied a variant of the problem, where the rays are allowed to (properly) intersect. The nature of this problem is significantly different from the disjoint case. For instance, it is easy to see that all configurations of $n$ red and $n$ blue elements can be realized from any point set with that number of red and blue points. However, we can show that for certain configurations any set of realizing rays must have a quadratic number of intersections. Yet another version of the question is which configurations can be realized by a set of pairwise-crossing rays. This condition is specially interesting, since any configuration realizable by pairwise-crossing rays can be realized by pairwise-disjoint rays as well (the converse is not true). Although there exist universal point sets for this problem, it can be shown that there is no universal configuration. Acknowledgments. This work started at the 2nd International Workshop on Discrete and Computational Geometry, held in Barcelona in July 1-5, 2013. R. Fabila-Monroy is supported by CONACyT of Mexico grant 153984. F. Hurtado, R. Silveira, J. Tejel and A. García are partially supported by projects MINECO MTM2012-30951, ESF EUROCORES programme EuroGIGA, CRP ComPoSe: MICINN Project EUI-EURC-2011-4306, F. Hurtado and R. Silveira are partially supported by Gen. Cat. DGR20098GR1040 and DGR2014SGR46. A. García and J. Tejel are partially supported by Gob. Arag. E58-DGA. R. Jaume is supported by “obra social La Caixa” and the DAAD. P. Pérez-Lantero is partially supported by project CONICYT, FONDECYT/Iniciación 11110069 (Chile), and Millennium Nucleus Information and Coordination in Networks ICM/FIC P10-024F (Chile). M. Saumell is supported by projects NEXLIZ - CZ.1.07/2.3.00/30.0038, which is co-financed by the European Social Fund and the state budget of the Czech Republic, and ESF EuroGIGA project ComPoSe as F.R.S.-FNRS - EUROGIGA NR 13604. R. Silveira was funded by Portuguese funds through CIDMA and FCT, within project PEst-OE/MAT/UI14106/2014, and by FCT grant SFRH/BPD/88455/2012. J. Urrutia is partially supported by Consejo Nacional de Ciencia y Tecnología, CONACYT (Mexico), grant number CB-2012-01-0178379. We thank Javier Cano, Clemens Huemer, Alberto Márquez, and Vera Sacristán for helpful discussions. References [1] O. Aichholzer, T. Hackl, C. Huemer, F. Hurtado, H. Krasser, and B. Vogtenhuber. On the number of plane geometric graphs. Graphs and Combinatorics, 23(1) (2007), 67-84. [2] J. Akiyama, and J. Urrutia. Simple alternating path problem. Discrete Mathematics 84 (1) (1990), 101-103. [3] S. Cabello, J. Cardinal, and S. Langerman, The Clique Problem in Ray Intersection Graphs. Discrete & Computational Geometry 50(3) (2013), pp. 771-783. [4] A. Dumitrescu, A. Schulz, A. Sheffer, and C. D. Tóth, Bounds on the maximum multiplicity of some common geometric graphs, SIAM Discrete Math. 27 (2) (2013), 802826. [5] P. Erdős, G. Szekeres, A combinatorial problem in geometry. Compositio Mathematica 2 (1935), pp. 463–470. [6] S. Felsner, G. B. Mertzios, and I. Musta. On the Recognition of Four-Directional Orthogonal Ray Graphs. Proc. 38th International Symposium on Mathematical Foundations of Computer Science, volume 8087 of Lecture Notes in Computer Science, pp. 373-384. Springer, (2013). [7] A. García, F. Hurtado, J. Tejel, and J. Urrutia. On the number of non-crossing ray configurations. Manuscript, submitted. Abstract with preliminary results in XII Encuentros de Geometría Computacional, Valladolid, Spain, 2007, pp. 129-134. [8] J. E. Goodman and J. O’Rourke, editors. Handbook of discrete and computational geometry. CRC Press, Inc., Boca Raton, FL, USA, second edition, 2004. [9] M. Hoffmann, M. Sharir, A. Sheffer, C. D. Tóth, and E. Welzl. Counting Plane Graphs: Flippability and its Applications. Proc. 12th Symp. on Algs. and Data structs., (2011), 524–535. [10] S. Jukna. Extremal Combinatorics With Applications in Computer Science, Springer-Verlag (Second Edition), Series Texts in Theoretical Computer Science XXIV, page 71 exercise 4.12. [11] A. Kaneko, and M. Kano. Discrete geometry on red and blue points in the plane – a survey. Discrete and Computational Geometry, The Goodman-Pollack Festschrift. Springer, Algorithms and Combinatorics series, Volume 25, 2003, pp. 551-570. [12] D. Kirkpatrick, B. Yang and S. Zilles. On the barrier-resilience of arrangements of ray-sensors. Proc. of the XV Sanish Meeting on Computational Geometry, Seville, Spain, June 2013, pp. 35-38. [13] C. Moreau. Sur les permutations circulaires distinctes. Nouvelles annales de mathématiques, journal des candidats aux écoles polytechnique et normale, Sér. 2, tom. 11 (1872), pp. 309–314 [14] M. Sharir and A. Sheffer. Counting triangulations of planar point sets. Electr. J. Comb., 18(1) (2011). [15] M. Sharir, A. Sheffer, and E. Welzl. Counting Plane Graphs: Perfect Matchings, Spanning Cycles, and Kasteleyn’s Technique. J. Combinat. Theory A, 120 (2013), 777–794. [16] M. Sharir, E. Welzl. On the number of crossing-free matchings, (cycles, and partitions). SIAM J. Comput. 36(3) (2006), pp. 695–720. [17] A. Shrestha, Sa. Tayu, S. Ueno. On orthogonal ray graphs. Discrete Applied Mathematics 158(15) (2010), pp. 1650-1659.	<urn:uuid:a309e8bf-5281-4bb6-9dd2-4098d27281db>	CC-MAIN-2018-47	http://cccg.ca/proceedings/2014/papers/paper59.pdf	2018-11-18T20:32:04Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-47/segments/1542039744649.77/warc/CC-MAIN-20181118201101-20181118223101-00194.warc.gz	68,820,361	10,015	eng_Latn	eng_Latn	0.952616	eng_Latn	0.977028	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	docling	[ 4085, 10501, 17038, 21572, 28078, 33389 ]
Non-Dirac topological surface states in (SnTe)n≥2(Bi2Te3)m=1 S. V. Eremeev Institute of Strength Physics and Materials Science, 634021, Tomsk, Russia Tomsk State University, 634050 Tomsk, Russia and Saint Petersburg State University, Saint Petersburg, 198504, Russia T. V. Menshchikova and I. V. Silkin Tomsk State University, 634050 Tomsk, Russia M. G. Vergniory Donostia International Physics Center (DIPC), 20018 San Sebasti´an/Donostia, Basque Country, Spain P. M. Echenique Donostia International Physics Center (DIPC), 20018 San Sebasti´an/Donostia, Basque Country, Spain and Departamento de F´ısica de Materiales UPV/EHU, Centro de F´ısica de Materiales CFM - MPC and Centro Mixto CSIC-UPV/EHU, 20080 San Sebasti´an/Donostia, Basque Country, Spain E. V. Chulkov Donostia International Physics Center (DIPC), 20018 San Sebasti´an/Donostia, Basque Country, Spain Departamento de F´ısica de Materiales UPV/EHU, Centro de F´ısica de Materiales CFM - MPC and Centro Mixto CSIC-UPV/EHU, 20080 San Sebasti´an/Donostia, Basque Country, Spain Tomsk State University, 634050 Tomsk, Russia and Saint Petersburg State University, Saint Petersburg, 198504, Russia A new type of topological spin-helical surface states was discovered in layered van der Waals bonded (SnTe)n =2 , 3(Bi2Te3)m =1 compounds which comprise two covalently bonded band inverted subsystems, SnTe and Bi2Te3, within a building block. This novel topological states demonstrate non-Dirac dispersion within the band gap. The dispersion of the surface state has two linear sections of diﬀerent slope with shoulder feature between them. Such a dispersion of the topological surface state enables eﬀective switch of the velocity of topological carriers by means of applying an external electric ﬁeld. PACS numbers: 71.20.Nr, 73.20.At, 85.75.-d INTRODUCTION A topological insulators (TIs) are materials with a gap in bulk electronic spectrum driven by the spin-orbit interaction (SOI), which is topologically distinct from the ordinary insulators. This distinction, characterized by a Z 2 topological invariant, is manifested in the existence of the time-reversal-symmetry protected spin-helical gapless surface state having linear (or almost linear) Dirac dispersion. Starting from the discovery of the TI phase in the quintuple layer (QL) structured binary compounds Bi2Te3, Bi2Se3, and Sb2Te3 and its thorough experimental and theoretical investigation [1–9] a huge number of Z 2 TIs were found. The most of known TIs are Bi2Te3-type ternary and quaternary layered materials. Among them QL and septuple layer (SL) structured compounds as well as the materials with alternating QL and SL units were theoretically predicted and experimentally conﬁrmed.[10–13] Another class of topological materials is materials with band gap inverted by strong spin-orbit interaction in which the topological surface states are protected by the crystal mirror symmetry [14] – so-called topological crystalline insulators (TCI). One representative of a TCI is SnTe, [15, 16] showing an even number of the Dirac cones in the surface spectrum. Recently it was demonstrated that in the Bi2Te3/SnTe heterostructure, the system containing Z 2 and crystal mirror symmetry TIs, the ¯ Γ Dirac surface states of Bi2Te3 and SnTe annihilate at the interface while the Dirac state of SnTe at the ¯ M "survives".[17] This points out that the interaction of Z 2 TI and TCI systems can results in unusual change in topological surface states picture. Diﬀerent systems, containing layers of band-inverted Bi2Te3 and SnTe materials are (SnTe)n(Bi2Te3)m compounds.[18] In this series the (n = 1, m > 1) compounds – SnBi4Te7, SnBi6Te10, and SnBi8Te13 are structurally identical to earlier studied lead-based TIs [10], containing alternating QL and SL structural units, while the (n ≥ 1, m = 1) compounds are formed by unique, nonalternating building blocks. The simplest system (n = 1, m = 1), i.e. SnBi2Te4 is composed by SL hexagonally ordered blocks stacked along the c axis and separated by van der Waals spacings. The SL building block (Fig. 1(b)) can be obtained from the original QL block of Bi2Te3 (Fig. 1(a)) by introducing the SnTe bilayer between the Bi atomic layer and the central Te one. This compound was predicted to be 3D Z 2 TI with single Dirac cone in the bulk energy gap [10]. The Sn2Bi2Te5 compound (n = 2, m = 1) is formed by nonuple layer (NL) building blocks [18]. The NL block (Fig. 1(c)) is constructed from SL block by introduction additional SnTe hexagonal bilayer in the middle of the SL or two bilayers into original QL. Thus this compound diﬀers from Bi2Te3/SnTe heterostructure having the ionic-covalent bonded Bi2Te3 and SnTe atomic layers. Another experimentally conﬁrmed structure (SnTe)n(Bi2Te3)m, which is also built from the ionic-covalent bonded Bi2Te3 and SnTe atomic layers is Sn3Bi2Te6 (n = 3, m = 1).[18] In this case additional SnTe layers are incorporated into the building block (Fig. 1(d)). We are not aware of the possibility of growth of stable (SnTe)n(Bi2Te3)m =1 compounds with larger n which have building blocks of the same type. In the present paper we demonstrate by means of relativistic density functional theory (DFT) calculations that (SnTe)n =2 , 3(Bi2Te3)m =1 compounds are Z 2 TIs, in which owing to complex band inversion of bulk states belonging to Bi2Te3 and SnTe subsystems at the surface arise the topological surface state (TSS) demonstrating non-Dirac, dog-leg dispersion within the bulk energy gap. We discuss the localization and spin texture of the TSS in the context of gate control of the topological transport properties. We also demonstrate the existence of such a TSS in Sn2Sb2Te5 compound. For calculations we use the Vienna Ab Initio Simulation Package (VASP) [19, 20] with generalized gradient approximation (GGA) [21] for the exchange correlation potential. The interaction between the ion cores and valence electrons was described by the projector augmented-wave method.[22, 23] Relativistic eﬀects, including SOI, were taken into account. The atomic positions of bulk (SnTe)n =2 , 3(Bi2Te3) compounds were optimized. In slab calculations a vacuum space of ∼ 20 ˚ A was included to ensure negligible interaction between opposite surfaces. Complementary calculations for bulk band structure were performed using the fullpotential linearized augmented plane-wave method as implemented in the FLEUR code.[24] RESULTS The bulk band structures of Sn2Bi2Te5 shown in Fig. 2 have been calculated with and without SOI included. As can be seen from Fig. 2(a), the direct energy gap of 0.32 eV exist at the Γ point in the calculation without SOI which transforms into indirect gap of 0.12 eV under switch on the SOI (Fig. 2(b)). The time-reversal invariant momenta (TRIMs) in this Brillouin zone are the Γ, A and triply degenerate M and L points. We checked the parity of the a a Sn Bi Te b d \|\| (A FIG. 3. (Color online) (a) Surface electronic structure of Sn2Bi2Te5; The size of the color circles represent the weight of the states in the outermost building block (NL) of the slab; red and blue colors show the sign of the in-plane ( S x and S y) spin components; lightpink and lightgreen rectangles mark the areas of the bandgap and valenceband topological surface states, respectively. Atomic weights of Bi and Sn in the bandgap (b) and valenceband (c) TSSs. (d) Energy dispersion of the bandgap TSS compared to Bi2Te3 and SnTe ¯ Γ Dirac cones. Dashed and dot-dashed lines are linear ﬁt for the TSS above and below shoulder, respectively. (e) Dispersion of the valenceband TSS compared to Bi2Te3. (f) Constant energy contours in the shoulder region (yellow stripe in panel (d)). (g) Spin-resolved constant energy contours for bandgap TSS at energies of 25 meV below and above the shoulders. Arrows adjacent to the contours denote the in-plane spin component S ∥. The out-of-plane spin component S z is indicated by the color with red and blue corresponding to the positive and negative values, respectively. (h) The spin components S ∥ and S z for bandgap TSS as functions of k ∥ along the ¯ Γ- ¯ K direction. wavefunctions at all TRIMs to determine the topological character of this material and found that the parity inversion of bulk bands occurs at the Γ point which leads to Z 2 invariants 1;(000) like in Bi2Te3. In spite of this similarity in SOI-induced wavefunction parity change, the total band inversion at Γ is an entanglement of two diﬀerent inversions corresponding to each subsystem due to the complex crystal structure of the compound. For instance, in Bi2Te3 the SOI modiﬁes the top valence band state (predominantly of pz character) of Te atoms lying in the outer layers of QL (Teo) and the Bi pz-state of the bottom conduction band so that they are inverted in the close vicinity of the Γ point. A similar simple band inversion occurs in the bulk SnTe where Sn and Te states are inverted in the L point of the cubic Brillouin zone. Instead, in Sn2Bi2Te5 the spectra calculated without SOI both Bi and Sn states form the bottom of the conduction band while the states of Teo atoms and tellurium atoms of the central layer of NL (Tec) lie in the top valence band (Fig. 2(c,d)). Switching on the SOI results in an inversion of Bi and Teo states and Sn and Tec states. However, in contrast to the binary systems this inversion has more complex character. As can be seen in Fig. 2(e) after switching on the SOI the Teo states become dominant in the conduction band while the Bi states (in contrast to the Bi2Te3 case) occupy the second valence band in the vicinity of Γ. The SOI-inverted Sn states lie in the highest valence band and Tec states appear in the second conduction band Fig. 2(f). Additionally, the SOI-inverted Sn states (with smaller weight) appear in the second valence band. Thus, the Sn2Bi2Te5 TI has a competitive bulk Γ-gap band inversion which comprises the inversion of the states belonging to diﬀerent subsystems, SnTe and Bi2Te3, so that the valence band edge is mainly formed by Sn states and the conduction band edge occupied by Teo states while the Bi and Tec states lie next to the edges bands. Such a superposition of the SOI-induced bulk band inversions in the the SnTe and Bi2Te3 subsystems of the (SnTe)2(Bi2Te3)1 TI results in formation of unusual topological states on the surface. In the surface spectrum two topological surface states arise at the ¯ Γ point. The upper TSS lies in the band gap (see lightpink rectangle in Fig. 3a) while the lower TSS (lightgreen rectangle in Fig. 3a) resides in the valence band (bandgap and valenceband TSS's, respectively from now on). The lower, valenceband TSS, propagating within the local valence band gap, has typical Dirac dispersion for TIs. In contrast, the bandgap TSS displays nonlinear (non-Dirac) dog-leg behavior. It has two linear sections in the spectrum: near the band crossing (Dirac point) and below the conduction band which connect to each other in the middle part of the gap with formation of shoulders in the spectrum. Like in other TIs, the TSSs in Sn2Bi2Te5 are localized within outermost building block of the slab. However, in this case, where the building block has two band-inverted SnTe and Bi2Te3 subsystems, the localization of the TSS is aﬀected by the peculiarities in the bulk band inversion. Figs. 3(b,c) show the Bi and Sn atomic weights in the TSSs. As one can see in Fig. 3(c), the valenceband TSS has dominant Bi weights that reﬂect its dominant localization in the outer Bi-Te layers of NL. Comparing the dispersion of this state with that of the Dirac cone in Bi2Te3[8] (Fig. 3(e)) one can conclude that at small k∥ (where the valenceband TSS has localized character) both bands are almost identical. In the bandgap TSS (Fig. 3(b)), the lower linear section near the band crossing, the Sn contribution dominates and thus the state is mainly localized in the inner Sn-Te layers of NL. Approaching the shoulders the Sn contribution disappears rather quickly and above the band shoulders the TSS becomes to be mostly localized in the outer Bi-Te layers. Thus the band shoulders in the TSS spectrum are associated with the change of the TSS localization from the SnTe to Bi2Te3 subsystem. It should be noted that the slope of the upper linear section of the bandgap TSS (at k∥ > 0.1 ˚A − 1 ) localized in the outer Bi-Te layers is comparable with the slope of the Bi2Te3 Dirac cone (Fig. 3(d)), while the dispersion of the lower linear section (k∥ < 0.05 ˚ A − 1 ) diﬀers considerably from both Bi2Te3 and rocksalt-SnTe[25] ¯Γ Dirac states. As a consequence, the linear ﬁtting for lower and upper sections of the bandgap TSS (dot-dashed and dashed lines in Fig. 3(d)) gives E/k∥ slopes of 2.22 and 1.13, respectively. Between these linear sections, in the shoulder region at 0.05 < k∥ < 0.1 ˚ A − 1 , two inﬂection points exist which limit almost ﬂat section in the TSS spectrum. Such very low velocity regime in the bandgap TSS resembles heavy-fermion topological state that has been proposed theoretically[26] and obtained from magnetothermoelectric transport measurements[27] in topological Kondo insulator (TKI) SmB6. Owing to slightly negative dispersion of the TSS in the shoulder region (see narrow yellow stripe in Fig. 3(d)) by varying the chemical potential the system will pass from one velocity mode in the lower linear section to the other velocity mode in the upper linear section through the three surface Fermi pockets regime at energy ≈50 meV (Fig. 3(f)). The detailed spin texture of the bandgap TSS is illustrated in Figs. 3(g,h). Fig. 3(g) shows spin-resolved constant energy contours (CEC's) for the lower (inner contour) and upper (outer contour) linear sections of the TSS. Both contours, apart from the in-plane clockwise spin polarization, also demonstrate the presence of the out-of-plane spin component, which is intrinsic feature of the spin-polarized states at hexagonal surfaces while Sz for the inner contour is extremely small. As clearly seen for the outer contour, Sz is zero along ¯ Γ- ¯ M and reaches a minimum (maximum) value in ¯ Γ- ¯ K directions. The dependencies of absolute values for S∥ and Sz on k∥ along ¯ Γ- ¯ K are shown in Fig. 3(h). The in-plane spin polarization having maximum near the band crossing point rapidly decreases approaching the shoulder. At k∥ > 0.1 ˚ A − 1 , i.e. in the upper linear section, it increases with k∥ until it reaches the region of the bulk states. In contrast, the out-of-plane spin polarization increases with k∥ in both linear sections of the TSS, having a kink at the band shoulder. The increase of the SnTe layers in the building block of (SnTe)n(Bi2Te3)m =1 compound up to n = 3 maintains the two TSSs in the surface spectrum as well as dog-leg behavior in dispersion of the bandgap surface state (Fig. 4(a)). The diﬀerence from the Sn2Bi2Te5 case is that the band shoulders lie closer to the bulk valence band making lower section of the TSS very short and two times less steep. Another way to modify the parameters of the bandgap TSS is substitution of Bi by Sb. In this case SnTe layers are introduced into Sb2Te3 TI forming (SnTe)n(Sb2Te3)m =1 compound. As can be seen in Fig. 4(b) the surface spectrum of Sn2Sb2Te5 also holds two TSSs with dog-leg dispersion in the bandgap TSS. However, in contrast to the previous case the band shoulders arise near the conduction band. SUMMARY In summary, on the basis of ab initio DFT calculations we have demonstrated that (SnTe)n =2 , 3(Bi2Te3)m =1 compounds are Z 2 topological insulators in which, owed to superposition of two pairs of SOI-induced band inversions realized in SnTe and Bi2Te3 subsystems, two spin-helical topological surface states arise at the ¯ Γ point. These states reside in the band gap and in the local gap of the valence band. The latter TSS, lying deep below the Fermi level, has a dispersion similar to that in the Bi2Te3 TI, while the bandgap TSS demonstrates unusual non-Dirac dog-leg dispersion with two linear sections of diﬀerent slope and very low-velocity shoulder section between them. In Sn2Bi2Te5 the shoulders are located in the middle of the gap and velocities of carriers in lower and upper linear sections diﬀer by a factor of two. Thus in contrast to all hitherto known TIs, where the slope of the spin-helical TSS is linear or varies smoothly with energy, the bandgap TSS in (SnTe)n =2 , 3(Bi2Te3)m =1 compounds shows abrupt switch of the velocity of topological carriers with change in the Fermi surface topology in the narrow energy range (shoulder section) where spin and charge current should be blocked. We also demonstrated that similar TSSs exist in (SnTe)n =2(Sb2Te3)m =1 compound. This novel ﬁnding enhance the understanding on the diversity of topological surface states and pave a way for the eﬃcient control of the group velocity with suﬃciently large spin current density by tuning the chemical potential. Further tuning of the bandgap TSS parameters can be realized by using (Bi1 −xSbx)2Te3[28, 29] or Bi2(Te1 −xSex)3[29, 30] compounds as basic TIs for construction of (SnTe)n((Bi-Sb)2(Te-Se)3)m =1 systems. [1] Y. Xia, D. Qian, D. Hsieh, L. Wray, A. Pal, H. Lin, A. Bansil, D. Grauer, Y. S. Hor, R. J. Cava, and M. 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B 89 , 125416 (2014). , 800 (2012).	<urn:uuid:8901ead5-c5c0-4950-b1b5-47a93eb24eb5>	CC-MAIN-2019-13	https://arxiv.org/pdf/1505.07616v1.pdf	2019-03-18T22:06:48Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-13/segments/1552912201707.53/warc/CC-MAIN-20190318211849-20190318233849-00320.warc.gz	417,759,873	6,321	eng_Latn	eng_Latn	0.729838	eng_Latn	0.95766	[ "eng_Latn", "eng_Latn", "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "dag_Latn" ]	false	rolmOCR	[ 1819, 6898, 6901, 9172, 15255, 17996, 21228 ]
February 19, 2024 All TCRC Members, As you are likely aware the TCRC is in an unprecedented position of having 3 major Collective Agreements expire on December 31 st , 2023 (Running Trade members at CPKC and CN, Rail Traffic Controllers at CPKC). All three bargaining committees commenced negotiation talks in the fall and have continued to make every good faith effort to attain agreement(s) that the membership would ratify. Unfortunately, it has become very clear that the carriers do not have that same objective. On Friday, February 16 th both CN and CPKC served Notice of Dispute to the Federal Government regarding all three Collective Agreements. These Notices were served within minutes of each other, and not during any active collective bargaining session(s). In fact, the last scheduled sessions took place the week of January 29 th , during which the TCRC was faced with resistance from the carriers when attempting to secure future bargaining dates. What does this mean? From a legal perspective, serving notice of dispute means enacting Section 71 of the Canada Labour Code to notify the Federal Government the parties have failed to reach an agreement. Normally this would indicate the parties are at an impasse and require assistance in the bargaining process. The Minister of Labour then has several options (as contained in Section 72) in which they can respond. What this has usually meant in the past is that the Minister directs a conciliation officer to be appointed through its federal agency (FMCS), to act as an intermediary to reach an agreement between the parties. The appointment of a conciliation officer must happen within 15 days of the Notice of Dispute. This is then followed by a 60-day conciliation period in which negotiations will continue with the aid of the officer appointed. This 60-day period can be mutually extended by the parties, otherwise it will conclude and be followed by a 21 day "cooling off" period. The earliest a legal strike or lockout could occur is at the expiration of the 81 days, with the Union having secured a strike mandate from the membership and followed by either party serving 72 hours notice. …/2 All TCRC Members February 19, 2024 Page 2 What does this mean to the membership? With regards to the legal process each committee will be seeking a strike mandate to properly respond should the conciliation process not yield a collective agreement(s). A strike vote does not mean there absolutely will be a strike but is required under the Code (Section 87.3(1)), before that right is legally acquired. Regarding the Collective Bargaining process, your respective bargaining committees remain steadfast in achieving terms that will be ratified by you, the affected members. Both carriers have enjoyed unprecedented growth and financial success over the past number of years. Denying employees the right to share that success is simply a non-starter. To the contrary, both CPKC and CN are focused on stripping existing rights instead of building a relationship and treating the membership with the respect it deserves. A glaring example of the carrier's contempt for both its employees and regulation is the outright refusal to properly implement DRPR (Duty and Rest Period Rules) recommendations, in light of their full involvement and input during the consultation phase. The membership experiences the worsening of work fatigue and unpredictability daily, yet the carriers refuse to accept the guidance of Transport Canada regarding the reset break application. Why? One can surmise endlessly, but what is becoming abundantly clear is that CPKC and CN have actively colluded on several fronts designed to undermine the membership's rights and the TCRC's ability to represent. Both carriers have refused to implement Transport Canada's recommendations regarding DRPR. Both carriers are seeking astonishingly similar concessions at the bargaining table. And now both carriers have served Notice of Dispute on the same day, for numerous Collective Agreements, within minutes of each other. There is certainly a pattern forming. What is their strategy? The TCRC has been and remains willing to continue the bargaining process in good faith, yet the carriers seem intent on rushing towards a work stoppage. A stoppage on a scale that Canada has likely never experienced. That has not been and never will be the TCRC's strategy. However, CN and CPKC appear to be willing to play with the Canadian economy and force the government to intervene as a result. The TCRC believes CPKC and CN need to be called out on their outrageous behaviour and actions. That is not to say the TCRC will not exercise its charter rights and take action to protect the membership's interests if necessary. This letter comes to you from all 3 affected bargaining committees as we remain stronger together - as does the membership. Each committee will continue to focus on their own processes and will update affected members accordingly, but it was felt a united message and update was required regarding these egregious recent events. All TCRC Members February 19, 2024 Page 3 In the coming days arrangements will begin regarding a strike vote(s). Information will continue to be available on existing websites and social media as before, but we encourage the membership to sign up for the TCRC App. We will be ramping up its usage during this process and notifications will be pushed as soon as possible. We also ask every Division Executive Officer to begin steps to ensure their membership information is up to date. The TCRC can only poll members we can contact, so please work with your respective General Committee to help in that process. Thank you for your attention to this matter, we remain, In Solidarity, Dave Fulton General Chairman – CP CTY West Greg Lawrenson, General Chairman – CP LE West Mark Kernaghan General Chairman – CN LE Central Jim Lennie General Chairman – CN CTY Central Wayne Apsey General Chairman – CP CTY East Ed Mogus General Chairman – CP LE East R.S. Donegan General Chairman – CN CTY West KC James General Chairman – CN LE West Jean-Michel Halle General Chairman – CN LE East Alain Gatien General Chairman – CN CTY East Jason Bailey General Chairman – CP RCTC Paul Boucher National President - TCRC Ryan Finnson National Vice President - TCRC Chris Lowe National Secretary-Treasurer - TCRC Don Ashley National Legislative Director - TCRC Stay Informed – with the TCRC App!	<urn:uuid:06379fc1-3425-4e49-9b60-28a7212cc30a>	CC-MAIN-2024-22	https://www.tcrccalgary.ca/Bargaining/2024/TCRC_Membership_Collective_Bargaining_Update_CN_CPKC.pdf	2024-05-23T05:59:52+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-22/subset=warc/part-00176-4dd72944-e9c0-41a1-9026-dfd2d0615bf2.c000.gz.parquet	879,398,017	1,300	eng_Latn	eng_Latn	0.87134	eng_Latn	0.998483	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2175, 5091, 6135, 6488 ]
STUDIES OF THE PHYSICAL STABILITY OF GLP-1 & CHEMICALLY MODIFIED FORMS OF GLP-1 Frederik Johannes Becher Peterhouse The Jackson Laboratory Department of Chemistry University of Cambridge This dissertation is submitted for the degree of Doctor of Philosophy November 2020 ii This thesis is dedicated to my grandparents "Ich habe keine besondere Begabung, sondern bin nur leidenschaftlich neugierig." Albert Einstein "Ideen, wie absolute Gewißheit, absolute Genauigkeit, endgültige Wahrheit und so fort, sind Erfindungen der Einbildungskraft und haben in der Wissenschaft nichts zu suchen." Max Born DECLARATION This dissertation is the result of my own work and includes nothing, which is the outcome of work done in collaboration except where specifically indicated in the text. It has not been previously submitted, in part or whole, to any university or institution for any degree, diploma, or other qualification. In accordance with the Department of Chemistry guidelines, this thesis is does not exceed 60,000 words. Signed: Date: 02/11/2020 Frederik Johannes Becher Cambridge SUMMARY Biopharmaceuticals, including proteins and peptides, are becoming increasingly important as therapeutic agents. However, the clinical use of protein and peptide therapeutics is still restricted due to undesirable properties such as their ability to self-assemble and aggregate. These properties not only influence production processes and storage but can also have adverse immunogenic effects within humans. To enhance their use, it is of great importance to understand and be able to manipulate their aggregation behaviour. In vivo, protein- and peptide-based drugs suffer from different problems, such as short lifetimes and low stability. Lipidation of peptides is widely established as a means of increasing stability in vivo. However, relatively little is known about the effect of lipidation on peptide self-assembly and other aggregation phenomena in vitro. The aim of this study is to develop a better understanding of the mechanism of aggregation and amyloid fibrillation of the therapeutic peptide GLP-1 and chemically modified forms of GLP-1. GLP-1, a metabolic hormone, has the ability to decrease blood sugar levels in a glucose-dependent manner by enhancing the secretion of insulin. Previous measurements of GLP-1 aggregation revealed that, at certain pH values, unusual behaviour is observed that has established that the standard nucleation-polymerization mechanism is insufficient to fully describe the reaction under these conditions. To study the aggregation mechanism of GLP-1 and chemically modified forms of the peptide, aggregation kinetics were measured over a wide range of different conditions. In addition, many biophysical techniques, such as AFM, SEM, far-UV CD, FT-IR, $\lambda_{\text{max}}$, ANS, ex situ ThT and DLS, were employed to probe the structure, size and properties of species in solution during aggregation. The influence of amidation at the C-terminus of GLP-1 on physical stability was assessed and significant differences to GLP-1 were found. The study of this relatively small modification generates a better understanding of the interdependence of net charge, solubility and secondary structure on the aggregation kinetics. The results of these studies also provide further evidence that peptides belonging to the GLP-1 family can form off-pathway oligomeric species that have a significant impact on the aggregation kinetics. Two lipidated analogues of C-terminally amidated GLP-1 (Am-GLP-1) were also studied and the results analysed in detail and compared to those obtained for GLP-1 and Am-GLP-1. Both lipidated peptides show a strong, nearly switch-like, pH dependence. Surprisingly, it was also shown that the amidation of the C-terminus had a bigger influence on the secondary structure of the peptides in comparison to the lipidation. ACKNOWLEDGEMENTS During my PhD, I had the support of a broad range of people – combinations of my family, friends, supervisors and co-workers all deserve my gratitude. Starting with my two supervisors, Prof Sophie Jackson and Dr Ana dos Santos, who helped me discover the exciting world of peptide aggregation. And it’s been an honour to work with you and do so at such magnificent places – the Chemistry Department at the University of Cambridge and the laboratory of MedImmune (now AstraZeneca - AZ). I want to say a big thank you for all the support, positive challenges and scientific discussions. I have learned and will continue to learn a lot from both of you. I also want to acknowledge the entire Jackson Group. Special thanks go to Karolina for laying the foundation to my project. Your continued help, always introducing me to different techniques and experiments, was priceless. I appreciated all questions, discussions of new data and lunch-time chats with Eva, Katie, Jack and Carolina. During my time at AZ, I have also had the support of the whole Formulation group (later DFDD group). Special thanks go to Shahid Udin and Steven Bishop for their support and interest in my work. Like many members of the Jackson Group, I was fortunate enough to receive help of many AZ employees. Specifically, I want to highlight Anne-Laure for her support with FT-IR and Elise for her support with LC-MS. Also, special thanks to Sophie for answering my many questions in the laboratory. In general, every person I met at AZ, without any exception, was absolutely helpful and supportive in my studies. For this, I am very lucky and truly grateful. And finally, all the other PhD students at AZ deserve an honourable mention. It was great to share my time with both Maria-Laura and Marcello – there was nothing we couldn’t solve together in the lab. In this context, I am greatly appreciative of the NanoScience group of Prof Sir Mark Welland which welcomed me during my AFM measurements. Special thanks go to Simon for explaining to me in detail everything I had to know about the instrument. I also thank Sonja and Géraldine, who were also always there if I had any questions. Altogether, we had a great time in Washington and Gaithersburg at MedImmune. Finally, I want to mention and thank George for answering all my questions regarding NEF-fitting. There is something in Cambridge which makes your life as a PhD student a bit more special than usual and that is the lovely college life. I am grateful that I was in the fortunate situation to become a member of Peterhouse, the oldest college of Cambridge. Great thanks go therefore to the entire college staff which I got to know very well during my year in the MCR committee. They all always made us feel like we were at home! I also want to thank to the whole MCR committee during my time as social secretary. It is not exaggerated to say that we all enriched the social life of Peterhouse as much as we could! Many thanks to Leo, Laura, Simone, Monique, Frederik and Jamie. I am sure one day Medusa will join us again to a fantastic formal hall. An essential part of my time in Cambridge was enjoying the fascinating conversations and beautiful walks along the River Cam with William and Simon. I really appreciated your thoughts! Another committee that played a major part of my life in Cambridge was the committee of the German Society. I thank all of the co-members for some of the finest memories you can imagine. I must also thank my best friends, Alexander, Arni and Philipp. It was a pleasure to show you around in Cambridge. I am really looking forward to our next adventures! It was something extraordinary to have Christian and Maija, two of my closest friends, around London and Cambridge. Both played an essential part in making me feel at home in the UK. In the end, I was lucky to have a really close friend offer me shelter during Covid-19 pandemic and at one of the most inspiring places one can imagine. I am really grateful Ann for providing me with a room at your little horse range. And many thanks to Marc, Leana, Sven and Saskia – they welcomed me warmly and made the time memorable despite all the work writing. Last but not least, I want to say thank you to my family. An enormous thank you goes to my parents, their partners and my brothers with their partners as well. They always support me in every step I take. Finally, I say thank you to AstraZeneca (MedImmune) and Peterhouse for financing the project. CONTENTS 1 INTRODUCTION ........................................................................................................ 1 1.1 A BRIEF HISTORY OF AMYLOIDS ................................................................. 3 1.2 MOLECULAR STRUCTURE OF PROTEIN OR PEPTIDE AMYLOIDS FIBRILS ....... 6 1.3 ATOMIC STRUCTURE OF GLUCAGON FIBRILS ............................................. 10 1.4 AGGREGATION TO FORM OTHER TYPES OF STRUCTURES ....................... 12 1.5 KINETICS OF FIBRILS FORMATION ................................................................. 12 1.5.1 Different Aggregation Mechanism ......................................................... 13 1.5.2 Off-Pathway Oligomers or Off-Pathway Species .............................. 14 1.6 FACTORS AFFECTING THE PHYSICAL STABILITY (AGGREGATION) OF PEPTIDES .......................................................... 16 1.6.1 Amino-acid Sequence ............................................................................ 16 1.6.2 Peptide Concentration ........................................................................... 19 1.6.3 pH and Net Charge ................................................................................ 24 1.6.4 Chemical Degradation .......................................................................... 25 1.6.5 Surfaces and Interfaces ......................................................................... 25 1.6.6 Excipients .............................................................................................. 27 1.6.7 Impurities .............................................................................................. 30 1.6.8 External Factors .................................................................................... 30 1.6.9 Chemical Modifications ........................................................................ 32 1.7 LIPIDATION OF PEPTIDES ............................................................................. 35 1.7.1 Endogenous Lipidation ......................................................................... 35 1.7.2 Influence of Lipidation in Therapeutics ............................................... 36 1.8 GLUCAGON-LIKE PEPTIDE 1 (GLP-1) ............................................................ 38 1.8.1 Biological Activity of GLP-1 ................................................................. 39 1.8.2 GLP-1 as a Therapeutic Agent and its Challenges ............................ 40 1.8.3 Modifications and Analogues of GLP-1 .............................................. 41 1.9 FATTY ACIDS USED FOR LIPIDATION .......................................................... 43 1.10 AGGREGATION OF GLP-1 UNDER ACIDIC, NEUTRAL AND BASIC CONDITIONS .......................................................... 44 1.11 CHANGES IN SECONDARY STRUCTURE DURING AGGREGATION ........ 51 1.12 THIOFLAVIN T AS FLUORESCENCE MARKER OF AMYLOID FIBRILS .......... 53 1.13 MEASUREMENT OF THE SECONDARY STRUCTURE OF PEPTIDES USING CIRCULAR DICHROISM ................................................................. 56 1.14 FOURIER TRANSFORM INFRARED SPECTROSCOPY OF POLYPEPTIDES ................................................................. 58 1.15 PRINCIPAL COMPONENT ANALYSIS OF SPECTROSCOPIC DATA ................................................................. 59 1.16 MEASUREMENT OF THE PI OF POLYPEPTIDES ................................................................. 60 1.17 AIMS OF THE THESIS ........................................................................... 63 2 METHODS AND MATERIALS .................................................................. 65 2.1 PEPTIDES ...................................................................................... 65 2.2 BUFFERS AND OTHER REAGENTS .................................................. 66 2.3 UV-VISIBLE ABSORPTION SPECTROSCOPY – NANO DROP ............ 67 2.4 SAMPLE PREPARATION .................................................................. 68 2.5 SOLUBILITY MEASUREMENTS ....................................................... 68 2.6 LIQUID CHROMATOGRAPHY-MASS SPECTROMETRY (LC-MS) ......... 68 2.7 DYNAMIC LIGHT SCATTERING (DLS) ............................................. 69 2.8 IMAGED CAPILLARY ISOELECTRIC FOCUSING (iCIEF) ..................... 70 2.9 THIOFLAVIN T AGGREGATION ASSAY ........................................... 71 2.9.1 Preparation of ThT Stock Solution ........................................... 72 2.9.2 ThT Assay Data Analysis: Fitting to a Sigma Function .......... 72 2.9.3 ThT Assay Data Analysis: Fitting to a Fragmentation-Dominated Model ................................................................. 72 2.10 FAR-UV CIRCULAR DICHROISM (FAR-UV CD) AND CDPRO ........ 73 2.11 FOURIER-TRANSFORM INFRARED SPECTROSCOPY (FT-IR) .......... 75 2.12 EXTRINSIC AND INTRINSIC PROTEIN FLUORESCENCE ............. 75 2.12.1 Tryptophan Fluorescence ...................................................... 75 2.12.2 8-Anilinonaphthalene-1-Sulfonic Acid (ANS) Binding Assay .... 76 2.12.3 Ex-situ ThT Fluorescence Measurements ................................ 76 2.13 FIBRIL SEPARATION ..................................................................... 77 2.14 IMAGING ..................................................................................... 78 2.14.1 Atomic Force Microscopy (AFM) .......................................... 78 2.14.2 Scanning Electron Microscopy (SEM) .................................... 78 2.15 NET CHARGE AND PI DETERMINATION ........................................ 79 2.16 ULTRA-PERFORMANCE LIQUID CHROMATOGRAPHY (UPLC) ...... 80 2.17 SINGULAR VALUE DECOMPOSITION (SVD) ................................ 80 2.18 SIZE-EXCLUSION CHROMATOGRAPHY .................................................. 81 3 PHYSICAL STABILITY OF GLP-1 ......................................................... 83 3.1 INTRODUCTION ............................................................................. 83 3.2 AGGREGATION OF GLP-1 AT NEUTRAL AND BASIC pH .............. 85 3.2.1 GLP-1 Lag Time Comparison of Data collected by KLZ and FJB ................................................................. 85 3.2.2 Reproducibility of GLP-1 ThT Assays with Different GLP-1 Batches ................................................................. 87 3.2.3 GLP-1 Aggregation Kinetics Around pH 7.5 in Tris and Phosphate Buffer ......................................................... 88 3.3 SOLUBILITY AND NET CHARGE OF GLP-1 .................................... 89 3.4 TIME-COURSE EXPERIMENTS ........................................................... 91 3.4.1 Imaging of Peptide Aggregates .................................................. 91 3.4.2 Disturbance of Aggregation Kinetics ........................................ 111 3.4.3 Changes in Secondary Structure During Aggregation .......... 112 3.4.4 Size of GLP-1 Aggregates in Solution ....................................... 119 3.5 DISCUSSION .................................................................................. 122 3.5.1 Physical Evidence for Off-Pathway Oligomeric Aggregates 122 3.5.2 Characteristics of GLP-1 Aggregates and Fibrils Formed Under Acidic and Basic Conditions ................................. 123 3.5.3 Challenges and Further Results from the Time-Course Measurements ................................................................. 124 3.5.4 The Relationship Between Aggregation Propensity and pI and Net Charge ................................................................. 125 3.5.5 Conclusion ................................................................................ 125 4 THE INFLUENCE OF C-TERMINAL AMIDATION ON THE PHYSICAL STABILITY OF GLP-1 ................................................................. 127 4.1 INTRODUCTION ............................................................................. 127 4.2 MOLECULAR WEIGHT AND PURITY OF GLP-1 AND AM-GLP-1 .... 129 4.3 THE INFLUENCE OF C-TERMINAL AMIDATION ON PEPTIDE SOLUBILITY ................................................................. 132 4.4 THE PEPTIDES HAVE A LOWER AGGREGATION PROPENSITY CLOSE TO THEIR PI VALUES ................................................................. 134 4.5 AGGREGATION KINETICS OF AM-GLP-1: PEPTIDE CONCENTRATION 4.6 The Variance Between Triplicate Runs Increases with Lag Time ........................................ 140 4.7 Additional Analysis of Kinetic Aggregation Data Using a Nucleated-Polymerisation Model ................................................................. 141 4.8 General Solution to Predict the Maximum Influence of Off-Pathway Species on Monomer Concentration .................................................. 147 4.9 Fibril Morphology and Higher Structures ...................................................... 149 4.9.1 SEM Control Measurements of Pure Buffer ........................................... 149 4.9.2 Fibril Morphology and Higher-Order Structure Varies with pH ............... 153 4.10 Conformational Differences Between Aggregates Formed Under Acidic or Basic Conditions ................................................................. 162 4.11 Specificity of ANS Binding to Oligomers/Fibrils ........................................ 164 4.11.1 ANS Fluorescence: Higher Under Acidic Conditions ....................... 166 4.11.2 Comparison to Tryptophan Fluorescence and Change of $\lambda_{\text{max}}$ ............. 167 4.11.3 Separated Aggregates Interact with ANS and ThT ............................ 170 4.12 Influence of the C-terminal Amidation on Secondary Structure ............... 172 4.13 Discussion .................................................................................................. 179 4.13.1 The Mechanism of Aggregation: The Role of On- versus Off-Pathway Oligomers ................................................................. 179 4.13.2 Role of Net Charge on Solubility and Aggregation Propensity ............. 181 4.13.3 Less Electrostatic Repulsion Does Not Lead to Higher Aggregation Propensity ................................................................. 183 4.13.4 Specificity of ANS Fluorescence ....................................................... 183 4.13.5 Structure of the Monomeric Peptides ................................................ 184 4.13.6 The Secondary Structure of the Monomeric Peptides Influences Aggregation Propensity and Mechanism ........................................ 188 4.13.7 Structure/Properties of Off-Pathway Oligomers ............................... 189 4.13.8 The Structure of Fibrils of GLP-1 and Am-GLP-1 are Sensitive to pH .... 190 4.13.9 Conclusion ................................................................. 191 5 THE EFFECT OF LIPIDATION ON THE PHYSICAL STABILITY OF PEPTIDES .......................................................... 192 5.1 Molecular Weight and Purity of IPP4 and IPP5 .................. 194 5.2 Solubility, Net Charge and pI are All Influenced by Lipidation ................................................................. 197 5.3 A pH Induced Switch of Aggregation Propensity ............... 199 5.4 Aggregation Kinetics of Lipidated Peptides at Different Peptide Concentrations .............................................. 201 5.5 Imaging of Higher-Order Structure in Aggregated Samples of Lipidated Peptides ............................................. 204 5.6 Secondary Structure of Lipidated Peptides ......................... 210 5.6.1 Influence of Lipidation and Amidation on the Secondary Structure ......................................................... 213 5.7 Size of Lipidated Peptide Oligomers .................................. 214 5.8 Discussion ........................................................................... 221 5.8.1 Solubility of Lipidated Peptides is Restricted to Neutral and Basic Conditions ............................................ 221 5.8.2 Is There Evidence that Lipidated GLP-1 Peptides Form Amyloid-Like Fibrils? ........................................... 221 5.8.3 ThT Fluorescence Caused by Non-Fibrillar Structures ..... 223 5.8.4 Kinetics of the Formation of Aggregates ....................... 224 5.8.5 Unusual Decrease of ThT Fluorescence ......................... 224 5.8.6 Peptide Concentration Dependence of the Aggregation Kinetics ............................................................. 225 5.8.7 Different Oligomer Sizes Influenced by Sequence and pH ... 226 5.8.8 Two Different Aggregation Behaviours That Depend on pH 228 5.8.9 Influence of the Amidation and Lipidation on the Secondary Structure ..................................................... 228 5.8.10 Conclusion .................................................................. 229 6 CONCLUSIONS AND FUTURE WORK .................................. 231 6.1 Summary and Conclusions .................................................. 231 6.1.1 Background .................................................................. 231 6.1.2 Summary of Experimental Chapters ............................... 232 6.1.3 Symmetrical Aggregation Propensity Around the pI .......................... 233 6.1.4 The Net Charge Influences the Aggregation Propensity more than the Secondary Structure of the Monomer ........................................... 234 6.1.5 Changes of Secondary Structure at pH Values near the pK_a Values of Specific Side Chains Influence Aggregation Propensity ................................................................. 234 6.1.6 Lipidation and Amidation Increase α-Helicity of Freshly Dissolved Peptides ...................................................................................... 235 6.1.7 Lipidated Peptides Self-Assemble to form β-Sheet Structures Independent of the Formation of Rigid Fibrils ........................................ 236 6.1.8 GLP-1 Forms β-Sheet Rich Intermediate Species ............................ 236 6.1.9 pH Switch Observed for Four Different GLP-1 Analogues ............. 236 6.1.10 Physical Evidence for Different Aggregates Formed Under Different pH Conditions for Individual Peptides ............................... 237 6.1.11 Rate Constants are not Globally Valid Under Different Sample Concentrations ................................................................. 237 6.2 FURTHER WORK ........................................................................... 238 6.2.1 Further Characterisation of the Structure of Oligomeric Species ........................................................................................................ 238 6.2.2 Further Characterisation of the Atomic Structure of Fibrils under Different pH Conditions .......................................................... 240 6.2.3 Is the Aggregation of GLP-1 and GLP-1 Analogues Influenced by Liquid-Liquid Phase Transition or Gelation? ......................... 241 6.2.4 Complementary Experiments for a Deeper Understanding of the Effect of Lipidation ................................................................. 242 6.2.5 Role of Zeta Potential in the Aggregation of GLP-1 and GLP-1 Analogues ......................................................................................... 242 7 REFERENCES .................................................................................. 244 8 APPENDICES .................................................................................. 278 ANALYTICAL DATA SHEETS ................................................................. 279 LIST OF TABLES Table 1.1. Some examples of peptide and protein pharmaceuticals known to form different types of aggregates. .................................................. 2 Table 1.2. Methods for predicting aggregation-prone regions and aggregation propensity in peptides................................................................. 18 Table 1.3. Examples of endogenous protein lipidation. .............................. 36 Table 1.4. Saturated fatty acids........................................................................... 43 Table 1.5. Summary of the averages and standard deviations of the kinetic parameters obtained from multiple repeats of the ThT assays for GLP-1 at different pH values............................................................... 50 Table 2.1. Parameters for the LC-MS experiments. ........................................ 69 Table 2.2. p$K_a$ values of ionisable groups in proteins. .................................... 79 Table 2.3. UPLC method..................................................................................... 80 Table 2.4. SEC calibration standards. ............................................................... 82 Table 3.1. Heights and widths of different fibril profiles. ............................... 109 Table 3.2. Description of GLP-1 aggregates imaged by AFM under different conditions......................................................................................... 110 Table 4.1. Kinetic parameters from the sigmoidal fits of the Am-GLP-1 ThT assay data shown in Figures 4.5 and 4.6........................................... 140 Table 4.2. Description of Am-GLP-1 aggregates imaged by SEM................. 161 LIST OF FIGURES FIGURE 1.1. NEGATIVELY STAINED AMYLOID FIBRILS ...........................................4 FIGURE 1.2. THE CROSS-B-SHEET MOTIF .................................................................7 FIGURE 1.3. IN- AND OUT-OF-REGISTER B-SHEETS AND ENERGETICALLY FAVOURABLE LADDERS ..................................................................................................................8 FIGURE 1.4. SYMMETRY CLASSES OF HOMO-STERIC ZIPPER AMYLOID SPINES ....9 FIGURE 1.5. ATOMIC STRUCTURE OF A GLUCAGON FIBRIL AT LOW pH .............11 FIGURE 1.6. AMYLOID FORMATION AND STRUCTURE OF AMYLOID-LIKE FIBRILS. ......................................................................................................................................................13 FIGURE 1.7. DIFFERENT MECHANISMS INVOLVING ON- AND OFF-PATHWAY OLIGOMERIC SPECIES .......................................................................................................................15 FIGURE 1.8. PREDICTION OF STRUCTURAL AGGREGATION ....................................17 FIGURE 1.9. DEFINITION OF KEY KINETIC PARAMETERS OBTAINED FROM SIGMOIDAL AGGREGATION KINETICS .................................................................20 FIGURE 1.10. DEPENDENCE OF GLP-1 AGGREGATION KINETICS ON PEPTIDE CONCENTRATION AT TWO DIFFERENT pH VALUES ..................................................21 FIGURE 1.11. INFLUENCE OF PEPTIDE CONCENTRATION ON $T_{1/2}$ AND $T_{LAG}$ AT DIFFERENT pH VALUES ..................................................................................................................23 FIGURE 1.12. DIFFERENT APPLICATIONS OF LIPIDATED PEPTIDES/PROTEINS IN vivo .........................................................................................................................................................37 FIGURE 1.13. PRODUCTS DURING THE PROCESS OF PROGLUCAGON ..................38 FIGURE 1.14. PHYSIOLOGY OF GLP-1 SECRETION AND ACTION ON GLP-1 RECEPTORS IN DIFFERENT ORGANS AND TISSUES .........................................................40 FIGURE 1.15. SEQUENCE AND STRUCTURE OF LIRAGLUTIDE AND ITS LIPIDATION. .........................................................................................................................................................41 FIGURE 1.16. GLP-1 AND GLP-1 RECEPTOR AGONISTS USED AS PHARMACEUTICALS .........................................................................................................................................................42 FIGURE 1.17. AGGREGATION KINETICS OF GLP-1 AS A FUNCTION OF PEPTIDE CONCENTRATION AT DIFFERENT pHs ..................................................................................45 Figure 1.18. Dependence of the GLP-1 aggregation lag time on the peptide concentration ................................................................. 46 Figure 1.19. Dependence of the GLP-1 aggregation half-time on the peptide concentration ................................................................. 47 Figure 1.20. Dependence of the GLP-1 aggregation half-time on the peptide concentration on a log-log scale ........................................... 48 Figure 1.21. Apparent growth rate of GLP-1 as a function of peptide concentration at different pHs ....................................................... 49 Figure 1.22. Changes in secondary structure in GLP-1 during aggregation shown with far-UV CD ....................................................... 52 Figure 1.23. Structure of ThT and its binding model to fibril-like β-sheets .......................................................................................... 54 Figure 1.24. Far-UV CD spectra associated with different types of secondary structure of proteins ....................................................... 57 Figure 1.25. FT-IR spectra of poly-L-lysine as a function of pH and temperature .................................................................................... 58 Figure 1.26. Singular value decomposition and back transformation of the first principal component to the original data space .... 60 Figure 1.27. Schematic of capillary isoelectric focusing (CIEF) and imaged CIEF (iCIEF) ................................................................. 62 Figure 2.1. Amino-acid sequence of GLP-1 and three GLP-1 analogues .............................................................................................. 65 Figure 2.2. Ionic strength of citrate, phosphate and Tris buffers ........ 66 Figure 2.3. Separation of peptide aggregates from supernatant using centrifugation ................................................................. 77 Figure 2.4. Calibration curve for SEC column ............................................. 82 Figure 3.1. ThT assay data following the aggregation of GLP-1 at different peptide concentrations .................................................. 86 Figure 3.2. Comparison of the kinetic parameters obtained from ThT aggregation assays performed by FJB and KLZ .................. 86 FIGURE 3.3. COMPARISON OF THE AGGREGATION LAG TIMES OF DIFFERENT BATCHES OF GLP-1 AT pH 7.5 .................................................................87 FIGURE 3.4. COMPARISON OF THE LAG TIME OF GLP-1 AGGREGATION IN DIFFERENT BUFFERS AROUND pH 7.5 ..................................................88 FIGURE 3.5. SOLUBILITY MEASUREMENT, NET CHARGE CALCULATION AND pI MEASUREMENT FOR GLP-1 USING CAPILLARY ISOELECTRIC FOCUSING..90 FIGURE 3.6. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN CITRATE BUFFER AT pH 3.0. .93 FIGURE 3.7. AFM IMAGES AND ANALYSIS OF THE HEIGHT AND WIDTH OF GLP-1 AGGREGATES FORMED IN CITRATE BUFFER AT pH 3.0...............................94 FIGURE 3.8. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN PHOSPHATE BUFFER AT pH 3.0. .................................................................................................................................95 FIGURE 3.9. HEIGHT AND WIDTH OF GLP-1 AGGREGATES FORMED IN PHOSPHATE BUFFER AT pH 3.0. ...........................................................................................................96 FIGURE 3.10. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN CITRATE BUFFER AT pH 3.5. .98 FIGURE 3.11. AFM IMAGES AND ANALYSIS OF THE HEIGHT AND WIDTH OF GLP-1 AGGREGATES FORMED IN CITRATE BUFFER AT pH 3.5. .........................99 FIGURE 3.12. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN PHOSPHATE BUFFER AT pH 3.5. .................................................................................................................................100 FIGURE 3.13. AFM IMAGES AND ANALYSIS OF THE HEIGHT AND WIDTH OF GLP-1 AGGREGATES FORMED IN PHOSPHATE BUFFER AT pH 3.5. .........................101 FIGURE 3.14. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN PHOSPHATE BUFFER AT pH 6.5. .................................................................................................................................103 FIGURE 3.15. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN PHOSPHATE BUFFER AT pH 7.5. .................................................................................................................................105 FIGURE 3.16. AFM IMAGES AND ANALYSIS OF THE HEIGHT AND WIDTH OF GLP-1 AGGREGATES INCUBATED IN PHOSPHATE BUFFER AT pH 7.5.................. 106 FIGURE 3.17. AFM IMAGES OF GLP-1 SPECIES FORMED AT DIFFERENT TIME POINTS DURING PEPTIDE AGGREGATION IN TRIS BUFFER AT pH 8.2 ..... 107 FIGURE 3.18. AFM IMAGES AND ANALYSIS OF HEIGHT AND WIDTH OF GLP-1 AGGREGATES INCUBATED IN TRIS BUFFER AT pH 8.2. ......................... 108 FIGURE 3.19. ASSESSMENT OF THE EFFECT OF SAMPLING ON GLP-1 AGGREGATION KINETICS................................................................. 111 FIGURE 3.20. CHANGES IN SECONDARY STRUCTURE IN GLP-1 DURING PEPTIDE AGGREGATION AT pH 3.0 AND 3.5 IN PHOSPHATE BUFFER SHOWN BY FAR-UV CD................................................................. 113 FIGURE 3.21. CHANGES IN SECONDARY STRUCTURE IN GLP-1 DURING PEPTIDE AGGREGATION AT DIFFERENT pHs SHOWN BY FT-IR. ...................... 114 FIGURE 3.22. SINGULAR VALUE DECOMPOSITION OF THE FAR-UV CD SPECTRA OF GLP-1 AT pH 3.0 AT DIFFERENT TIMES DURING AGGREGATION........... 116 FIGURE 3.23. SINGULAR VALUE DECOMPOSITION OF FT-IR SPECTRA OF GLP-1 AT DIFFERENT TIME POINTS DURING AGGREGATION AT pH 3.0 ............ 117 FIGURE 3.24. CUMULATIVE PERCENTAGE OF SINGLE-VALUE DECOMPOSITION (SVD) COMPONENTS. ................................................................. 118 FIGURE 3.25. RESULTS OF DLS MEASUREMENTS TO DETERMINE THE SIZE OF GLP-1 SPECIES IN SOLUTION AT DIFFERENT TIME POINTS DURING AGGREGATION................................................................. 121 FIGURE 4.1. LC-MS OF GLP-1 ................................................................. 130 FIGURE 4.2. LC-MS OF AM-GLP-1 ............................................................. 131 FIGURE 4.3. SOLUBILITY, NET CHARGE OF AM-GLP-1 AND GLP-1. .......... 133 FIGURE 4.4. AGGREGATION LANDSCAPES FOR GLP-1 AND AM-GLP-1....... 135 FIGURE 4.5. ThT AGGREGATION ASSAYS OF AM-GLP-1 AT DIFFERENT PEPTIDE CONCENTRATIONS AND pH VALUES.............................................. 137 FIGURE 4.6. KINETIC PARAMETERS FROM THE AGGREGATION KINETICS OF GLP-1 AND AM-GLP-1................................................................. 138 FIGURE 4.7. APPARENT GROWTH RATE RESULTS .................................................. 139 FIGURE 4.8. FITS OF AM-GLP-1 ThT DATA TO THE NEF MODEL .................... 142 FIGURE 4.9. FITS OF GLP-1 ThT DATA TO THE NEF MODEL ............................. 143 FIGURE 4.10. KINETIC PARAMETERS FROM THE AGGREGATION KINETICS OF THE NEF MODEL OF GLP-1 AND AM-GLP-1 ......................................................... 145 FIGURE 4.11. PRIMARY AND SECONDARY NUCLEATION RATES FOR AM-GLP-1 ThT DATA FITTED TO THE NEF MODEL ......................................................... 146 FIGURE 4.12. PRIMARY AND SECONDARY NUCLEATION RATES FOR GLP-1 ThT DATA FITTED TO THE NEF MODEL ......................................................... 147 FIGURE 4.13. SEM IMAGES OF PHOSPHATE BUFFER AT pH 3.0 .............................. 150 FIGURE 4.14. SEM IMAGES OF PHOSPHATE BUFFER AT pH 4.0 .............................. 151 FIGURE 4.15. SEM IMAGES OF TRIS BUFFER AT pH 8.2 ........................................... 152 FIGURE 4.16. SEM IMAGES OF AGGREGATED FORMS OF AM-GLP-1 UNDER ACIDIC CONDITIONS ........................................................................................................ 154 FIGURE 4.17. SEM IMAGES OF AGGREGATED FORMS OF AM-GLP-1 UNDER BASIC CONDITIONS ........................................................................................................ 155 FIGURE 4.18. SEM IMAGES OF AGGREGATED FORMS OF AM-GLP-1 SAMPLES DRIED WITH NITROGEN ........................................................................................................ 156 FIGURE 4.19. WIDTH OR DIAMETER OF AM-GLP-1 FIBRILS AND OLIGOMERS DETERMINED USING GREY SCALE PROFILES ......................................................... 157 FIGURE 4.20. MEASUREMENT OF MAJOR AND MINOR AXIS OF AM-GLP-1 OLIGOMERS FORMED IN 25 mM CITRATE BUFFER AT pH 4.0 ............................... 158 FIGURE 4.21. GREY SCALE PROFILES ALONG AM-GLP-1 FIBRILS ......................... 159 FIGURE 4.22. ANS AND Trp FLUORESCENCE OF AM-GLP-1 AND GLP-1 BEFORE AND AFTER AGGREGATION ......................................................................................... 163 FIGURE 4.23. TRYPTOPHAN FLUORESCENCE: SHIFT IN $\Lambda_{\text{MAX}}$ AFTER AGGREGATION ................................................................................................................................. 164 FIGURE 4.24. ANS FLUORESCENCE OF GLP-1 AND AM-GLP-1 AGGREGATES FORMED AFTER AGGREGATION AND AFTER SEPARATION OF INSOLUBLE/SOLUBLE FRACTIONS ................................................................. 165 FIGURE 4.25. ANS FLUORESCENCE EXPERIMENTS TO DETERMINE THE SPECIFICITY OF ANS BINDING: MAXIMUM FLUORESCENCE SIGNAL .... 166 FIGURE 4.26. TRYPTOPHAN FLUORESCENCE EXPERIMENTS: AFTER AGGREGATION AND CENTRIFUGATION STEPS ................................................................. 168 FIGURE 4.27. TRYPTOPHAN FLUORESCENCE EXPERIMENTS: $\lambda_{\text{MAX}}$ .................. 169 FIGURE 4.28. EX-SITU ThT FLUORESCENCE EXPERIMENTS: AFTER AGGREGATION AND CENTRIFUGATION ................................................................. 171 FIGURE 4.29. SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 AT ACIDIC pH BEFORE AND AFTER AGGREGATION ...................................................... 172 FIGURE 4.30. SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 AT ACIDIC AND NEUTRAL pH BEFORE AND AFTER AGGREGATION ....................... 173 FIGURE 4.31. SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 AT NEUTRAL AND BASIC pH BEFORE AND AFTER AGGREGATION ....................... 174 FIGURE 4.32. FRACTIONS OF SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 BEFORE AND AFTER AGGREGATION AS A FUNCTION OF pH ........... 176 FIGURE 4.33. THREE-DIMENSIONAL FAR-UV CD SPECTRAL LANDSCAPE ILLUSTRATING THE DIFFERENCES IN SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 AT DIFFERENT pH VALUES USING FRESHLY PREPARED SAMPLES ................................................................. 177 FIGURE 4.34. THREE-DIMENSIONAL FAR-UV CD SPECTRAL LANDSCAPE ILLUSTRATING THE DIFFERENCES IN SECONDARY STRUCTURE OF GLP-1 AND Am-GLP-1 AT DIFFERENT pH VALUES AFTER 144 h OF AGGREGATION. ................................................................. 178 FIGURE 4.35. CORRELATION OF NET CHARGE WITH AGGREGATION PROPENSITY AND SECONDARY STRUCTURE FOR GLP-1 AND Am-GLP-1 ............. 182 FIGURE 4.36. CORRELATION OF AGGREGATION PROPENSITY ($T_{\text{LAG}}$ AND $T_{1/2}$) AND SECONDARY STRUCTURE FOR GLP-1 ................................................................. 186 FIGURE 4.37. CORRELATION OF AGGREGATION PROPENSITY ($T_{\text{LAG}}$ AND $T_{1/2}$) AND SECONDARY STRUCTURE FOR Am-GLP-1 ................................................................. 187 Figure 4.38. Two different monomer conformations (state $M_A$ and $M_B$) and how these relate to the pI and their role in forming on- and off-pathway oligomers. ................................................................. 188 Figure 5.1. Amino-acid sequence of GLP-1, AM-GLP-1, IPP4, IPP5 and Liraglutide. ........................................................................................................... 193 Figure 5.2. LC-MS of IPP4. .................................................................................. 195 Figure 5.3. LC-MS of IPP5. .................................................................................. 196 Figure 5.4. Solubility, net charge and experimentally determined pI of lipidated GLP-1 peptides. ........................................................................................................... 198 Figure 5.5. ThT aggregation assay data for lipidated peptides at different pH values. ........................................................................................................... 199 Figure 5.6. Three-dimensional aggregation landscapes illustrating the ThT assay data for peptide aggregation for lipidated peptides at different pH values. ........................................................................................................... 200 Figure 5.7. ThT aggregation assays of lipidated peptides at different peptide concentrations and pH values. ........................................................................................................... 202 Figure 5.8. Kinetic parameters from the aggregation kinetics of IPP4. ........................................................................................................... 203 Figure 5.9. SEM images of aggregated forms of IPP4 in phosphate buffer at pH 7.5. ........................................................................................................... 205 Figure 5.10. Size of oligomer-like IPP4 species formed in 25 mM phosphate buffer at pH 7.5. ........................................................................................................... 206 Figure 5.11. SEM images of aggregated forms of IPP4 in Tris buffer at pH 8.2. ........................................................................................................... 207 Figure 5.12. SEM images of freshly dissolved lipidated peptides of IPP5 in phosphate buffer at pH 7.5. ........................................................................................................... 208 Figure 5.13. SEM images of aggregated forms of IPP5 in 25 mM phosphate buffer at pH 7.5 and measurement of width of fibrils. ........................................................................................................... 209 Figure 5.14. Far-UV CD spectra of lipidated peptides at different pH VALUES BEFORE AND AFTER AGGREGATION .................................................. 211 FIGURE 5.15. SECONDARY STRUCTURE OF THE LIPIDATED PEPTIDES AT DIFFERENT pH VALUES BEFORE AND AFTER THE AGGREGATION ASSAY. ................................................................................................................................. 212 FIGURE 5.16. SECONDARY STRUCTURE OF GLP-1, Am-GLP-1 AND THE LIPIDATED PEPTIDES AT DIFFERENT pH VALUES BEFORE AND AFTER THE AGGREGATION ASSAY ........................................................................................................... 214 FIGURE 5.17. IPP4 AND IPP5 OLIGOMER DISTRIBUTION ANALYSED BY SEC AND ESTIMATED SIZES OF OLIGOMERS ................................................................................................................................. 215 FIGURE 5.18. IPP4 AND IPP5 OLIGOMERS DISTRIBUTION AT TWO DIFFERENT TIME POINTS ANALYSED BY SEC ................................................................................................................................. 216 FIGURE 5.19. RESULTS OF DLS MEASUREMENTS TO DETERMINE THE SIZE OF IPP5 SPECIES IN SOLUTION AT TIME ZERO AND AT FOUR DIFFERENT pH VALUES. ................................................................................................................................. 218 FIGURE 5.20. ANALYSIS OF DLS RESULTS: SIZE AND AMOUNT OF SMALLER SPECIES OF IPP5 FORMED AT FOUR DIFFERENT pH VALUES. .................................................. 219 FIGURE 5.21. RESULTS OF DLS MEASUREMENTS TO DETERMINE THE SIZE OF IPP5 SPECIES IN SOLUTION AFTER 144 h INCUBATION AT 37 °C AND AT FOUR DIFFERENT pH VALUES. ................................................................................................................................. 220 FIGURE 5.22. ThT FLUORESCENCE CAUSED BY NON-FIBRILLAR STRUCTURES. ................................................................................................................................. 225 FIGURE 5.23. INFLUENCE OF DIFFERENT ON-PATHWAY OLIGOMERS ON THE AGGREGATION KINETICS ................................................................................................................................. 227 ALL FIGURES TAKEN FROM OTHER SOURCES ARE DONE SO WITH PERMISSION FROM THE RELEVANT JOURNALS. \| Abbreviation \| Description \| Page \| \|-------------\|------------------------------------------------------------------------------\|------\| \| AF4 \| Asymmetric Flow Field Flow Fractionation \| 226 \| \| AFM \| Atomic Force Microscopy \| 78 \| \| Am-GLP-1 \| Glucagon-like peptide C-terminally amidated \| 65 \| \| ANS \| 8-Anilinonaphthalene-1-sulfonic acid \| 76 \| \| APR \| Aggregation-prone region \| 17 \| \| CIEF \| Capillary Isoelectric Focusing \| 60 \| \| CMC \| Critical/Minimum Micelle Concentration \| 14 \| \| DLS \| Dynamic Light Scattering \| 69 \| \| DPP-4 \| Dipeptidyl Peptidase 4 \| 40 \| \| DTPA \| Pentetic Acid \| 29 \| \| EDTA \| Ethylenediaminetetraacetic Acid \| 29 \| \| EOF \| Electro Endosomatic Flow \| 61 \| \| FAR-UV CD \| Far-UV Circular Dichroism \| 73 \| \| FS \| Fused Silica \| 60 \| \| FTIR \| Fourier-transform Infrared Spectroscopy \| 75 \| \| GAP-43 \| Growth Associated Protein 43 \| 35 \| \| GLP-1 \| Glucagon-Like Peptide 1 \| 3 \| \| GLP-2 \| Glucagon-Like Peptide 2 \| 39 \| \| hIAPP \| Human Islet Amyloid Polypeptide \| 14 \| \| HNE \| 4-Hydroxynonenal \| 34 \| \| HPLC \| High-performance Liquid Chromatography \| 68 \| \| IAPP \| Islet Amyloid Polypeptide Precursor \| 24 \| \| iCIEF \| Imaged Capillary Isoelectric Focusing \| 70 \| \| IL-1ra \| Interleukin-1 receptor antagonist \| 29 \| \| Abbreviation \| Description \| Page \| \|--------------\|-------------\|------\| \| LC-MS \| Liquid chromatography-mass spectrometry \| 68 \| \| LPDs \| Lipopeptide detergents \| 33 \| \| MALS \| Multi-angle light scattering \| 226 \| \| MPGF \| Major proglucagon fragment \| 39 \| \| NEF \| Nucleated-polymerisation & elongation model with fragmentation \| 141 \| \| NMR \| Nuclear magnetic resonance \| 18 \| \| PEG \| Polyethylene glycol \| 26 \| \| SAXS \| Small-angle X-ray scattering \| 226 \| \| SEM \| Scanning electron microscopy \| 78 \| \| SLS \| Static light scattering \| 226 \| \| ssNMR \| Solid-state nuclear magnetic resonance \| 11 \| \| ThT \| Thioflavin T \| 71 \| \| TIC \| Total ion count \| 129 \| \| Tween20 \| Polysorbate 20 \| 28 \| \| Tween80 \| Polysorbate 80 \| 28 \| LIST OF APPENDICES ANALYTICAL DATA SHEETS ................................................................. 279 \| Chapter \| Title \| \|---------\|----------------------------------------------------------------------\| \| 1 \| Introduction \| \| 2 \| Theoretical Framework \| \| 3 \| Methodology \| \| 4 \| Results \| \| 5 \| Discussion \| \| 6 \| Conclusion \| xxviii 1 INTRODUCTION In recent years, biopharmaceuticals specifically peptide therapeutics, have become increasingly important and are now responsible for a considerable share of the pharmaceutic market.\textsuperscript{1,2} However, despite many advantages over other types of therapeutic agents such as high bioactivity and specificity, peptides also pose considerable challenges.\textsuperscript{3} One of these is associated with their physical stability as many peptides have a tendency to aggregate and precipitate. This has a major impact on their usability and safety: predictable shelf lives are crucial, and it is known that peptide aggregates formed in drug solutions can induce adverse immune responses and lead to a loss of safety and efficacy.\textsuperscript{4} One example of physical instability is polypeptide chain self-assembly into highly regular structures such as amyloid fibrils. The formation of amyloid fibrils is one of the most common processes influencing almost all phases of biological drug development. The importance of understanding these processes becomes clear by the broad range of different protein pharmaceuticals known to form different types of aggregates as shown in Table 1.1. \| peptide or protein \| length (residues) \| conditions \| type of aggregates \| \|------------------------------------\|-------------------\|-------------------------------------------------\|--------------------\| \| GLP-1 (7-37) \| 31 \| pH 7.5-8.2 \| fibril$^5$ \| \| GLP-1 (7-36)-NH$_2$ \| 30 \| pH 7.4 \| fibril$^6$ \| \| glucagon \| 29 \| pH 2.0 \| fibril$^7-9$ \| \| glucagon \| 29 \| pH 8.5-9.7 \| fibril$^{10,11}$\| \| salmon calcitonin \| 32 \| neutral pH \| fibril$^{12-15}$\| \| amylin \| 37 \| under different conditions \| fibril$^{16-20}$\| \| insulin \| 51 (31 chain A, 20 chain B) \| pH 2.0 \| fibril$^{21-23}$\| \| \| \| pH 1.1-3.2 \| fibril$^{24-27}$\| \| \| \| pH 1.5-7.5 \| fibril$^{28}$ \| \| Insulin \| 51 (31 chain A, 20 chain B) \| pH 1.75-2.0 \| spherulite$^{29}$\| \| \| \| conc. < 5 mg ml$^{-1}$ \| fibril$^{29}$ \| \| \| \| conc. > 5 mg ml$^{-1}$ \| \| \| insulin analogues \| 51 (31 chain A, 20 chain B) \| high temperature and mechanical agitation \| precipitation$^{30}$\| \| human parathyroid hormone \| 84 \| – \| fibril$^{31}$ \| \| human interferon a2b \| \| chemical degradation-oxidation \| covalent aggregate$^{32,33}$\| \| PYY (3-36) & lipidated derivatives \| 34 \| pH 2, 4 & 8 \| micelles / nanotapes / fibrillar hydrogels$^{34}$\| \| Proleukin \| \| +SDS \| formation of micellar-like structures containing approx. 27 molecules$^{35}$\| \| Met-G-CSF \| \| pH 6.9, 37 °C \| precipitation$^{36}$\| Table 1.1. Some examples of peptide and protein pharmaceuticals known to form different types of aggregates. To learn more about the formation of amyloid fibrils and the mechanisms by which peptide and protein aggregation occurs, as well as the factors that influence the reaction, numerous and extensive research programmes have been undertaken. This has led to significant progress, especially in the field of peptides and proteins where aggregation in vivo is associated with disease states, particularly neurodegenerative diseases.\textsuperscript{37} Typical examples of neurodegenerative diseases associated with amyloid aggregates are Alzheimer’s Disease (Amyloid-$\beta$)\textsuperscript{38}, Parkinson’s disease ($\alpha$-synuclein)\textsuperscript{39,40} and Huntington’s disease (Huntington fragments)\textsuperscript{41}. A considerable amount of the research on aggregation and self-assembly of disease-related peptides and proteins can be applied to the aggregation of peptide-based therapeutic agents currently developed by the pharmaceutical industry. In general, however, the aggregation pathways of peptides and polypeptide-based drugs coming through the drug pipelines have not been characterised in any depth. The topic of this Thesis is the study of the physical stability of glucagon-like peptide 1 (GLP-1) and chemically modified forms of GLP-1. To understand the aggregation mechanism and the physical stability of peptide and protein pharmaceuticals, it is essential to understand the influence of mutations and other types of chemical modifications. In this Chapter, a short introduction is provided on the physical stability and aggregation of peptides, kinetics of peptide aggregation, different factors influencing peptide aggregation, the lipidation of peptides and more details about the peptide used throughout this study, GLP-1 and its lipidated analogues. ### 1.1 A Brief History of Amyloids The research on amyloids and amyloid fibrils has a long and eventful history. Most likely, the first observation was by Nicolao Fontano, who described an autopsy of a young man with an abscess in his liver and a large spleen filled with white stone.\textsuperscript{42} In 1854, Rudolf Virchow described the structures as amyloids because he observed the peculiar reaction of the corpora amylacea of the nervous system with iodine.\textsuperscript{43} He adopted the term from Matthias Schleiden, a botanist, who coined the term less than two decades earlier to describe a normal amylaceous constituent of plants.\textsuperscript{42} The iodine reaction for starch was already reported by J.J. Colin and H.F. Gaultier de Clauburg, and independently Stromeyer in 1814.\textsuperscript{44} The term amyloid replaced with time the originally more common terms ‘lardaceous’ or ‘waxy’ changes. In 1859, Carl Friedreich and August Kekulé proved that the waxy spleen they observed consisted neither of amylon nor cellulose but from albumoid compounds based on the high nitrogen content.\textsuperscript{42} Why the term amyloidosis still prevailed is not clear, but it is assumed that Virchows standing as a pathologist and the common use of iodine to stain the samples, had an influence. Aniline based dyes used to recognise amyloid were first described in parallel by André-Victor Cornil, Richard Heschl and Rudolph Jürgen in 1875.\textsuperscript{42} These initially used metachromatic stains were eventually replaced by another aniline based stain, Congo Red. Generally used for staining textiles, Congo Red was found to bind avidly to amyloid by Bennhold in 1922.\textsuperscript{45} \begin{figure}[h] \centering \includegraphics[width=0.8\textwidth]{amyloid_fibrils.png} \caption{Negatively stained amyloid fibrils.} Amyloid fibrils imaged using an electron microscope by Shirahama & Cohen in 1965.\textsuperscript{46} Note various combinations and coplanar disposition of filaments and loose random twisting of fibrils (x 250,000). \end{figure} In the 20th Century, more and more details about the structure of amyloids were discovered. William Astbury took the first diffraction images of amyloid and discovered a fibrous state for many proteins, for example keratin in 1931-33 and pepsin in 1934.\textsuperscript{47–50} With the help of electron microscopy, Cohen and Calkins first recognised in 1959 that amyloid demonstrates a non-branching fibrillar structure with a width of 6-13 nm.\textsuperscript{51} The first twisting protofilaments were reported only six years later by Shirahana and Cohen.\textsuperscript{52} Figure 1.1. In 1967, Geddes, Parker, Atkins and Beighton also published a paper on X-ray diffraction patterns of naturally occurring cross-$\beta$ fibrous proteins.\textsuperscript{53} Just one year later, Eanes and Glenner published their work about filamentous protein components of amyloid-laden tissue studied by X-ray diffraction procedures. They concluded from the X-ray diffraction patterns that the material forms a “cross-$\beta$” structure. They observed an intense ring at 4.75 Å, an overlaying diffuse halo at 4.3 Å and a broad and less intense ring at 9.8 Å.\textsuperscript{54} These features were interpreted as a “pleated sheet” structure consisting of amyloid polypeptide chains regularly folded on themselves, where adjacent chain segments were laterally and antiparallel arranged.\textsuperscript{54} The data also suggested that the axes of the chain segments run orthogonal to the filament axis.\textsuperscript{54} In the last 50 years, the progress in our understanding of the structure of amyloid aggregates has been remarkable and has mainly been driven by further X-ray and electron diffraction experiments as well as the rapid evolution of solid-state nuclear magnetic resonance (ssNMR) and cryo-electron microscopy (cryo-EM). For a detailed review on about half a century of amyloid research see Ke \textit{et al.}, 2020.\textsuperscript{55} 1.2 Molecular Structure of Protein or Peptide Amyloid Fibrils With the report of cross-β fibrils, a milestone in the general understanding of amyloid fibrils was reached. Nowadays, a commonly accepted biophysical definition of amyloid fibrils is that they show a cross-β fibre diffraction pattern when measured by X-ray diffraction. The origin of these patterns is caused by the unique way the peptides or proteins are assembled. Elongated peptide or protein strands (β-strands) stack on top of each other forming β-sheets. The β-strands within the β-sheets are held together by hydrogen bonds formed between their amide groups, resulting in the measured distance of 4.8 Å of the β-strands within the β-sheets, Figure 1.2. The interaction of pairs of β-sheets to form a protofilament is supported by the interdigitating or butting of amino-acid side chains extending on both sides of the β-sheets. Because of the interaction of the side chains between the β-sheets, protofilaments are sometimes also called steric zippers. The length of the side chains determines the distance of the two interacting β-sheets and is typically between 5 and 16 Å, Figure 1.2. The interfaces between the β-sheets are, with few exceptions, devoid of water. The self-assembly of these aggregates is energetically favourable and stable for several reasons. Water plays a significant role, specifically it orients near non-polar surfaces, which adversely affects its 3D hydrogen-bonding network. This leads to a decrease in configurational entropy. Reducing the hydrophobic surface interacting with water leads to increased configurational entropy of water molecules. Therefore, the hydrophobic effect is experienced as an attractive force between two non-polar objects if they are brought sufficiently close together. The arrangement of the β-strands in the β-sheets can either be in- or out-of-register. The former means that the β-strands are orthogonal to the β-sheet direction and out-of-register that the β-strands are out of square, Figure 1.3A. Figure 1.2. The cross-β-sheet motif. A defining characteristic of amyloid fibrils is the typical X-ray fibre cross-β diffraction caused by their cross-β-sheet motif. The typical spacing of the β-strands causes a meridional reflection at about 4.8 Å and the distance between the stacked β-sheets causes a protein dependent equatorial reflection between 6–12 Å. In the Figure the distance of 10 Å is chosen as an example. Figure adapted from R. Riek & D. S. Eisenberg, 2016.$^{58}$ If the β-strands are in-register in a β-sheet, energetically favourable side chain ladders can be formed. Typical ladders are formed of asparagine or tyrosine, Figure 1.3B.$^{59}$ From theoretical considerations, it becomes clear that there are many possible β-strand arrangements. Assuming that the interacting β-strands are homosteric, four distinctly different amyloid structures are adoptable by a single sequence. It is the case because each β-strand can be orientated, N- to C-terminus, and has a distinct front and back side. These two variables lead to two arrangements in which the β-strands are parallel and two in which the orientation of the β-strands alternates (antiparallel). In addition, these arrangements can be found with separated face and back sides (antifacial) or alternating between face and back side (equifacial), Figure 1.4.$^{59}$ Figure 1.3. In- and out-of-register β-sheets and energetically favourable ladders. A) In-register sheets are defined by strands orthogonal to its translational repeat direction (white vertical arrows) in comparison to out-of-register sheets. If the angle is not orthogonal, the sheet is out-of-register. B) In-register β-sheets are capable of forming energetically favourable ladders, for example, asparagine (Asn) or tyrosine (Tyr) ladders. Figure adapted from D. S. Eisenberg & M. R. Sawaya, 2017.\textsuperscript{59} These four different β-sheets can be arranged in ten different classes of homosteric zipper amyloid spines, Figure 1.4. These different possible β-strand arrangements are biological significant as it means that a single sequence can theoretically self-assemble in many ways, which is known and observed as amyloid polymorphism.\textsuperscript{59} This may be the molecular basis of prion strains.\textsuperscript{61,62} The number of different steric zipper amyloid spines increases even further if segmental polymorphs, combinational polymorphs, intra-/intermolecular polymorphs and single-chain registration polymorphs are considered. For excellent reviews on the different structures of amyloid fibrils that have been observed, peptide fibrilization in general and the influence of peptide aggregation on current and future nanotechnology see D. S. Eisenberg & M.R Sawaya, 2016, I. Hamley, 2007 and Wei \textit{et al.}, 2017.\textsuperscript{59,63,64} Figure 1.4. Symmetry classes of homo-steric zipper amyloid spines. β-strands showing the C- to N-terminal direction, up/down edge and front/back face are illustrated as fictitious Max Perutz bank notes. They can be arranged in four different β-sheet conformations. These four different β-sheets can form ten different homo-steric zipper amyloid spines based on symmetry considerations, also called classes. Single-bladed arrows signify 2-fold symmetry axes, a $180^\circ$ rotation about the arrow. Shifts of one-half or a whole repeat distance between β-strands of a β-sheet are possible. Figure adapted from D. S. Eisenberg & M. R. Sawaya, 2017.\textsuperscript{59} 1.3 Atomic Structure of Glucagon Fibrils An example of the atomic structure of a fibrillar aggregate of a peptide hormone is shown in Figure 1.5. The structure of glucagon at pH 2 was resolved by Gelenter et al. using ssNMR and $^{13}$C and $^{15}$N-labeled glucagon. The observed length of the $\beta$-strand is formed by the complete length of the 29 residues of glucagon.\textsuperscript{65} Such a long $\beta$-strand is remarkable as most commonly observed $\beta$-strands in known amyloid fibril structures and $\beta$-barrel membrane proteins only show $\beta$-strands containing fewer than thirteen amino acids.\textsuperscript{66,67} Glucagon aggregated at pH 2 also showed not only one but two different $\beta$-strand conformations. Conformer I and Conformer II can be differentiated from each other by their different wet and dry interfaces. Conformer I adopts a steric zipper structure with its odd-numbered residues, whereas Conformer II uses even-numbered residues. These two different conformers form the basic unit of glucagon fibrils at low pH which is a dimer of dimers.\textsuperscript{65} The symmetry class can be described as antiparallel, antisymmetric and equifacial like class 8 in Figure 1.4. The structure of two molecular conformations integrated within a single ultrastructural fibril morphology is unique among the amyloid fibril structures known today, as well as containing the longest known $\beta$-strand among all peptides and proteins.\textsuperscript{65} The fibrillar structure of glucagon is a good example of typical side chain interactions. The steric zipper of glucagon formed at pH 2 is stabilised by a series of different side chain interactions. These favourable interactions include one tetrameric ‘aromatic box’ (F6-W25), several polar interactions (Q3-N28, T7-G24, S11-Q20, D15-S16), cation-$\pi$ interactions (Y13-R18) and steric complementarity (M27-G4). The cation-$\pi$ interaction mitigates an unfavourable electrostatic repulsion caused by the Arg18 side chains at the homodimer interface.\textsuperscript{65} Figure 1.5. Atomic structure of a glucagon fibril at low pH. Atomic-resolution structure of glucagon fibrils at pH 2 determined using ssNMR. A) Side and top view of the fibril. The conformation of the β-strands in the β-sheet alternate between Conformer I (red) and Conformer II (blue). It is similar to equifacial antisymmetric (class 8). However, one β-sheet is shifted by one position so that the β-strands are face-to-face. B) Side-chain packing in the dimer-of-dimer subunit steric zipper. The fibril axis is pointing out of the page. The light blue shaded region represents the solvent. Detailed image of the two conformers with hydrophobic side chains coloured white, polar residues green, and positively charged residues red. Figure adapted from Gelenter et al., 2019.\textsuperscript{65} Alterations in pH, temperature, mechanical conditions, or the peptide concentration can easily influence the interaction of amino-acid side chains. This leads to the assumption that the glucagon sequence can form a diverse set of 3D structures.\textsuperscript{65} This is supported by the fact that at a pharmaceutical concentration of $\sim$287 µM ($\sim$1 mg mL$^{-1}$) glucagon not only exists as straight fibrils but also in a twisted morphology. The system shows a peptide concentration dependence as the twisted species become more predominant below 72 µM (0.25 mg mL$^{-1}$). Additional fibrils morphologies can be formed by glucagon under different pH, temperature, and mechanical conditions.\textsuperscript{9,68} ### 1.4 Aggregation to Form other Types of Structures Higher-order structures comprised of amyloid-like fibrils have been observed for a number of proteins. Insulin and β-lactoglobulin have been shown to form spherulites, spherical structures consisting of radiating fibrils from a central core.\textsuperscript{69} In addition, a number of peptides that self-assemble into fibrillar structures have also been shown to form hydrogels.\textsuperscript{63,70,71} The formation of hydrogels can also be influenced by lipidation. The gut-derived peptide hormone PYY3-36 was shown to form hydrogels if lipidated but not in its unlipidated form.\textsuperscript{34} The measured peptide concentration of the formed hydrogels was in the range of 3.5-5.5 mM.\textsuperscript{34} For an excellent book chapter about colloidal gels from proteins and peptides see Djabourov \textit{et al.}, 2013.\textsuperscript{72} Amorphous aggregates, also known as disordered aggregates, are unstructured and contain no ordered intermolecular interactions.\textsuperscript{73} They are often granular in appearance and can vary in size and solubility. When insoluble they form precipitates, which presents a major challenge for biotechnology. ### 1.5 Kinetics of Fibrils Formation Aggregation is a complex phenomenon and can occur from many different states. In many cases, aggregation occurs from an unfolded or largely unstructured state, i.e., in the case of many peptides and intrinsically disordered proteins.\textsuperscript{74–77} For amyloid fibril formation, the monomeric peptides first selfassociate to form oligomeric structures which go on to form a critical nucleus, Figure 1.6. Elongation of the nucleus is rapid relative to its formation giving rise to the sigmoidal aggregation kinetics often observed, Figure 1.6. The lag time caused by the primary nucleation process which can be shortened or eliminated by the addition of seeds.\textsuperscript{78,79} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{image.png} \caption{General mechanism of amyloid formation} Simplification of the mechanism of aggregation of amyloid fibrils following sigmoidal kinetics. Shown are the primary nucleation, elongation and saturation phases. \end{figure} \subsection{Different Aggregation Mechanisms} As shown in Figure 1.6, the kinetics of aggregation/fibril formation can often be described by a sigmoidal curve, with a lag phase, growth phase and a final plateau, at which point the system either completely depletes the pool of monomer, or the system reaches equilibrium between peptide monomers, oligomers and fibrils. Since the middle of the last century, significant research has been conducted in order to understand the aggregation process of polypeptide chains in detail.\textsuperscript{80} In 1961, Oosawa and Kasai introduced a nucleated-polymerisation mechanism and a theory on the helical aggregation of macromolecules in which each amino-acid residue binds to three neighbouring residues instead of one, as it would in a simple linear polymer.\textsuperscript{81} Two decades later, Ferrone & co-workers added a double nucleation mechanism in which the fibrils autocatalyze aggregation by the nucleation of additional polymers at the surface of existing ones.\textsuperscript{82} Recently, Cohen & co-workers described an analytical solution for the formation and growth of fibrils including not only primary nucleation and growth elongation but fragmentation of filaments and surface-catalysed secondary nucleation,\textsuperscript{83} Figure 1.7A. Their approach has been successful in describing and predicting the aggregation behaviour of the Aβ42 peptide.\textsuperscript{84,85} In their model, nucleation is a high-order reaction and oligomeric species that are formed prior to the final fibrillar structure are all on-pathway. In this case, lag times depend strongly on the peptide/protein concentration and lag times decrease with increasing peptide concentration. \subsection{1.5.2 Off-Pathway Oligomers or Off-Pathway Species} In the last ten years, there have been a number of observations on peptide and protein aggregation which can’t be explained by these mechanisms alone. For example, it was shown that an amyloidogenic fragment of native human islet amyloid polypeptide (hIAPP)\textsuperscript{86} and GLP-1(7-37)\textsuperscript{5}, under certain conditions, have aggregation kinetics that show no dependence on peptide concentration. Such unusual results are not consistent with a pure on-pathway oligomer mechanism and have been explained, in part, by the presence of off-pathway oligomeric species populated during the aggregation reaction. Rhoades & co-workers also introduced an off-pathway oligomer model for peptide aggregation in 2000 in which the monomeric peptide concentration is buffered by the existence of off-pathway micelles\textsuperscript{87}, Figure 1.7C. They proposed that above a minimum peptide or protein concentration, the minimum micelle concentration (CMC), off-pathway micelles are formed, Figure 1.7C. In this case, the formation of the micelles maintains the monomer concentration at the CMC. The formation of micelles is one property peptides have in common with surfactants and detergents. Supporting this, it was also shown that Aβ peptides lower the surface tension of water with increasing peptide concentration similar to the behaviour of surfactants.\textsuperscript{88} Figure 1.7. Different mechanisms involving on- and off-pathway oligomeric species. A) Simple on-pathway model and additional secondary nucleation where M is monomer, on are on-pathway oligomers, and off are off-pathway oligomers. Primary nucleation with the primary nucleation rate $k_n$ leads to on-pathway nuclei consisting out of $n_c$ monomers. They are assumed to be stable and no dissociation happens. Fibrils are formed by elongation or through fragmentation and by monomer-dependent secondary nucleation. The rate constants for elongation, dissociation, fragmentation and secondary nucleation are $k_+$, $k_d$, $k_-$ and $k_{sn}$, respectively. In a nucleation-elongation model, a higher monomer concentration M leads to faster aggregation. B) Simple off-pathway model with the rate constants $k_{on}$ and $k_{off}$ as association and dissociation rate constants, respectively. C) On- and off-pathway species mechanism following a critical peptide concentration (CMC) model. At the CMC the system is saturated and excess monomers associate as off-pathway aggregates. D) On- and off-pathway species model without a CMC. The two pathways are independent of each other. E) On- and off-pathway species model in which there is an interaction between the different species. This can lead to aggregation reactions in which there is an increase in lag time and $t_{1/2}$ with increasing peptide concentration. This could be caused by a change in the fluidity of the solution with increasing peptide concentration, or the binding of off-pathway species to binding sites of on-pathway aggregates. In 2008 it was shown by Powers and Powers\textsuperscript{89} that aggregation mechanisms in which a parallel off-pathway process occurs additional to the on-pathway process can not only lead to constant $t_{\text{lag}}$ and $t_{1/2}$ but also to increasing $t_{1/2}$ values with increasing peptide/protein concentration. In their model, the increase of $t_{1/2}$ with increasing peptide/protein concentration can be explained by the effect of the off-pathway species which buffer the available monomer concentration during the aggregation process, Figure 1.7D. Subsequently the rate of fibril formation is restricted but the amount of peptide/protein available for the formation of fibrils is not. However, $t_{\text{lag}}$ itself cannot increase with increasing peptide/protein concentration, as shown mathematically in Section 4.8. The observation of increasing $t_{\text{lag}}$ with increasing peptide concentration can only be explained by more complex models, for example, one in which there is an active interaction of the off-pathway species with on-pathway species (Figure 1.7D), in comparison to simple on-pathway models or other on- and off-pathway models.\textsuperscript{90} ### 1.6 Factors Affecting the Physical Stability (Aggregation) of Peptides It is well established that the physical stability of peptides is affected by many factors including temperature, excipients, freeze-thaw, processing, peptide sequence, peptide concentration, pH and chemical modifications.\textsuperscript{73,91–95} A brief summary of the different factors affecting the physical stability of peptides follows. #### 1.6.1 Amino-acid Sequence How the amino-acid sequence of a peptide affects its intrinsic propensity to aggregate, to form either amorphous or amyloid-like fibrils, is now very well understood, such that there are numerous prediction programmes available.\textsuperscript{73,96} Factors such as hydrophobicity, charge state, $\beta$-sheet forming propensity along with other properties are all known to contribute.\textsuperscript{73,96–98} A consecutive series of five or more residues which all have a high intrinsic propensity form what is known as an aggregation-prone region, APR.\textsuperscript{96,99–102} In some cases, these methods have been used to predict the effect of an amino-acid substitution on aggregation propensity, for example, the effect of pathogenic mutations on the aggregation of Aβ \textit{in vitro} and \textit{in vivo}.\textsuperscript{96} A typical example of a prediction of structural aggregation using the TANGO method is shown in Figure 1.8. A number of approaches have been developed to predict aggregation propensity some of which are primarily based on our knowledge of the intrinsic propensity of amino acids to aggregate and form fibrils. As our understanding of the factors that affect aggregation in terms of amino-acid sequence has improved, methods have also been developed that not only take into account APRs in peptide sequence but also other factors such as the presence of gatekeeper residues that help prevent aggregation,\textsuperscript{103–105} and the flexibility and solvent accessibility of the peptide chain.\textsuperscript{106} Other algorithms also take into account the propensity of amino acids to form other forms of stable structure such as α-helices, as aggregation is always in competition with the formation of other conformational states.\textsuperscript{107} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{figure1.png} \caption{Prediction of structural aggregation.} Aggregation propensity of GLP-1 predicted by the Tango algorithm at pH 7.5. Any segment with an aggregation tendency above 5% over five or more residues in length is a potential aggregating segment. The data are shown as percentage of β-strand (orange line), β-turns (red line), α-helical (green line), aggregation (dark blue line) and helical aggregation (bright blue line). \end{figure} Since high-resolution structures of amyloid fibrils have become available from X-ray crystallographic and NMR studies, structure-based methods for predicting APRs have also been developed. In these cases, APRs which are compatible with the formation of the cross β-structure seen in the core of amyloid fibrils are identified by threading peptide and protein sequences through templates of different amyloid structures scoring each resultant structure in terms of packing density, pairing energies for side chains that pack against each other in the structure and other metrics. In another case, a combination of the two approaches has been used and a position-specific scoring matrix developed taking into account both intrinsic propensities and also structure. \| Name \| Description of method \| \|---------------\|---------------------------------------------------------------------------------------\| \| Zygreggator \| APRs and gatekeepers, protein flexibility and solvent accessibility \| \| TANGO \| statistical thermodynamics approach. Identifies APRs but takes into account competition β-aggregated state and other conformations \| \| SALSA \| uses β-propensity for each amino acid and a sliding average to identify APRs \| \| AGGRESCAN \| uses aggregation propensity for each amino acid \| \| FoldAmyloid \| packing density \| \| 3D profile method \| structure-based method uses amyloid fibril structure as a template \| \| Pre-AMYL \| structure-based method uses amyloid fibril structure as a template \| \| PASTA \| pairing energies calculated for pairs of residues within an amyloid structure. Sequences are scored by energies to identify APRs \| \| BETASCAN \| β-strand pairing energies using amyloid core structure \| Table 1.2. Methods for predicting aggregation-prone regions and aggregation propensity in peptides. For peptides which do not form stable tertiary or quaternary structures, these approaches work well, and predictions are generally reasonably accurate. In addition, while many algorithms which are not structure-based predict both the propensity for a peptide to form either an amorphous or highly structured aggregate, the structure-based methods are largely accurate only for predicting the formation of amyloid-like fibrillar structures. Given these prediction methods, summarized in Table 1.2, it is relatively straightforward to identify APRs in largely unstructured peptides and to rationally design amino-acid substitutions to reduce aggregation propensity. Of course, such changes may also affect activity. At the moment, there are no programs available to predict the effects of incorporating non-natural amino acids nor the effects of chemical modification of a peptide on its aggregation propensity. ### 1.6.2 Peptide Concentration One of the most important factors influencing the physical stability of peptides is peptide concentration. This is long-established through numerous kinetic studies on the formation of amyloid fibrils,\textsuperscript{118–122} amorphous aggregates\textsuperscript{123,124} and adsorption on surfaces.\textsuperscript{125} With respect to the formation of amyloid-like fibrils, extensive kinetic studies have been performed over wide ranges of peptide concentrations and, in the majority of cases, the kinetics have been shown to be consistent with a nucleation – polymerization mechanism, Figure 1.7A.\textsuperscript{126} In this case, the monomeric starting material is converted into oligomers, and ultimately a species that can act as a nucleus for rapid fibril growth. Addition of usually monomers to a nucleus or growing fibrils occurs rapidly to form protofibrils and mature fibrils. The essential features of such systems are that the kinetics show a lag phase, a rapid elongation or growth phase and a plateau. During the lag phase, a number of oligomeric species, including nucleating species, and short amyloid fibrils form until a point is reached at which the growth of fibrils is rapid, Figure 1.9. The formation of fibrils then slows as a plateau is reached which represents either the point where monomers are completely depleted or an equilibrium point at which mature fibrils are in equilibrium with starting monomers and other species. The sigmoidal kinetic traces can be fitted to obtain key kinetic parameters such as lag time, $t_{1/2}$ and the apparent growth rate, Figure 1.9. How these kinetic parameters depend upon peptide concentration has been established for many systems including Aβ\textsuperscript{127}, α-synuclein\textsuperscript{128}, tau\textsuperscript{129}, glucagon-like peptide-1 (GLP-1)\textsuperscript{5} and other peptides. The majority of peptides and conditions show kinetics typical of nucleation – polymerization mechanisms, and in these cases, generally both $t_{1/2}$ and $t_{\text{lag}}$ decrease with increasing peptide concentration. The growth rate has been shown to decrease or increase, or be independent of peptide concentration, depending upon the peptide/conditions and rate-limiting step. Cases where there is an increase in growth rate with peptide concentration point towards association of monomer to the fibril being rate limiting to the growth. In contrast, if the growth rate is independent of peptide concentration this can indicate that some other step, such as a conformational change of the monomeric unit, is rate limiting. The growth rate is also dependent upon secondary nucleation steps, if they exist, such as fragmentation of the fibrils to form small fibrils with a net increase in reactive fibril ends from which growth can occur, or secondary nucleation sites on the surface of a fibril, Figure 1.7A.\textsuperscript{119} The fact that $t_{1/2}$ and $t_{\text{lag}}$ decrease with increasing peptide concentration highlights the issues of physical stability of peptides, which may not be a significant issue at low peptide concentrations, but which can become a serious problem at high concentrations such as those frequently used in therapeutics. ![Figure 1.10. Dependence of GLP-1 aggregation kinetics on peptide concentration at two different pH values.](image) Data adapted and normalised from Zapadka et al.\textsuperscript{5} GLP-1 incubated at six different concentrations (dark blue circles 25 µM, bright blue circles 50 µM, bright green circles 75 µM, dark green circles 100 µM, orange circles 125 µM, red circles 150 µM) and at 37 °C. A) Aggregation kinetics of GLP-1 in Tris buffer at pH 8.2 with decreasing $t_{1/2}$ and $t_{\text{lag}}$ with increasing peptide concentration. Most likely following a simple nucleation – polymerization mechanism with only on-pathway oligomeric intermediate states. B) Aggregation kinetics of GLP-1 in phosphate buffer at pH 7.5 where $t_{1/2}$ and $t_{\text{lag}}$ increase with increasing peptide concentration. In stark contrast to the systems and kinetics described above, there are an increasing number of peptides and conditions under which very different kinetics have been observed. In these cases, increasing concentrations of peptide leads to no change or an increase in $t_{1/2}$ and $t_{\text{lag}}$. This unusual kinetic behaviour has been attributed to the formation of a different form of oligomeric species where the oligomers formed are off-pathway, and either cannot directly be converted into on-pathway oligomers or nucleating species, or the interconversion is extremely slow, or where the off-pathway oligomers even actively suppress the on-pathway aggregation, Figure 1.7C,D & E. One such system is GLP-1, which is a particularly interesting system as, in this case, there is a switch in the kinetic behaviour with pH. At pH > 8.0, GLP-1 follows the more common nucleation – polymerization kinetics with $t_{1/2}$ and $t_{\text{lag}}$ decreasing with increasing peptide concentration, Figures 1.10A and 1.11A & C; however, at pH 7.5, the kinetics reverse such that both lag time and $t_{1/2}$ increase with increasing peptide concentration indicating off-pathway oligomers have formed, Figures 1.10B and 1.11B & D. At an intermediate pH, 8.0, there is little dependence on peptide concentration as there is a delicate balance between on- and off-pathway species. Although off-pathway oligomers have been observed now for a number of peptides and proteins, these systems have not been studied in the detail that peptides and proteins showing simpler nucleation – polymerization kinetics have been and therefore not much is known about the nature of off-pathway oligomers, for example, their size, structure and cellular toxicity. Figure 1.11. Influence of peptide concentration on GLP-1 aggregation parameters $t_{1/2}$ and $t_{\text{lag}}$ at different pH values. Data adapted and normalised from Zapadka et al.\textsuperscript{5} GLP-1 incubated at 25, 50, 75, 100, 125 and 150 µM and at 37 °C. A) Dependence of $t_{1/2}$ on peptide concentration for the aggregation of GLP-1 into amyloid fibrils at pH 8.2 under conditions where the peptide follows a simple nucleation-polymerization mechanism with on-pathway oligomers only. B) Dependence of $t_{1/2}$ on peptide concentration for the aggregation of GLP-1 into amyloid fibrils at pH 7.5. C) Dependence of $t_{\text{lag}}$ on peptide concentration for the aggregation of GLP-1 into amyloid fibrils at pH 8.2 under conditions where the peptide follows a simple nucleation-polymerization mechanism with on-pathway oligomers only. D) Dependence of $t_{\text{lag}}$ on peptide concentration for the aggregation of GLP-1 into amyloid fibrils at pH 7.5 under conditions where on- and off-pathway oligomers are populated. 1.6.3 pH and Net Charge Electrostatic interactions are known to play major roles in the self-association of peptides to form all types of aggregates.\textsuperscript{131–136} Essentially, for systems carrying an overall net charge, unfavourable electrostatic repulsion needs to be overcome in order for self-association/aggregation to take place. Generally, it has been shown for many systems, the higher the net charge the slower the aggregation and the lower the net charge the higher the propensity to aggregate.\textsuperscript{131–136} As such, solution conditions such as pH, ionic strength, nature of cations and anions in solution and the presence of polyelectrolytes can all have a dramatic effect on both the rate and extent of aggregation. One of the best characterized systems in terms of the effects of net charge, ionic strength, and counter ions on aggregation is the 37-residue positively charged peptide IAPP which has no acidic groups.\textsuperscript{137} A comprehensive and rigorous study has shown that there are multiple effects on aggregation depending upon the pH.\textsuperscript{137} At pH 8.0 there is a strong dependence on ionic strength due to Debye screening and increasing ionic strength accelerates aggregation by up to a factor of ten. In this case, specific ion effects were also observed, the nature of the cation being relatively unimportant but the rate depending crucially on the identity of the anion. For example, at pH 8.0 and a total ionic strength of 30 m, the $t_{1/2}$ measured in sulphate and fluoride differed by a factor of four. The effects were observed both on the lag phase and the apparent growth phase. At pH 5.5, where IAPP has a higher overall net charge, the aggregation kinetics were considerably slower than at pH 8.0, but there were similar effects of ionic strength.\textsuperscript{137} For lysozyme and acylphosphatase, studies have established that polyelectrolytes can also have significant effects. In these cases, a number of different polyelectrolytes were found to bind to and stabilize mature fibrils.\textsuperscript{138} Although it is easy to establish some general rules of thumb with regards to the effects of pH, net charge, ionic strength, ions and polyelectrolytes, these rules should be viewed with caution. There are an increasing number of examples where these rules are not followed due to the complexity of aggregation reactions. For example, around the isoelectric point of peptides and proteins, where net charges are essentially zero, then monodisperse and quasi-amorphous aggregates have been observed instead of amyloid-like fibrils.\textsuperscript{69} Thus, aggregation kinetics can be very different from those of amyloid-like fibril formation which is often seen at pH values away from the isoelectric point. In addition, other changes in mechanism have been found at different values of pH and net charge. For example, as already discussed in Section 1.6.2, the aggregation kinetics of GLP-1 into amyloid-like fibrils is highly sensitive to pH.\textsuperscript{5} In this case, the presence of off-pathway species slows the rate of aggregation considerably, particularly at high peptide concentrations. Thus, although the net charge on the protein at pH 7.5 is lower than at pH > 8.0, the rate of aggregation is considerably slower, contrary to what would be expected.\textsuperscript{5} In previous studies, GLP-1 aggregation showed only minor changes with ionic strength. It was shown that 50, 75, 100, 125 and 150 µM GLP-1 in 25 mM citrate buffer at pH 3.5 show no change in aggregation kinetics at 0, 50 or 150 mM NaCl (ionic strength of the samples 18, 68 and 168 mM, respectively).\textsuperscript{139} ### 1.6.4 Chemical Degradation Chemical degradation pathways in biological pharmaceuticals have been reviewed many times.\textsuperscript{140} A number of chemical degradation pathways have been characterized including: deamidation and isomerization,\textsuperscript{141} oxidation,\textsuperscript{140,142} hydrolysis, disulfide bond breakage and formation, succinimidation,\textsuperscript{143} deglycosylation, Maillard reaction, racemization and β-elimination and many of these have been shown to increase the aggregation of biologics.\textsuperscript{143} This is in effect because chemical degradation/modification often changes the physical properties of a peptide/protein such as hydrophobicity, secondary structure (relevant for relatively unstructured peptides) and/or tertiary structure, and the thermodynamic and/or kinetic barriers to unfold (relevant only for highly structured proteins and not discussed further here).\textsuperscript{143} ### 1.6.5 Surfaces and Interfaces Surface-induced aggregation, often called ‘surface adsorption’, is a physical degradation process whereby there is accumulation and adhesion of peptide molecules to a surface. During this process, peptide molecules change their physical state, i.e., they are no longer in solution.\textsuperscript{144–147} There are different mechanisms of surface adsorption of biomolecules and some of the major factors driving adsorption include intra-molecular forces, hydrophobicity,\textsuperscript{148–153} and ionic or electrostatic interactions.\textsuperscript{147,154} Extensive research has been conducted on the surface adsorption of human insulin.\textsuperscript{150,155–159} It is well known that insulin aggregates to form fibres in the presence of hydrophobic surfaces\textsuperscript{149,150,157,158} and especially in a peristaltic pump system.\textsuperscript{159} In this case, the potential formation of aggregation-prone intermediates is very problematic as this may catalyse the aggregation of other molecules in bulk solution. Other studies have established that the aggregation of Aβ\textsubscript{1–40} into fibrils is also influenced by surfaces.\textsuperscript{160–164} Surface adsorption has been studied for other systems such as GLP-1,\textsuperscript{154} GLP-2,\textsuperscript{165} acylated glucagon-like peptide-2,\textsuperscript{165,166} glucagon,\textsuperscript{167} poly(ethylene glycol) (PEG)-glucagon\textsuperscript{168} and α-synuclein.\textsuperscript{151,169} It has been demonstrated that any interface (between solid, liquid or air) will affect the ability of water molecules to form a dynamic hydrogen-bonding network as in bulk water, and therefore air–water and ice–water interfaces are described in the literature as hydrophobic interfaces, because these interfaces do not allow hydrogen bonding.\textsuperscript{146} Adsorption of peptides through their hydrophobic side chains to such hydrophobic interfaces can thus ‘hide’ the hydrophobic surface from the aqueous bulk. Some research shows that, for example, Aβ\textsubscript{1–40}\textsuperscript{161,170} and insulin both aggregate at air–water interfaces.\textsuperscript{171} Many studies have confirmed that the rate of peptide and protein adsorption is normally governed by diffusion and is thus a function of concentration.\textsuperscript{143} The amount of surface-adsorbed species slowly increases over time, usually due to further peptide aggregation at the site.\textsuperscript{160} Of course, there may also be slow structural rearrangements of the adsorbed peptide.\textsuperscript{160} The adsorbed layer often changes its properties over time; this is associated with a change from a reversible to an irreversible process.\textsuperscript{147} The final morphologies of the aggregates formed can be sensitive to the surface chemistry.\textsuperscript{154,156,160} For example, charged surfaces promote protofibril formation, while hydrophobic surfaces promote formation of spherical amorphous clusters.\textsuperscript{160} It is well known that after sufficient time most biomolecules will adsorb to solid surfaces so strongly that they will not (or only very slowly) desorb from the attached surface back into solution.\textsuperscript{172} However, it is possible to some degree to control this process by adding surface active agents which can lead to desorption. The degree of adsorption depends on multiple factors, including concentration, pH, excipients and temperature.\textsuperscript{146,147} \subsection{1.6.6 Excipients} Excipients of many types have been employed to try and reduce aggregation in numerous systems including salts, surfactants, osmolytes, preservatives, chelators and antioxidants, specific ligands, sugars and carbohydrates. Below is a brief description of some of the excipients that have been used and their effects on aggregation. \subsubsection{Buffering agents} As already discussed, pH strongly influences peptide stability and the potential for biomolecular aggregation. The most commonly used buffers in pharmaceutical development are acetate, citrate, histidine, phosphate, Tris and glycine.\textsuperscript{93,143} A complete description of the effects of buffer on peptide aggregation is beyond the scope of this chapter; however, there is an excellent review by Zbacnik and co-workers.\textsuperscript{173} \subsubsection{Salts} Standard physiological salts have been used as tonicity modifiers in peptide formulations.\textsuperscript{93,143} Tonicity measures the effective osmotic pressure gradient of two solutions separated by a semipermeable cell membrane. It differs from osmotic pressure by taking only solutes into account, which cannot cross the membrane.\textsuperscript{174} Salts have complex effects on the physical stability of biomolecules affecting both conformational and colloidal stability. Their effects frequently vary according to the surface charge on the peptide or protein, and the overall effect of a salt on physical stability is a balance of different and multiple mechanisms by which salt interacts with water and biomolecules. Salts can influence physical stability by altering the properties of the peptide–solvent system (Hofmeister effects) and by screening electrostatic interactions (Debye–Hückel effects). Many different studies on the dependence of amyloid formation on ionic strength over the past ten years have shown that ions can influence both the kinetics of aggregation and the structure of fibrils formed. This was, for example, shown for islet amyloid polypeptide (37-residue),\textsuperscript{137} human glucagon (29-residue),\textsuperscript{175} and Aβ peptide.\textsuperscript{134,136,176} Surfactants Surface-active agents are amphiphilic molecules that tend to orient such that the exposure of the hydrophobic part of the molecule to the aqueous solution is minimized. Non-ionic surfactants such as Tween20 and Tween80 are often added to peptide solutions during pharmaceutical development to prevent aggregation or adsorption during purification, filtration, shaking and transportation.\textsuperscript{3,93,177–179} However, the chemical stability of Tween20 and Tween80 in pharmaceutical formulations is very important. Unfortunately, both surfactants are known to undergo oxidation and cleavage at their ethylene oxide subunits, as well as hydrolysis of the fatty acid ester bond.\textsuperscript{180–183} Thus, their use can be complicated as these chemical processes can potentially promote precipitation in some peptide formulations. The use of Tween80 is also far from straightforward as it has been reported that it can have a dual effect on physical stability. For example, Tween80 in the formulation of the protein IL-2 mutein inhibited shaking-induced aggregation, but also had a dramatic effect on the oxidation and aggregation of the protein during storage of the liquid formulation.\textsuperscript{184,185} To counteract this issue, methionine and tryptophan are used in formulation development to prevent Tween from oxidative degradation.\textsuperscript{186} There are two excellent reviews on the interaction between surfactants and peptides, see Otzen\textsuperscript{187} and Khan and co-workers.\textsuperscript{178} Amino acids A number of free amino acids have been used to stabilize proteins and reduce aggregation. Arginine, histidine, lysine, glycine and aspartic acid have been found to reduce aggregation for a number of biomolecules.\textsuperscript{93} Osmolytes Osmolytes such as sucrose, trehalose, sorbitol and glycine are commonly used in formulation development.\textsuperscript{93} Sucrose has been shown to inhibit IL-1ra dimer formation.\textsuperscript{143} However, their use is not always beneficial and it has been reported that some osmolytes accelerate the rate of aggregation, for example, of glucagon.\textsuperscript{188} Antioxidants and chelators Peptide oxidation is a major cause of chemical instability and also sometimes linked to physical stability. Amino acids such as methionine, cysteine, histidine, tyrosine and tryptophan in peptides are susceptible to oxidation under some conditions encountered during pharmaceutical development. Therefore, a number of antioxidants are used as excipients including ascorbic acid.\textsuperscript{93} It has also been reported that sodium thiosulfate, methionine, catalase or platinum, and the chelating agents EDTA and DTPA are also effective in reducing the oxidation of biologics.\textsuperscript{93,189–191} Preservatives Preservatives are used as antimicrobial agents and are very common in liquid formulations.\textsuperscript{93,192} Their role is to prevent bacterial growth during storage.\textsuperscript{93} The most commonly used preservatives in pharmaceutical development are $m$-cresol, phenol and benzyl alcohol. However, it has been reported that preservatives can sometimes cause protein aggregation. For example, benzyl alcohol induces aggregation of recombinant human interleukin-1 receptor,\textsuperscript{193} and $m$-cresol induces aggregation of cytochrome $c$.\textsuperscript{194} Moreover, destabilizing effects of phenol and $m$-cresol were reported for insulin lispro and insulin aspart.\textsuperscript{195} Little is known about their effects on the physical stability of peptides. Polymers and Proteins A number of polymers have been shown to stabilize drug products including polyethylene glycols (PEG). The process of both non-covalent and covalent attachment or amalgamation of PEG polymer chains is described as PEGylation. Other polymers that are used as excipients include dextrans, heparin, gelatins type A, poly-L-glutamic acid, poly-L-lysine, poly-Asp and poly-Gly.\textsuperscript{93,143} For example, it has been reported that different PEGs stabilize the proteins lysozyme and bovine serum albumin.\textsuperscript{143} Human serum albumin is also commonly used as an excipient to inhibit protein/peptide adsorption onto surfaces during product development.\textsuperscript{143} However, adding protein-based excipients adds more complexity to pharmaceutical formulations.\textsuperscript{93} Recently, some excellent reviews on biologics formulation\textsuperscript{196,197} and excipients, including protein–excipients interactions\textsuperscript{93,197,198} have been published. ### 1.6.7 Impurities The results of \textit{in vitro} aggregation studies are often controversial and difficult to reproduce by others. One of the reasons for this problem is the variable amounts of intrinsic impurities in peptide and protein preparations that can affect aggregation rates. For example, the aggregation kinetics of synthetic Aβ has been reported to vary not only batch-to-batch but also with storage and solubilization conditions.\textsuperscript{199} In line with these findings, kinetics studies revealed that the impurities left in the synthetic peptides of glucagon decreased fibrillation rates dramatically compared to that of pharmaceutical-grade glucagon.\textsuperscript{68,175,200} ### 1.6.8 External Factors Numerous other external factors including temperature, pressure, agitation and lyophilization/freeze drying can affect the aggregation of peptides, in many cases, in ways difficult to predict. #### Pressure High hydrostatic pressure (HHP) has been used in a number of studies.\textsuperscript{201} It is now well established that HHP pushes the conformational equilibria towards ensembles of structures that occupy smaller volumes, it acting on cavities that are excluded from solvent that can be found in the hydrophobic cores of natively folded proteins and aggregates including fibrils.\textsuperscript{201} HHP has been used to dissociate multimers in oligomeric structures and, in some cases, dissociate aggregates.\textsuperscript{201,202} The degree to which HHP acts to dissociate aggregated forms of peptides depends upon the structures that are formed and also their inherent thermodynamic stability. For example, if fibrils have cavities within them (cavity defects as they are called) then often low pressures are sufficient to dissociate the aggregated form; for example, early aggregates and protofibrils are generally more readily dissociated by HHP than mature fibrils.\textsuperscript{203} For a peptide from transthyretin that can form fibrils, TTR\textsubscript{105–115}, 220 MPa dissociates aggregates and protofibrils while mature fibrils remain stable up to 1.3 GPa.\textsuperscript{203} For α-synuclein, pathogenic variant fibrils are less resistant to HHP than those of the wild-type protein, hence more toxic oligomers are present.\textsuperscript{201} The dissociation of aggregates and fibrils by HHP is reversible and can be enhanced by the addition of cosolvents such as glycerol, methanol and dimethylsulfoxide.\textsuperscript{203} Temperature Aggregation kinetics frequently show non-Arrhenius behaviour even over short temperature ranges.\textsuperscript{204} A consequence of this is that it is challenging to extrapolate the results of aggregation kinetics commonly measured at higher temperatures to lower temperatures. In addition, cold denaturation of amyloid fibrils has been observed,\textsuperscript{205,206} and low temperatures have been combined with high pressures to dissociate aggregates and fibrils.\textsuperscript{203} Experiments at increased temperatures between 50 and 100 °C with globular proteins has shown heat-induced gelation can occur for some systems.\textsuperscript{207} Agitation Agitation, in the form of a magnetic stirring bar or by use of a shaker table, is routinely used in studies of peptide and protein aggregation. It has been employed in order to accelerate otherwise slow aggregation kinetics and also used to improve the reproducibility of experimental results.\textsuperscript{208} Despite the frequent use of agitation little is known about the shear forces that are produced and the effects on different steps in the aggregation reaction. In addition, as stirring/shaking is often different in different studies, it is challenging to undertake a comparative analysis on systems studied in different research groups.\textsuperscript{209} Lyophilization/freeze drying The stabilization of peptides in a solid form is a very common approach to increase both their chemical and physical stability.\textsuperscript{210} Lyophilization and freeze drying are frequently used to prepare peptides in a solid state. However, for a number of systems studies have shown these processes can result in conformational changes leading to increased aggregation after reconstitution.\textsuperscript{211} These conformational changes can be caused by different effects such as stress induced by formation of ice-water interfaces, freezing induced pH-changes of specific buffers, changes in concentration of solutes and phase separations.\textsuperscript{146,212} Parameters that can be controlled to minimise the effect of freeze-drying are the choice of the buffer,\textsuperscript{213} the duration of the freezing process\textsuperscript{214} or additives, which minimise the interaction of the peptide with the water-ice interface, for example, surfactants.\textsuperscript{146} 1.6.9 Chemical Modifications Chemical modifications of different types are increasingly used to optimize the chemical/physical and biological properties of therapeutic peptides. This includes the incorporation of non-natural amino acids,\textsuperscript{215} engineering of disulfide bonds\textsuperscript{216–220} and lipidation or acylation of the peptide.\textsuperscript{221,222} Lipidation/acylation of peptides is becoming increasingly important in the field of therapeutic peptides.\textsuperscript{223,224} Inspired by endogenous lipidation processes, it has been shown to improve many properties of a peptide, particularly its ability to bind to human serum albumin increasing the half-life of the peptide \textit{in vivo} dramatically and also enhancing its ability to permeate body tissues.\textsuperscript{223,224} Current therapeutics which use this approach include Liraglutide\textsuperscript{225} (a lipidated form of GLP-1), and insulin detemir, a lipidated conjugate of insulin.\textsuperscript{226} Although considerable research has been undertaken on how this class of chemical modification affects the activity of the peptide \textit{in vitro} and \textit{in vivo}, rather little is known about how these modifications affect the physical stability of the system. One recent biophysical study on Liraglutide by Wang and co-workers showed that this lipidated peptide can form oligomers in solution.\textsuperscript{227} In this case, a pH-sensitive equilibrium between octamers and dodecamers was observed in the vicinity of pH 7.\textsuperscript{227} The importance and impact of oligomers, synthetic processes and lyophilisation on the aggregation of Liraglutide was also shown by Bothe \textit{et al.}\textsuperscript{91} Different oligomeric states showed different aggregation kinetics as well as different potencies. They were also able to show that Liraglutide can maintain its oligomerisation state in dried lyophilised powders, acting as a memory effect from its synthetic process and purification. In another case, acylation of the anti-microbial peptide novicidin resulted in an increased tendency to form $\alpha$-helical structure when a C$_{12}$-acyl group was attached. The peptide concentration dependence of this conformational change was attributed to the increased tendency of the peptide to form micelles as shown by NMR.\textsuperscript{228} Although not peptides with any therapeutic potential, the Prive group has published extensively on the properties of lipopeptide detergents (LPDs) which have been developed for structural studies of membrane proteins.\textsuperscript{229} LPDs, which consist of an $\alpha$-helical peptide with alkyl chains at either end of the helix, have been shown to self-assemble into cylindrical micelles that have a densely packed hydrophobic core.\textsuperscript{229} In contrast to the chemical modifications used by the pharmaceutical industry to optimize the properties of therapeutic peptides, where little is known about the effect of the modifications on physical stability, a great deal has been reported for peptides whose aggregation is associated with disease states. In these cases, the modifications investigated are largely post-translational modifications that occur \textit{in vivo} and which, in many cases, are thought to affect the disease state. For example, the effects of many post-translational modifications on the aggregation of A$\beta$ peptides have been studied. An N-terminal truncation and pyroglutamate modification at residue 3 of A$\beta$ peptide has been shown to have a higher propensity for oligomerization and aggregation than full-length A$\beta$.\textsuperscript{230,231} In addition, phosphorylation of A$\beta$ has been shown to increase oligomer formation,\textsuperscript{232,233} while citrullination of A$\beta$ decreases the rate of fibril formation but may increase the amount of toxic oligomers.\textsuperscript{234} Similarly, nitration of tyrosine 10 (Y10) of Aβ has also been shown to increase the amount of oligomers of Aβ in solution.\textsuperscript{235} Backbone modification of Aβ at Gly29 also shows decreased fibril formation and increased oligomer formation.\textsuperscript{236} Similarly, differences in the sequence in the form of mutations influence the aggregation pathway and, therefore, the progression of Alzheimer diseases. Common mutations of Aβ are A21G Flemish, E22K Italian, E22Q Dutch, E22G artic, and D23N Iowa. More details from a Chemist’s perspective about Aβ, its mutations and its role in Alzheimer’s Disease and fibrillation can be found in an excellent review by I. W. Hamley.\textsuperscript{38} The aggregation and fibril formation of α-synuclein is associated with another neurodegenerative disease, Parkinson’s Disease. α-synuclein is a 14 kDa intrinsically disordered protein.\textsuperscript{237} It is known to consist of three main domains: An amphipathic N-terminal involved in membrane binding,\textsuperscript{238} an aggregation-prone hydrophobic central region,\textsuperscript{239} and an acidic unstructured C-terminal region.\textsuperscript{238} Different autosomal dominantly inherited point mutations (Ala53Thr, Ala30Pro, and Glu46Lys) have been described.\textsuperscript{240-242} They all can cause Parkinsonism and, as shown for Glu46Lys, also result in clinical and pathological features characteristic of Lewy body dementia.\textsuperscript{242} There is also a large body of data that establishes that numerous post-translational modifications \textit{in vivo} affect the propensity of the protein to aggregate and thus potentially the disease state. For example, N-acetylation has been shown to decrease fibrillation,\textsuperscript{243,244} post-translational modifications due to oxidative stress such as HNE conjugation, nitration and oxidation have been shown to reduce fibril formation but increase oligomer formation,\textsuperscript{245,246} and oxidation of Met5 also decreases fibril formation but increases the concentration of oligomers.\textsuperscript{247} The intracellular protein tau, associated with Alzheimer’s disease, is also known to undergo a large number of post-translational modifications \textit{in vivo} including phosphorylation, ubiquitination, nitration, truncation, prolyl isomerization, glycosylation and glycation. Many of these are thought to affect neurofibrillar tangle formation, the aggregated form of tau in cells.\textsuperscript{248} A few, but not many, of these post-translational modifications on tau aggregation have been studied in detail. For example, cysteine guanylation of tau has been shown to inhibit fibril formation with a corresponding increase in the population of oligomers.\textsuperscript{248} The effects of a large number of other modifications on the physical stability of specific peptides or proteins have also been reported, including different glycosylations\textsuperscript{249} and fatty acid conjugation.\textsuperscript{250} 1.7 Lipidation of Peptides The focus of this Thesis is the physical stability of GLP-1, GLP-1 with amidated C-terminus and two lipidated forms of GLP-1 with amidated C-termini. The idea of using lipidation to influence the properties of peptides \textit{in vivo} is directly motivated by examples observed in Nature, so called endogenous lipidation. 1.7.1 Endogenous Lipidation Lipidation of polypeptides can be found naturally in mammalian cells, for example, palmitoylation or myristoylation. S-palmitoylation, in particular, is a reversible covalent post-translational attachment of palmitic acid to the amino acid cysteine. It is the most common acylation of polypeptides in eukaryotic cells and can be found in many proteins including G-proteins, ion channels, receptors, cytoskeletal proteins and kinases.\textsuperscript{222,251} The modification affects, amongst other things, the regulation of protein subcellular localisation, stability, trafficking, translocation to lipid rafts, aggregation and the interaction with effectors.\textsuperscript{222} Palmitoylation is reversible and dynamically regulated by enzymes.\textsuperscript{222} Several naturally occurring acylations of different proteins are presented in Table 1.3. The spectrum of lipids is broad, ranging from caprylic acid, through geranylgeranyl groups to cholesterol. The attachment can be catalysed by enzymes, can be non-enzymatic, autocatalytic or the mechanism is still unknown. In the case of GAP-43, a heterogeneity in the naturally attached fatty acid was found with both C\textsubscript{16} or C\textsubscript{18} fatty acids observed, showing that either palmitoyl transferase can attach different fatty acids as substrates or there exist other transferases which are, as yet, unknown.\textsuperscript{222,251} \| Attached lipid \| Modified amino acid \| Enzyme that catalyses the attachment \| Modified protein \| \|---------------------------------\|---------------------------\|-------------------------------------\|------------------\| \| Octanoic acid \| Serine \| Ghrelin O-acyl transferase (GOAT) \| Ghrelin \| \| Myristic acid \| N-terminal Glycine \| N-Myristoyl transferase \| Recoverin \| \| Palmitic acid \| Cysteine \| Palmitoyl transferase \| PSD-95 \| \| Palmitoleic acid \| Serine \| Porcupine \| Wnt3a \| \| Steeric acid \| Cysteine \| Unknown \| GAP-43 \| \| Farnesyl group \| Cysteine \| Farnesyl transferase \| H-Ras \| \| Geranylgeranyl group \| Cysteine \| Geranylgeranyl transferase I \| RhoA \| \| Palmitic acid \| N-terminal Cysteine \| Hedgehog acyl transferase (Hhat) \| Hedgehog \| \| 10-nitro-9,12-cis-octadecadienoic acid \| Cysteine \| Non-enzymatic \| Keap1 \| \| Cholesterol \| Carboxylate group of a carboxy-terminal Glycine \| Autocatalytic \| Hedgehog \| \textbf{Table 1.3. Examples of endogenous protein lipidation.}\textsuperscript{222} \subsection{1.7.2 Influence of Lipidation in Therapeutics} Artificial lipidation can be used in a similar manner to that of Nature to improve the therapeutic effect of polypeptides.\textsuperscript{221} Connected by covalent bonding, a lipid group (cholesterol, palmitic acid or farnesyl) can have a significant influence on the efficiency of a drug.\textsuperscript{221} The lipid group can be attached to an alcohol, amino or acid group on a peptide/peptidomimetic inhibitor \textit{via} amide, ether or carbamate linkages. Through its interaction with the membrane in cells, the lipid group has a strong influence on the location of the drug. In Figure 1.12A, B and C, three different applications of lipidated peptides/proteins are shown. When anchored in a membrane, the lipidated peptide/protein can bind to soluble proteins or membrane-bound proteins. The former can be helpful in reducing the amount of a certain protein and the latter can take advantage of the higher molarity of membrane-binding peptides within the membrane.\textsuperscript{252} Lipidation can also influence cell-permeability as it was shown for palmitoylated peptidyl inhibitors by Tarasova \textit{et al.},\textsuperscript{253} Figure 1.12D. However, the effect of lipidation is not restricted to its influence on the interaction with membranes. It also influences the binding affinity to plasma proteins as human albumin.\textsuperscript{254} A schematic representation of a lipidated peptide that binds to serum albumin is shown in Figure 1.12E. \begin{figure}[h] \centering \includegraphics[width=\textwidth]{image.png} \caption{Different applications of lipidated peptides/proteins in vivo.} \end{figure} A) A lipidated inhibitor binds to a membrane. B) Soluble protein (blue moon-shaped molecule) immobilised by binding to the lipidated therapeutic. C) Membrane bound protein (green molecule) immobilised by binding to the lipidated therapeutic. D) Increased cell permeability due to lipidation. E) Lipidated peptide binds to serum albumin (grey molecule) preventing its degradation. 1.8 Glucagon-Like Peptide 1 (GLP-1) The peptide used in these studies is glucagon-like peptide 1 (GLP-1 (7-37)). It is an incretin hormone and different modified variants are currently already in use as drugs to treat type two diabetes mellitus.\textsuperscript{224,255,256} Previously, Zapadka \textit{et al.} have investigated and reported how the peptide concentration dependence of the aggregation kinetics of GLP-1 (7-37) varies from pH 7.5 to 8.2.\textsuperscript{5} The main finding was that there was a striking change in kinetic behaviour over this very short pH range, which was attributed to the population of off-pathway oligomeric species at pH values close to the pI of GLP-1. Values of $t_{1/2}$ and the lag time were found to decrease with increasing peptide concentration at pH 8.2 as expected for a nucleated-polymerisation mechanism. However, at pH 7.7, little effect of peptide concentration on these kinetic parameters was observed and at pH 7.5, they were found to increase with increasing peptide concentration.\textsuperscript{5} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{proglucagon.png} \caption{Products during the process of proglucagon.} \end{figure} The numbering of GLP-1 (7-37) and (7-36) refers to the major proglucagon fragment MPGF (green font colour). GLP-1 is important in mammalian metabolism and plays a main role in preventing hyperglycemia. GLP-1 was described for the first time in 1986 as a specific fragment of proglucagon. Proglucagon itself was described by K. Lund and J Habener, who were able to deduce the structure of proglucagon of angler fish.\textsuperscript{257} Bell and co-workers published the full human proglucagon structure in 1983.\textsuperscript{258} In addition to glucagon itself, proglucagon contains two glucagon-like structures. Framed by consensus cleavage sites for the prohormone convertase, the fragments for the two glucagon-like structures are proglucagon 72-108 and 126-158.\textsuperscript{258} However, neither directly affected pancreatic insulin secretion, and only become active on truncation. This led to the conclusion that the sequence is processed in the pancreas as well as the gut. Holst and co-workers found that in the pancreas, the major proglucagon fragment (MPGF) is formed and secreted, whereas GLP-1 and GLP-2 were both formed and released in the gut.\textsuperscript{259,260} The highly immunoreactive GLP-1 turned out to be a truncated form of the predicted GLP-1. Instead of proglucagon 72-107, the active sequence starts with residue 78, Figure 1.13.\textsuperscript{261} The naturally occurring and active human GLP-1 peptides are nowadays often referred to as GLP-1 (7-36) amide or GLP-1 (7-37) because of the original assumption that GLP-1 would consist of 37 amino acids. \textit{In vivo}, the C-terminal Gly of GLP-1 7-37 can be amidated, Figure 1.13.\textsuperscript{261,262} \subsection{1.8.1 Biological Activity of GLP-1} GLP-1 is, as mentioned, a highly immunoreactive incretin.\textsuperscript{263} It can influence the blood sugar level in two different ways, first by stimulating glucose-induced insulin release and second by inhibiting glucagon secretion.\textsuperscript{264} Both effects can limit hepatic glucose production, which is closely correlated to fasting hyperglycemia of type 2 diabetes. GLP-1 is also known to be a physiological and potent inhibitor of gastrointestinal secretion, both gastric and pancreatic, as well as motility.\textsuperscript{265} Glucagon-like peptide 1 (GLP-1) is an intestinal hormone signalling nutritional abundance, with an unusual therapeutic potential. An overview over the physiology of GLP-1 secretion and its influence on different organs and tissue is given in Figure 1.14. 1.8.2 GLP-1 as a Therapeutic Agent and its Challenges The biggest challenge in the development of GLP-1 as a therapeutic was that it lasts for extremely short times in blood plasma. The measured half-life of GLP-1 in humans is around 2 min after injection. One major factor of its fast degradation is the enzyme dipeptidyl peptidase 4 (DPP-4). Ahren and co-workers showed in 2004 that the use of DPP-4 inhibitors can prolong the half-life of GLP-1. Another approach to minimise degradation uses the dependence of DPP-4 on the presence of a penultimate Pro or Ala at the N-terminus. It was shown that GLP-1 analogues, with Ser, Val or α-aminobutyric acid substituted at the relevant positions, stayed biologically active and were more resistant against degradation. Unfortunately, the degradation through DPP-4 is only one factor in its degradation processes, and the half-life increased... only slightly up to 4-5 min.\textsuperscript{269} The remaining degradation is caused by extraction of GLP-1 in the kidneys\textsuperscript{270} although degradation by other enzymes may also play a role. It all meant that to overcome the challenge of a short half-life, more complex modifications were needed. ### 1.8.3 Modifications and Analogues of GLP-1 Strategies to overcome the short half-life of GLP-1 were developed using two different approaches. The first one uses a non-human peptide, isolated from the saliva of a reptile, the Gila Monster (\textit{Heloderma suspectum}).\textsuperscript{271} The 39-amino acid long peptide Exendin-4 has 53% homology to human GLP-1. Being a full and potent agonist of the mammalian GLP-1 receptor, Exendin-4 has the advantage that it is not sensitive to DPP-4 as well as the fact that it is barely extracted in the kidneys. Its half-life is about 30 min after injection and this can be increased further by subcutaneous injection, and adequate concentrations can be achieved for up to five hours.\textsuperscript{272} This was sufficient for the development of a therapeutic based on two daily injections. Subsequently, a synthetic replica was produced and marketed under the name Exenatide. It was the first GLP-1 receptor agonist on the market in 2005.\textsuperscript{272} A slightly modified version is Lixisenatide which is designed for once-daily use. Despite its improved usability, it is identical to Exenatide in terms of its pharmacokinetics.\textsuperscript{273} ![Liraglutide Sequence](image) Figure 1.15. Sequence and structure of Liraglutide and its lipidation. Blue highlighted residues are known to be important for binding to the receptor. Residues by Tango predicted to be important for amyloid formation are highlighted by orange circles. The second approach was based on modification of human GLP-1 with lipids. The potency of different lipidated GLP-1 analogues was determined using a functional assay with cloned human GLP-1 receptors which were expressed in baby hamster kidney cells.\textsuperscript{255} In general, lipidation at the carboxyl terminus (C-terminus) with long chain fatty acids did not affect the potency of the GLP-1. From earlier studies it was already known that the amino acids at position 7, 10, 12, 13, 15 in the N-terminal region and 28, 29 in the C-terminal region are important for binding and activation of the receptor as shown in Figure 1.15.\textsuperscript{274} For the lipidation itself, Knudsen \textit{et al.} used the amino acid lysine as the attachment site. The first successful approach, known as Liraglutide, was released in 2009/10. It is a lipidated form of GLP-1. The attachment of palmitic acid via a glutamic acid linker at residue 26 (Lys) results in the ability to bind non-covalently to serum albumin. The latter increases its half-life in blood plasma by reducing the renal filtration as well as by improved protection from DPP-4 degradation. With a half-life of about 12 hours, Liraglutide is suited for a once-daily injection. It has also been approved to treat obesity.\textsuperscript{275} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{glp1_sequences.png} \caption{GLP-1 and GLP-1 receptor agonists used as pharmaceuticals.} \end{figure} The sequence of GLP-1 (7-37) (blue circles) in comparison to different GLP-1 receptor agonists. Red circles highlight modifications of the original sequence of GLP-1 (7-37). To reach the aim of improved usability, several once-weekly use agonists have also been developed. This was achieved by coupling the peptide to larger molecules, for example human albumin or an IgG4 Fc domain, by covalent (Albiglutide\textsuperscript{276–278}, Dulaglutide\textsuperscript{278}) or non-covalent (Semaglutide\textsuperscript{279}) binding, Figure 1.16. The attachment to a larger molecule leads to slower clearance and improved half-life. The future of GLP-1 receptor agonist (GLP-1RA) treatment stays an exciting topic, more so as patents of the first marked products will run out in the early 2020s. ### 1.9 Fatty Acids Used for Lipidation A commonly used lipid for lipidation of GLP-1 are fatty acids, a carboxylic acid with a long aliphatic chain. Typical examples of saturated fatty acids are shown in Table 1.4. In this Thesis, all modifications of GLP-1 are based on palmitic acid. Palmitic acid is the most common saturated fatty acid found in animals, plants and microorganisms and is a significant component of palm oil, as the name suggests. The lipid is attached to the peptide, \textit{via} a glutamic acid spacer to increase the distance to the peptide, Figure 1.15. The lipidation of GLP-1 with palmitic acid and a glutamic spacer was based on detailed studies evaluating the influence of the position as well as different spacers and fatty acids with different lengths. Residues known to be important for binding to the receptor were excluded as lipidation sites.\textsuperscript{274} Different fatty acids, spacers and positions were screened by Knudsen \textit{et al.} (2000).\textsuperscript{255} The combination of good biological activity and physical stability lead ultimately to the choice of glutamic acid and palmitic acid. \| Carbon atoms \| Systematic name \| Common name \| Melting point (°C) \| \|--------------\|-----------------------\|---------------\|--------------------\| \| 12:0 \| n-dodecanoic \| Lauric \| 44 \| \| 14:0 \| n-tetradecanoic \| Myristic \| 54 \| \| 16:0 \| n-hexadecanoic \| Palmitic \| 63 \| \| 18:0 \| n-octadecanoic \| Stearic \| 70 \| \| 20:0 \| n-eicosanoic \| Arachidic \| 77 \| \textbf{Table 1.4.} Examples of saturated fatty acids. 1.10 Aggregation of GLP-1 under Acidic, Neutral and Basic Conditions In previous studies, the aggregation of GLP-1 into amyloid fibrils was investigated in some detail at pH values between pH 7.5-8.2.\textsuperscript{5} Dr Karolina Zapadka extended these studies in previously unpublished work to characterise the physical stability of GLP-1 at low pH (3.0 and 3.5). Standard ThT assays were used to measure the aggregation kinetics to obtain the lag time, $t_{1/2}$ and apparent growth rate as a function of peptide concentration, Figures 1.17 - 1.21. At both pH 3.0 and 3.5, GLP-1 aggregates into $\beta$-sheet rich fibrils that bind ThT and which show sigmoidal kinetic traces typical of a nucleated polymerisation reaction. The timescales of aggregation at pH 3.0 and 3.5 are similar to those at pH 7.5-8.2, lag times varying from 5-50 hours depending upon peptide concentration, Figure 1.18A & B. Figure 1.18C & D show the results at pH 7.5 and 8.2, which are consistent with previously reported aggregation kinetics of GLP-1. The dependence of lag time and $t_{1/2}$ on the initial concentration of monomeric peptide is shown in Figures 1.18, 1.19 and 1.20, and this provides important information on the mechanism of fibril formation. At pH 3.0, $t_{1/2}$ and lag time decrease with increasing peptide concentration, the slope of the plot of log peptide concentration vs log lag time, $\gamma$, is $-1.0 \pm 0.2$, Figure 1.20A. This suggests that, at this pH, only on-pathway oligomers play a major role and that the filamentous growth reactions are limited by primary and surface-catalysed secondary nucleation processes rather than by simple breakage.\textsuperscript{280} These results are similar to those obtained at pH 8.2, Figure 1.17D.\textsuperscript{5} In contrast, at pH 3.5, both the lag time and $t_{1/2}$ increase with increasing peptide concentration similar to the results at pH 7.5, Figures 1.17B, 1.18B and 1.19B. These results suggest, under these conditions, off-pathway oligomeric species are present and significantly affect the aggregation kinetics. Additionally, at pH 3.5 and 7.5, there is an increase in ThT fluorescence in the initial baseline of the aggregation assays, Figure 1.17B & C. This indicates either that small fibrils are being formed or that other species such as on- or off-pathway oligomers capable of binding and increasing the ThT signal are populated. However, the formation of early fibrils is unlikely as secondary nucleation mechanisms should result in an immediate rapid growth phase instead of the observed approx. relatively slow linear increase seen during the lag phase. Therefore, it is probable that the off-pathway oligomers have some capacity to bind to ThT and increase its fluorescence. Figure 1.17. Aggregation kinetics of GLP-1 as a function of peptide concentration at different pHs. Data collected by Dr Karolina Zapadka. GLP-1 aggregation kinetics in 25 mM citrate buffer at pH 3.0 (A), 25 mM citrate buffer at pH 3.5 (B), 25 mM phosphate buffer at pH 7.5 (C), and 25 mM Tris buffer at pH 8.2 (D). Panels A-D show typical traces for the fibrillation of GLP-1 followed by ThT fluorescence at different peptide concentrations: 25 µM (yellow), 50 µM (red), 75 µM (green), 100 µM (blue), 125 µM (purple), and 150 µM (pink). Each peptide concentration was performed in triplicate. Figure 1.18. Dependence of the GLP-1 aggregation lag time on the peptide concentration. Data collected by Dr Karolina Zapadka. Dependence of the lag time on the concentration of GLP-1 in 25 mM citrate buffer at pH 3.0 (A), 25 mM citrate buffer at pH 3.5 (B), 25 mM phosphate buffer at pH 7.5 (C), and 25 mM Tris buffer at pH 8.2 (D). All samples incubated at 37 °C. The error bars shown in A-D correspond to the standard deviations of the kinetic parameters determined from one experiment where each peptide concentration was run in triplicate. See Table 1.5 for further details. Figure 1.19. Dependence of the GLP-1 aggregation half-time on the peptide concentration. Data collected by Dr Karolina Zapadka. Dependence of the half-time on the concentration of GLP-1 in 25 mM citrate buffer at pH 3.0 (A), 25 mM citrate buffer at pH 3.5 (B), 25 mM phosphate buffer at pH 7.5 (C), and 25 mM Tris buffer at pH 8.2 (D). All samples incubated at 37 °C. The error bars shown in A-D correspond to the standard deviations of the kinetic parameters determined from one experiment where each peptide concentration was run in triplicate. See Table 1.5 for further details. Figure 1.20. Dependence of the GLP-1 aggregation half-time on the peptide concentration on a log-log scale. Data collected by Dr Karolina Zapadka. Dependence of the half-time on the concentration of GLP-1 in log-log scale in 25 mM citrate buffer at pH 3.0 (A), 25 mM citrate buffer at pH 3.5 (B), 25 mM phosphate buffer at pH 7.5 (C), and 25 mM Tris buffer at pH 8.2 (D). All samples incubated at 37 °C. The error bars shown in A-D correspond to the standard deviations of the kinetic parameters determined from one experiment where each peptide concentration was run in triplicate. See Table 1.5 for further details. Figure 1.21. Apparent growth rate of GLP-1 as a function of peptide concentration at different pHs. Dependence of the apparent growth rate on the concentration of GLP-1 in 25 mM citrate buffer at pH 3.0 (A), 25 mM citrate buffer at pH 3.5 (B), 25 mM phosphate buffer at pH 7.5 (C), and 25 mM Tris buffer at pH 8.2 (D). All samples incubated at 37 °C. The error bars shown in A-D correspond to the standard deviations of the kinetic parameters determined from one experiment where each peptide concentration was run in triplicate. See Table 1.5 for further details. \| Peptide concentration (µM) \| Half-time (h) \| SD \| Lag time (h) \| SD \| Apparent growth rate (h⁻¹) \| SD \| \|---------------------------\|---------------\|-----\|--------------\|-----\|----------------------------\|-----\| \| pH 3.0 \| \| \| \| \| \| \| \| 150 \| 12.7 \| 0.2 \| 5.3 \| 0.3 \| 0.27 \| 0.02\| \| 125 \| 12.2 \| 0.2 \| 5.6 \| 0.3 \| 0.30 \| 0.01\| \| 100 \| 15.0 \| 0.4 \| 9.4 \| 0.8 \| 0.36 \| 0.03\| \| 75 \| 17.6 \| 0.8 \| 12.4 \| 1.4 \| 0.39 \| 0.05\| \| 50 \| 28.4 \| 0.8 \| 23.3 \| 0.5 \| 0.41 \| 0.11\| \| 25 \| 29.0 \| 1.9 \| 25.9 \| 2.6 \| 0.67 \| 0.14\| \| pH 3.5 \| \| \| \| \| \| \| \| 150 \| 37.6 \| 2.1 \| 31.0 \| 2.7 \| 0.31 \| 0.03\| \| 125 \| 33.5 \| 0.6 \| 27.0 \| 0.9 \| 0.31 \| 0.06\| \| 100 \| 17.5 \| 0.5 \| 10.9 \| 1.3 \| 0.31 \| 0.05\| \| 75 \| 12.0 \| 0.9 \| 6.5 \| 0.1 \| 0.37 \| 0.05\| \| 50 \| 9.0 \| 0.2 \| 5.0 \| 0.8 \| 0.53 \| 0.10\| \| 25 \| 11.9 \| 1.0 \| 9.0 \| 0.5 \| 0.72 \| 0.15\| \| pH 7.5 \| \| \| \| \| \| \| \| 150 \| 30.4 \| 0.3 \| 22.7 \| 0.4 \| 0.26 \| 0.02\| \| 125 \| 25.1 \| 3.6 \| 16.6 \| 3.6 \| 0.24 \| 0.00\| \| 100 \| 19.7 \| 1.4 \| 12.5 \| 0.2 \| 0.28 \| 0.06\| \| 75 \| 18.9 \| 3.1 \| 11.1 \| 3.2 \| 0.26 \| 0.02\| \| 50 \| 14.2 \| 2.3 \| 6.1 \| 2.5 \| 0.25 \| 0.03\| \| 25 \| 15.5 \| 3.3 \| 5.6 \| 1.8 \| 0.21 \| 0.06\| \| pH 8.2 \| \| \| \| \| \| \| \| 150 \| 31.5 \| 2.5 \| 14.6 \| 0.3 \| 0.12 \| 0.02\| \| 125 \| 30.8 \| 1.3 \| 12.9 \| 0.6 \| 0.11 \| 0.01\| \| 100 \| 32.0 \| 0.7 \| 13.0 \| 0.8 \| 0.11 \| 0.01\| \| 75 \| 32.5 \| 1.2 \| 15.3 \| 0.3 \| 0.17 \| 0.01\| \| 50 \| 52.3 \| 2.3 \| 31.9 \| 1.6 \| 0.10 \| 0.00\| \| 25 \| / \| / \| / \| / \| / \| / \| Table 1.5. Summary of the averages and standard deviations of the kinetic parameters obtained from multiple repeats of the ThT assays for GLP-1 at different pH values. Data collected by Dr Karolina Zapadka. 1.11 Changes in Secondary Structure During Aggregation To study the change of the secondary structure during the aggregation process, time-course measurements of GLP-1 were conducted in the Jackson Group. The measurements of far-UV CD spectra at different time points from 0 up to 144 h show for all four pH conditions (pH 3.0, 3.5, 7.5 and 8.2) an overall change from a structure containing α-helical, turn, disordered and β-sheet structure to a structure containing mainly β-sheet structure. In citrate buffer at pH 3.0, the most dominant change of the secondary structure can be observed between 4-6 h, and therefore approx. the same time as the lag time of 5 h, Figure 1.22A & Table 1.5. The time-course measurements at pH 3.5 show an earlier change in the secondary structure. Here, the main change is observed after less than half of the measured lag time of 31 h, Figure 1.22B and Table 1.5. Under neutral pH conditions (pH 7.5), the data shows again a close relation between the lag time and the significant change of the secondary structure, which both were determined to be around 23 h, Figure 1.22C & Table 1.5. However, a more gradual transformation in secondary structure can be seen at pH 8.2, with some significant changes happening between 7 and 8 h and a complete transformation of the secondary structure already after 9 h, Figure 1.22D. Between 9 and 144 h, the secondary structure stays constant. The change in secondary structure occurs earlier in comparison to the measured lag time of the ThT assay, which was measured to be 15 h, Table 1.5. Figure 1.22. Changes in secondary structure in GLP-1 during aggregation shown with far-UV CD. Measurements conducted by Dr Karolina Zapadka. Far-UV CD spectra of 150 µM GLP-1 incubated at 37 °C measured at different time points. The far-UV CD measurements were conducted at 25 °C. The x-axis and y-axis show the wavelength (nm) and the molar ellipticity ($10^3 \cdot \text{deg} \cdot \text{cm}^2 \cdot \text{dmol}^{-1}$), respectively. The different colours represent different time points in hours. The measured lag times taken from previous ThT assays, Figure 1.17, are shown in black. Time points showing the first major changes of the secondary structure are shaded in blue. A) 25 mM phosphate, pH 3.0. B) 25 mM phosphate, pH 3.5. C) 25 mM phosphate, pH 7.5. D) 25 mM Tris, pH 8.2. 1.12 Thioflavin T as a Fluorescent Marker of Amyloid Fibrils The study of amyloid fibrils was, from the beginning, influenced and inspired by the usage of dyes. The most widely used amyloid dye is the fluorescent dye thioflavin T (ThT). In 1959, its potential was demonstrated by Vassar and Culling.\textsuperscript{281} Three decades later, the first detailed characterisation of the ThT fluorescence spectra and binding properties was undertaken by Naiki \textit{et al.}\textsuperscript{282} Their work on the fluorometric determination of amyloid fibrils \textit{in vitro} showed that ThT in the absence of amyloid fibrils has only a faint fluorescence at the excitation and emission maxima of 350 and 438 nm, respectively. In comparison, the ThT fluorescence in the presence of amyloid fibrils was significantly increased at the shifted excitation and emission maxima of 450 and 482 nm, respectively. Understanding the specificity of ThT binding to amyloid fibrils has been studied extensively using a broad range of biophysical and biochemical analyses, protein/peptide engineering, fluorescence microscopy, and computational simulations.\textsuperscript{283} It has been suggested that ThT behaves in solution as a “molecular rotor” because of the single shared carbon-carbon bond between the benzylamine and benzathiole ring, Figure 1.23A.\textsuperscript{284,285} If the rotation is possible, it enables the molecule to undergo a charge transfer which leads to the population of a non-fluorescent twisted intramolecular charge transfer state (TICT state)\textsuperscript{284}. This quenching leads to a low fluorescence emission for non-immobilised ThT molecules. The binding of the ThT molecule to a fibril and selective immobilisation of a subset of the ThT molecules suppresses the population of the TICT state, which leads to an increase in the ThT fluorescence in samples with amyloid fibrils compared to samples without. The characteristics of increased fluorescence caused by the binding of ThT to amyloid fibrils has brought the mechanism of its binding into the focus of a wide range of studies. The typical structure showing the fibril-ThT interaction has been described by a “channel” model.\textsuperscript{286–288} Channel-like motifs are formed by amino-acid side chains forming cross-strand ladders. In these channels, the ThT molecules bind aligned parallel to the long axis of the fibre, Figure 1.23B.\textsuperscript{289} It was shown that ThT molecules prefer certain types of channels, especially channels formed by hydrophobic or aromatic residues.\textsuperscript{290} In contrast, highly charged fibrils often show a poor affinity for ThT.\textsuperscript{291} Furthermore, the minimum length of a channel to bind a ThT molecule was determined experimentally and corresponds to the height of five or more $\beta$-strands,\textsuperscript{292} whereas computational simulations suggested that, in the absence of repulsive forces, already a groove formed by the side chains of four $\beta$-strands is sufficient to bind ThT.\textsuperscript{293} It is assumed that the groove's minimum length is why ThT typically does not bind to $\beta$-sheet rich globular proteins as they usually contain highly twisted $\beta$-sheet motifs consisting of four or less $\beta$-strands.\textsuperscript{289,294,295} However, from several significant studies on the specificity of ThT, it is known that there are some exceptions where ThT has been shown to bind to globular proteins. For example, it was shown that ThT binds to acetylcholinesterase.\textsuperscript{296} In contrast to fibrils, here, the binding site is primarily formed of $\alpha$-helices. The interaction of ThT and the hydrophobic binding pockets is again mediated by aromatic side chains, including $\pi$-stacking of Tyr and Trp.\textsuperscript{296} Similarly, ThT has been shown to bind to a hydrophobic pocket of human serum albumin with an observed binding constant comparable to that of other drug-like molecules.\textsuperscript{297} Despite some binding to globular proteins, ThT binds relatively specifically to amyloid fibrils and shows low or no binding affinity to soluble proteins in folded, unfolded or partially folded states.\textsuperscript{298} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{tht_fibril_binding.png} \caption{\textbf{Figure 1.23. Structure of ThT and its binding model to fibril-like $\beta$-sheets.}} A) Structure of ThT consisting out of two planar segments whose mutual rotation defines its chirality and influences its fluorescent properties. B) The binding of ThT molecules is proposed to occur along surface side-chain grooves. These so called “channels” run parallel to the long axis of the $\beta$-sheet. Figure adapted from M. Biancalana & S. Koide, 2010.\textsuperscript{283}} \end{figure} However, the low or sometimes complete lack of binding to non-fibrillar aggregates does not mean that these species cannot influence the ThT fluorescence indirectly. For example, it cannot be excluded that these aggregates reduce the overall fibril yield or affect the kinetics of fibril formation. In some cases, oligomers have been shown to have only a poor interaction with ThT resulting in a low ThT fluorescence.\textsuperscript{299} During ThT assays, it is always important to check if the ThT fluorescence is linearly related to the amount of fibrils in solution, i.e., peptide concentration. Another factor influencing ThT fluorescence is pH. Caution should be exercised when comparing measurements under acidic conditions and neutral pH values, as the protonation of the tertiary amine leads to a lower ThT fluorescence absorption and emission below pH 3.0.\textsuperscript{300} Another critical factor influenced by pH is hydroxylation. Most notable under elevated temperatures and basic conditions, it can also play a role at neutral pH and 37 °C. For example, at pH 7.3 and 15 h incubation at 50 °C, a ~25% decrease in the ThT absorbance has been attributed to hydroxylation.\textsuperscript{301} It has also been suggested that ThT binds to at least two different binding sites in insulin amyloid fibrils which each have a different influence on its fluorescence,\textsuperscript{302} which is a good reminder that a change in ThT fluorescence intensity in a fibrillar sample does not automatically mean a change in the total fibril concentration. Instead, it could simply be caused by an equilibration process between two ThT binding sites on a given fibril surface. ThT assays can be conducted \textit{in-situ} or \textit{ex-situ} as fixed-timepoint assays. The latter has the advantage that no ThT is present during the actual aggregation process as it can theoretically influence the process. However, during fixed-timepoint assays, the extraction of samples, volume change, and agitation caused by sample extraction can also influence the aggregation process. A recent study showed that ThT present during the aggregation process alters the fibrillation kinetics of α-synuclein in comparison to an \textit{ex-situ} assay.\textsuperscript{303} However, the main differences were only seen for the fluorescence intensity. The primary kinetic parameters lag time and $t_{1/2}$ were not significantly affected. One possible explanation for the difference in the fluorescence intensity is the higher accessibility of binding sites during an \textit{in-situ} assay.\textsuperscript{304} Overall, in-situ ThT assays are a powerful tool to follow the kinetics of fibril formation. They enable detailed kinetic analyses of the aggregation process, however, the linear dependence of the ThT fluorescence on fibril concentration should be checked and additional factors such as the effect of ThT binding to excipients and globular proteins (if included in the assay) must be excluded. It is also always recommended to support conclusions from ThT assay data with orthogonal methods such as AFM, SEM, TEM, far-UV CD or FT-IR. ### 1.13 Measurement of the Secondary Structure of Peptides Using Circular Dichroism Biomolecules often possess a molecular asymmetry which means that their mirror image is not identical. Such behaviour is known as chirality, and these molecules are said to be optically active. Circular dichroism exploits the fact that chiral molecules have a non-zero difference in response to left- and right-circular polarized light.$^{305}$ In the case of polypeptides, the main chromophores interacting in the far-UV region are the peptide bonds.$^{306}$ If the latter is part of a regular folded structure as in an $\alpha$-helix or $\beta$-sheet, it is influenced by the conformationally asymmetric structure. To measure the circular dichroism, an unpolarised light source gets polarised and subsequently circular polarised with a quarter-wave modulator.$^{305,307}$ Depending on the modulation the circularly polarised radiation can be comprised of one of two different circularly polarised vectors.$^{305}$ Both vectors, the right-handed and left-handed, are of equal intensity. Samples with chromophores in optically symmetrical structures will typically absorb the two components in equal measures. In contrast, chromophores in an asymmetric environment will absorb the two different vectors to a different extent. The difference between the absorption of the left-handed and right-handed polarised light provides insights into the conformation of the measured samples. The method of far-UV CD profits from requiring only a low sample volume needed to gain structural data and the fact that the samples can be measured in solution. Figure 1.24 shows different components of typical far-UV spectra of a polypeptide adopting different conformations. Excellent reviews or book articles of the CD technique and its applications to the study of proteins and other biomolecules have been written by L. A. Nafie (1995), Kelly et al. (2005) and S. R Martin & M. J. Schilstra (2008). A standard method to analyse far-UV CD spectra is to compare the measured dataset with spectra of proteins whose crystal structures have been determined. This is accomplished with the software package CDPro and the web-based Dichroweb, there are two prominent compilations of algorithms and reference sets. Figure 1.24. Far-UV CD spectra associated with different types of secondary structure of proteins. Spectra shown of $\alpha$-helix (solid line), anti-parallel $\beta$-sheet (long dashed line), type I $\beta$-turn (dotted line), extended $3_1$-helix or poly (Pro) II helix (cross dashed line), irregular structure (short dashed line). Figure adapted from Kelly et al., 2005. 1.14 Fourier-transform Infrared Spectroscopy of Polypeptides A different spectroscopic approach to gain information about the secondary structure of polypeptides is Fourier-transform infrared (FT-IR) spectroscopy. While CD uses circularly polarised light, FT-IR measures the wavelength and intensity of a sample's absorption of infrared radiation.\textsuperscript{310} The technique is thereby based on interferometry and Fourier transformation.\textsuperscript{311} The interferometer in the instrument has one fixed and one movable mirror. A beam splitter directs 50% of the light onto the static and 50% onto the movable mirror. If the right path length difference is introduced, it results in interference as soon as the two beams are recombined. After the beam interacts with the sample, the measured light intensity can be set in relation to the position of the movable mirror.\textsuperscript{311} It results in an interferogram, which is the Fourier transform of the spectrum. Therefore, a second Fourier transform is performed by a computer to convert the data back to a spectrum.\textsuperscript{312} In contrast to other spectrophotometric approaches, for example, far-UV CD, FT-IR is not based on a monochromatic scan of the sample. FT-IR benefits from its polychromatic approach in terms of speed and sensitivity.\textsuperscript{311} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{ftir_spectra.png} \caption{FT-IR spectra of poly-L-lysine as a function of pH and temperature.} The homopolymer forms a $\beta$-sheet at pH 12 and 46 °C, $\alpha$-helix at pH 12 and 20 °C and random coil at pH 4 and 20 °C. Figure adapted from L. P. DeFlores \textit{et al.}, 2009.\textsuperscript{313} \end{figure} In the infrared spectroscopy of polypeptides, the peptide bonds absorb mainly in nine different characteristic infrared active vibration modes. The two most prominent vibration modes for analysing the secondary structure of polypeptides are the amide I and amide II modes.\textsuperscript{312} At a frequency of approx. 1690-1600 cm\textsuperscript{-1}, the amide I mode absorbs mainly due to the C=O stretching vibrations. Additionally, minor contributions come from out-of-phase C-N stretching and the N-H inplane-bend. The amide II mode, in comparison, absorbs at a frequency of approx. 1575-1480 cm\textsuperscript{-1}. Its absorption is mainly caused by N-H plane-bend and the C-N stretching vibration.\textsuperscript{312} The modes shift depending on the structure of the sample. From previous studies, it is known that the amide I mode is composed from different absorption bands. A strong absorption band at 1610-1640 cm\textsuperscript{-1} and a weaker band at 1680-1690 cm\textsuperscript{-1} are typical for β-sheets. The absorption band for α-helical and random coil structure have been determined to be at 1640-1650 and 1650-1660 cm\textsuperscript{-1}, respectively. In Figure 1.25, typical FT-IR spectra of poly-L-lysine in the three different conformations, α-helical, β-sheet and random coil are shown. ### 1.15 Principal Component Analysis of Spectroscopic Data The principal component analysis (PCA) is a computational method to analyse a set of multi-dimensional data,\textsuperscript{314} for example, the time-dependent change of absorbance spectra. The analysis aims to extract the important information from data by finding inter-correlated quantitative dependent variables. The latter are orthogonal variables and called principal components (PCs).\textsuperscript{315} In the case of a matrix of time-dependent absorption spectra, a PCA can give an overview of the variables which contribute the most to the different characteristics of the spectra at different time points. A mathematical approach to deconvolute a data table in which each row describes an absorbance spectrum is singular value decomposition. After such a deconvolution, the data can be transformed back to the original data space,\textsuperscript{316} such as the absorbance spectra space. It can help to understand the dominant spectra composing the measured data. For example, the contribution of the first and most dominant principal component to each spectrum can be calculated using only the eigenvalue of the first principal component while all other eigenvalues are set to zero. The resulting matrix, $M_{PC1}$ contains then, for each time point, the contribution of the first principal component, Figure 1.26. ![Figure 1.26. Singular value decomposition and back transformation of the first principal component to the original data space.](image) Decomposition of a real matrix $M$ into a real unitary matrix $U$, a diagonal matrix $\Sigma$ with the eigenvalues $\sigma_x$ of the data set and a unitary matrix $V$. Multiplication of the two unitary with a single eigenvalue, for example $\sigma_1$, leads to the contribution of the first principal component for each row summarised in matrix $M_{PC1}$ (Sigma 1). ### 1.16 Measurement of the pI of Polypeptides The isoelectric point (pI) is the pH value at which the molecule carries no net charge. Therefore, the pI value is of particular interest in the context of peptide aggregation and was determined for all investigated peptides and lipidated peptides using imaged capillary isoelectric focusing (iCIEF). iCIEF is an enhanced version of capillary isoelectric focusing (CIEF). Both share the approach to focus polypeptides isoelectrically in a capillary coated with fused silica (FS). The coating is needed to suppress the electroendosomatic flow (EOF). This is essential because EOF disturbs the focusing process.\textsuperscript{319} At the beginning of the measurement, the capillary gets filled with a mixture containing carrier ampholytes covering the anticipated pH range (e.g., 3-8), the sample(s) and pI markers.\textsuperscript{320} Sometimes also blocking agents are included, which have a lower or higher pI compared to the samples measured. Typical examples are iminodiacetic acid (pI 2.2) and arginine (pI 10.7).\textsuperscript{319} When the pI and the amount of the blocker agents are chosen correctly, this can help focus the mixture correctly. The pH of the starting mixture is determined by the concentration and dissociation state of all substances present. The capillary is connected to an inlet and outlet vial filled with a low pH solution (H\textsubscript{3}PO\textsubscript{4}) and a high pH solution (NaOH). A positive voltage can be applied to the inlet, which becomes the anode. The outlet is grounded and acts, therefore, as the cathode.\textsuperscript{320} As soon as the voltage is applied, highly mobile hydrogen ions move towards the cathode, and hydroxyl ions move in the opposite direction. With time a pH gradient is created, and amphoteric molecules protonate/deprotonate and focus in a small zone in which their net charge is minimised.\textsuperscript{319} To determine if the molecules are in focus, CIEF relies on the current as an indirect measurement. iCIEF profits in this case from the fact that focusing is directly detected. Another advantage of iCIEF compared to CIEF is that it needs no mobilisation step, which increases the accuracy of the measurement.\textsuperscript{317,319} Figure 1.27. Schematic of capillary isoelectric focusing (CIEF) and imaged CIEF (iCIEF). A) Depiction of the capillary composition before and after the focussing process during a CIEF run. Before the voltage is applied, the mixture of carrier ampholytes, blocking agents, the protein or peptide sample to be analysed, and pI markers are all homogeneously distributed over the whole capillary. The applied voltage leads with time to a pH gradient within the capillary. In a classical CIEF experiment, the neutralised and focussed molecules must be subsequently mobilised and moved past the point of detection, a spectrophotometric detector (UV-DAD) at 280 nm. Figure adapted from T. Kristl, H. Stutz, C. Wenz & G. Rozing, 2014.\textsuperscript{320} B) Schematic of iCIEF. Compared to CIEF, it enables the measurement of the UV signal over the whole range of the capillary. It leads to an improved focus because the focusing process can be observed not only based on the current drop to a minimum as for CIEF but in real-time during the whole process. The precision also gains from the fact that no mobilisation step is needed to move the sample past a POD. Figure adapted from G. Rozing, 2019 (Picture courtesy of H. Stutz, Salzburg University).\textsuperscript{319} 1.17 Aims of the Thesis The aim of the work presented in this Thesis was to look into the aggregation pathways of GLP-1 and chemically modified forms of GLP-1 and to characterise their physical stability. GLP-1 and its analogues were selected due to their importance as therapeutics as well as their size, chemical structure and propensity to form fibrils. The focus was on the influence of amidation of the C-terminus as well as two lipidated versions which were investigated to understand how lipidation influences the aggregation behaviour of the peptide. Objective 1 Based on the work of Dr Karolina Zapadka, the first objective of the research was to study the aggregation of GLP-1 at different time points during aggregation in order to understand the size, structure and nature of species in solution throughout the aggregation reaction. Motivated by the pH-dependent concentration dependence of the aggregation kinetics of GLP-1, four different pH values were selected which showed different behaviour. Many different biophysical techniques were used in order to obtain a better understanding of the aggregation mechanisms. Objective 2 Another focus of the Thesis was on the determination of the influence of C-terminal amidation (Am-GLP-1) on the physical stability and aggregation kinetics of GLP-1. The effect of pH and peptide concentration was studied and compared in detail to the results obtained for GLP-1. The amidation of the C-terminus changes the net charge of the peptide enabling the role of net charge in determining the solubility as well as the aggregation propensity to be established. Objective 3 Two lipidated forms of Am-GLP-1 were studied to determine the influence of lipidation on the aggregation kinetics. Similar to Am-GLP-1, the impact of pH and peptide concentration on the aggregation kinetics/amyloid fibril formation was studied. The studies also provided information on how the lipidation influences the secondary structure of the peptide by a comparison of results with those obtained for GLP-1 and Am-GLP-1. Objective 4 Analysing the collected data using different fitting approaches provided a better understanding of the underlying mechanisms of the aggregation process. ThT assay data were subjected to a sigmoidal fit and also fit to an analytical solution of a Master equation describing the formation and growth of fibrils by nucleation, elongation and fragmentation. 2 METHODS AND MATERIALS 2.1 Peptides The 31-residue GLP-1 (7-37) and Am-GLP-1 (7-37) (HAEGTFTSDVSSYLEGQAAKEFIAWLVKGRG-OH and HAEGTFTSDVSSYLEGQAAKEFIAWLVKGRG-NH$_2$) were purchased from Bachem (Purity: 98.5% and 96.7%). Both peptides have a molecular weight of approximately 3.36 kDa. IPP4 (HAEGTFTSDVSSYLEGK($\gamma$-E-palmitoyl)-AAREFIAWLVGRGRG-OH was purchased from Peptides International (Purity: 96.3%) and IPP5 HAEGTFTSDVSSYLEGQAAK ($\gamma$-E-palmitoyl) EFIAWLVGRGRG-NH$_2$) was purchased from Bachem (Purity: >95.0%). All peptides were used without further purification. GLP-1 HAEGTFTSDVSSYLEGQAAKEFIAWLVKGRG Am-GLP-1 HAEGTFTSDVSSYLEGQAAKEFIAWLVKGRG-NH$_2$ IPP4 HAEGTFTSDVSSYLEGKAARREFIAWLVGRGRG-NH$_2$ IPP5 HAEGTFTSDVSSYLEGQAAKEFIAWLVGRGRG-NH$_2$ $\gamma$-E-palmitoyl Figure 2.1. Amino-acid sequence of GLP-1 and three GLP-1 analogues. The lipidated peptides are both based on the C-terminally amidated form of GLP-1 (Am-GLP-1) with additional modifications indicated by the red rings. 2.2 Buffers and other Reagents The buffers were purchased from Sigma-Aldrich (citric acid anhydrous and sodium citrate dihydrate) and Baker (sodium phosphate dibasic 7-hydrate and dibasic sodium phosphate monohydrate/Tris base and Tris HCl). All buffers were prepared by weighing of the appropriate acidic and basic forms of the buffers, which were subsequently dissolved in deionised water. The final buffer concentration was 25 mM and citrate buffer was used at pH 3.0, 3.5, 4.0, 4.5, 5.0, 5.5 and 6.0, phosphate buffer at pH 6.5, 7.0 and 7.5 and Tris buffer at pH 8.0, 8.5 and 9.0. The $pK_a$ of Tris buffer is temperature-dependent which means if the temperature is increased from 25 to 37 °C, the pH of the buffer changes from 8.0, 8.5 and 9.0 to 7.7, 8.2 and 8.7, respectively. In this Thesis, the samples in Tris buffer are referred to as samples at pH 7.7, 8.2 and 8.7 if not stated otherwise, as these are the pH values under aggregation conditions. No additional salt was added. The ionic strengths due to the buffer itself varied with pH and were in the range from 2 to 121 mM, Figure 2.2. The decision to conduct all measurements at the lowest possible ionic strength at each pH was based on a brief study by Dr Karolina Zapadka, which showed no significant differences in aggregation rate over this ionic strength range, Section 1.6.3. ![Figure 2.2. Ionic strength of citrate, phosphate and Tris buffers](image) The calculated ionic strength of 25 mM citrate, phosphate and Tris buffer prepared at 25 °C and used at 37 °C. The calculation was performed with the BioMol buffer calculator.$^{321}$ After preparation, the buffers were filtered through a 0.2 µm PES filter unit (Thermo Scientific™ Nalgene™ Rapid Flow™ 90 mm) and the pH checked using a multiparameter pH meter (SevenExcellence, Multiparameter, Mettler Toledo, pH electrode: InLab® Micro-Pro-ISM). Buffers were stored at -20 °C. The sources of all other reagents are given in the relevant Methods sections. ### 2.3 UV-visible Absorption Spectroscopy – NanoDrop A NanoDrop 2000 spectrophotometer (Thermo Scientific) with a 1 mm pathlength was used to determine the concentration of GLP-1 or ThT in solution. After recording an appropriate buffer as a blank, an absorption spectrum of the sample was recorded in triplicate. Concentrations were determined using the measured absorbance at 280 nm and corrected for light scattering using the absorbance at 340 nm. \[ c = \frac{A_{280} - A_{340}}{\epsilon_{280} \cdot l} \] (2.1) The correlation of the absorbance with the concentration $ c $ is given by the Beer-Lambert equation, Equation 2.2, where $ \epsilon_\lambda $ is the extinction coefficient at a specific wavelength and $ l $ the pathlength in cm. \[ A_\lambda = \epsilon_\lambda \cdot l \cdot c \] (2.2) For all GLP-1 peptides a theoretical extinction coefficient of 6990 M$^{-1}$cm$^{-1}$ at 280 nm was used, which was calculated using the Expasy ProtParam tool$^{322}$. The molar extinction coefficient for ThT was 31600 M$^{-1}$ cm$^{-1}$ at 412 nm.$^{323}$ The sample size was 2.5 µL. The data were analysed with the program NanoDrop 2000/2000c, which calculates the absorbance using the logarithmic relation between the absorbance $ A $ at a certain wavelength, and the intensity of the sample $ I_s $ and blank $ I_b $. \[ A_\lambda = - \log \left[ \frac{I_s}{I_b} \right] \] (2.3) 2.4 Sample Preparation The peptides were dissolved in 25 mM citrate, phosphate or Tris buffer up to a final stock concentration of 300 µM depending on the solubility of the peptide. Citrate was used to buffer from pH 3.0 to 6.0, phosphate from pH 6.5 to 7.5 and Tris from 8.0 to 9.0. After the peptides were dissolved, the pH was checked using a pH meter (SevenExcellence, Multiparameter, Mettler Toledo, pH electrode: InLab® Micro-Pro-ISM) and the solutions were subsequently filtered using a 0.45 µm PVDF Millipore centrifuge filter prior to use (Biofuge pico, Heraeus, 2 min, 13000 rpm at room temperature). The peptide concentration was then determined spectrophotometrically using a NanoDrop spectrophotometer, Section 2.3. 2.5 Solubility Measurements The peptides were weighed, and approx. 0.2 mg were dissolved in 50 µL of buffer to get a final concentration of approx. 1200 µM. 25 mM buffer was used for all pH values between pH 3.0 and 9.0. After the buffer was added to the peptide, the samples were left to dissolve for 30 min and were subsequently centrifuged for 5 minutes at 13000 rpm at room temperature (Biofuge pico, Heraeus) before the concentration of the supernatant was determined spectrophotometrically using a NanoDrop spectrometer. 2.6 Liquid Chromatography-Mass Spectrometry (LC-MS) For the LC-MS measurements, lyophilised sample was dissolved in 33% deionised water, 33% acetic acid (glacial, purum) and 33% acetonitrile (HPLC grade). The sample size was 5 µL with a peptide concentration of 30 µM. The LC-MS was performed using an Agilent System, with an Agilent Polaris analytical C8-A, 4.6 x 100 mm, 5 µm Agilent Technologies column attached. The experiment was run at room temperature. The instrument was equipped with a 3100 Mass Detector (Waters, GB) and the peptides were run according to the methods summarised in Table 2.1 depending on whether they were lipidated or not. \| Parameter \| Value \| \|----------------------------\|--------------------------------------------\| \| Flow rate \| 1.5 ml/min \| \| UV detector \| 210 nm \| \| Run time \| 6 min \| \| Sample injection \| 5 µL \| \| Mobile phase A \| 0.1 % trifluoroacetic acid (TFA) in water \| \| Mobile phase B \| 0.1 % trifluoroacetic acid (TFA) in acetonitrile \| Gradient of the run for non-lipidated peptides \| Time (min) \| Mobile phase A (%) \| Mobile phase B (%) \| \|------------\|--------------------\|--------------------\| \| 0 \| 90 \| 10 \| \| 5 \| 10 \| 90 \| \| 5.75 \| 10 \| 90 \| \| 6 \| 90 \| 10 \| Gradient of the run for lipidated peptides \| Time (min) \| Mobile phase A (%) \| Mobile phase B (%) \| \|------------\|--------------------\|--------------------\| \| 0 \| 85 \| 15 \| \| 5 \| 0 \| 100 \| \| 5.75 \| 0 \| 100 \| \| 6 \| 85 \| 15 \| Table 2.1. Parameters for the LC-MS experiments. ### 2.7 Dynamic Light Scattering (DLS) For the DLS experiments, a Zetasizer Nano ZS (Malvern Instruments, Malvern, UK) was used. Using a monochromatic laser light source and quasi-elastic light scattering it determines the mutual translational diffusion coefficient $D_t$ of macromolecules in a sample. Assuming that all particles are spherical, homogeneous and with equivalent density (Mie scattering), the Zetasizer software calculates the intensity-weighted mean hydrodynamic distribution and of the number size distribution. Samples of 150 µM GLP-1, freshly prepared or fibrillar, were measured. The measurements were recorded at 25 °C in a Zen 2112 cuvette and with a scattering angle of 173 degrees. Before each measurement, the cuvette was rinsed three times with deionised water and subsequently with ethanol (95%). After the cuvette was dried using compressed air, it was filled with approximately 60 µL of the sample. The submenu measurement type was set on peptide, and in the submenu the appropriate dispersant was chosen. This was either 25 mM citrate, phosphate or Tris buffer. For each sample, three consecutive traces were recorded and averaged. ### 2.8 Imaged Capillary Isoelectric Focusing (iCIEF) The pI of the peptides was determined using iCIEF (proteinsimple - Maurice). All peptides were dissolved in Tris buffer at pH 8.5 with a final peptide concentration of 336 µM (approx. 1 mg mL$^{-1}$). For each run, 40 µL of the sample was diluted with 160 µL of Master Mix, which contained distilled water, methyl cellulose, broad-range ampholytes, arginine and different pI markers. The composition of the Master Mix varied for different peptide samples. For two runs of Am-GLP-1, the Master Mix was mixed using 178 µL distilled water, 168 µL 1% methyl cellulose (proteinsimple), 19.2 µL pharmalytes® 3-10 (Sigma), 9.6 µL 500 mM arginine (prepared from L-Arginine monohydrochloride, Merck), 4.8 µL pI marker I (Trp-Asp-Asp-Arg, pI 4.05), and 4.8 µL pI marker II (Trp-Tyr-Lys-Lys, pI 9.99). The Master Mix for the GLP-1 sample contained urea to prevent precipitation and was prepared for approximately eight samples. For the Master Mix with urea, 0.96 g of urea was weighed and dissolved in 500 µL distilled water, vortexed and subsequently heated for 5 minutes at 80 °C (heat block). Immediately afterwards 400 µL 1% methyl cellulose (proteinsimple) was added and the sample vortexed again. After the sample cooled down to room temperature, 80 µL pharmalytes® 3-10 (Sigma), 80 µL 500 mM arginine (prepared from L-arginine monohydrochloride, Merck), 20 µL pI marker I (Trp-Asp-Asp-Arg, pI 4.05), and 20 µL pI marker II (Trp-Tyr-Lys-Lys, pI 9.99) were added. The Master Mix for IPP4 and IPP5 followed the same method as GLP-1 but the pharmalytes® were changed to 40 µL pharmalytes® 3-10 (Sigma) and 40 µL pharmalytes® 5-8. Additionally, the second marker was changed to 20 µL pI marker II (pI 7.05). The cartridge was prepared by adding 2 mL of Catholyte solution (100 mM sodium hydroxide in 0.1% MC, proteinsimple) to the OH⁻ electrolyte tank and 2 mL of Anolyte solution (80 mM phosphoric acid in 0.1% MC, proteinsimple) to the H⁺ electrolyte tank. 2 mL 0.5% methyl cellulose (proteinsimple) and 500 µL fluorescence calibration standard (proteinsimple) were used as batch reagents. All samples were measured with a pre-focusing time of 1 min at 1500 V and a focusing time of 10 min at 3000 V. Before the measurement a System Suitability (proteinsimple) sample was run to check the performance of the instrument. The experimental data were processed and analysed using Compass Software for ICE (Protein Simple, USA). ### 2.9 Thioflavin T Aggregation Assay Thioflavin T (ThT) was purchased from Sigma. For kinetic experiments, a stock solution of 300 µM of each peptide was prepared, as described above. The samples were incubated in a 96-well half-area plate made of black polystyrene with a clear bottom and a non-binding surface (Corning 3881, USA). The appropriate volumes of peptide stock solution and buffer were mixed with 6 µL of 1 mM ThT stock in the wells in the plate such that the final peptide concentrations were 25, 50, 75, 100, and 150 µM and the ThT concentration was 50 µM and the final volume 120 µL. A sealing tape (Corning, Thermowell™ Sealing Tape for 96 Well Plates, 6570) was used to protect samples from evaporation. Fluorescence measurements were carried out using a Fluostar Optima Microplate Reader (BMG Labtech, Offenburg, Germany) at 37 °C. Fluorescence was measured using an excitation filter at 440 nm and emission filter at 480 nm. Bottom reading of the plate every 30 min with 5 min of shaking prior to each measurement was performed. Each cycle was executed with the orbital shaker at 350 rpm, 5 flashes per well and fluorescence measurements were made at a gain of 800. All measurements were made in triplicate for each peptide concentration in a single 96-well plate and each experiment was repeated at least three times on different days with freshly prepared samples. 2.9.1 Preparation of ThT Stock Solution For all ThT assays, a 5 mM ThT stock solution was prepared by dissolving dry ThT powder (Sigma-Aldrich, T3516-5G, Lot # MKCF7580, dye content 66 %) in deionized water. After the ThT was completely dissolved, the stock solution was filtered using a 0.22 µm PVDF syringe filter. The stock was stored at -20 °C. Before use, the stock was diluted to 1 mM and the concentration was verified spectrophotometrically using a NanoDrop spectrometer and a molar extinction co-efficient ($ \varepsilon $) of 31600 M$^{-1}$cm$^{-1}$ at 412 nM.$^{323}$ 2.9.2 ThT Assay Data Analysis: Fitting to a Sigma Function Each individual ThT dataset was fit to \[ y = y_0 + \frac{A}{1 + \exp \left( -k \left( t - t_{1/2} \right) \right)} + bt \] (2.4) with $ y_0 $ as the starting fluorescence, $ A $ is the amplitude of the transition, $ t_{1/2} $ the half-time, which is defined as the time at which the ThT fluorescence has reached 50% of its final baseline value, $ k $ the apparent growth rate and $ b $ the slope of the final baseline.$^{324,325}$ Note, in many other studies data are normalized prior to fitting such that the inclusion of the additional term $ bt $ is not needed. The lag time was calculated from the kinetic parameters obtained using:$^{324,325}$ \[ t_{lag} = t_{1/2} - \frac{2}{k} \] (2.5) 2.9.3 ThT Assay Data Analysis: Fitting to a Fragmentation-Dominated Model To gain further insight into the aggregation kinetics, the ThT data were also fitted to an equation based on principal moments. This simplified solution of a Master equation takes primary nucleation, elongation and fragmentation into account.\textsuperscript{83,280} \[ M_{RF}(t) = M_0 \left[ 1 - \exp \left( C_- e^{-\kappa t} - C_+ e^{\kappa t} + \frac{\delta^2}{\kappa^2} \right) \right] \] (2.6) where the fibril mass is $M_{RF}$, the total protein concentration is $M_0$ and $C_\pm = \pm (\delta/2\kappa)$. Here $\delta$ and $\kappa$ represent the effective rate for nucleated polymerisation without secondary pathways and the rate of multiplication of the filament population, respectively. The effective rate for nucleated polymerisation without secondary pathways, $\delta$, is given by \[ \delta = \sqrt{2M_0^{n_c} k_n k_+} \] (2.7) It depends, therefore, on the total peptide concentration $M_0$, the size of the nucleus $n_c$, the primary nucleation rate constant $k_n$ and the elongation rate constant $k_p$. $\delta$ is precisely the effective rate constant derived by Oosawa\textsuperscript{81,326} for nucleated polymerisation without secondary pathways. The rate of multiplication of the filament population, $\kappa$, is given by \[ \kappa = \sqrt{2M_0 k_n k_m} \] (2.8) It includes the fragmentation rate constant $k_m$. ### 2.10 Far-UV Circular Dichroism (Far-UV CD) and CDPro Circular dichroism measures the differential absorption of right-handed and left-handed polarised light by chiral molecules. The far-UV CD spectra of freshly prepared peptide samples (150 µM) in the appropriate buffer, as well as samples aggregated in a BMG Fluostar plate reader (150 µM) using the method described in Section 2.9 without ThT, were measured using a 0.1 mm pathlength cuvette in a Jasco J815 spectrophotometer (Jasco Spectroscopic Co. Ltd., Tokyo, Japan). The cuvette was filled with 75 µL of sample and the CD spectra and HT voltage were recorded from 180 to 260 nm at 25 °C. Data with a HT voltage higher than 500 V was discarded as the CD signal was too noisy to use. Therefore, only data from 190 to 260 nm were further analysed as in this range the HT voltage was always below 500 V. For each measurement, spectra were acquired three times with a scanning speed of 20 nm min$^{-1}$. After baseline subtraction, the spectra were processed using Spectra Manager Version 2 software and smoothed using a mean movement method with a convolution width of 5. The method, also known as the simple moving average method, uses a rectangular function as a weighting function. The smoothed value $y(i)$ for each discrete value $x(i)$ of the input signal was determined using Equation 2.9. The rectangle width is defined as $N = 2m + 1$ and $i = m+1, m+2, \ldots, n-m$ for $n$ discrete values $x(i)$. \[ y(i) = \frac{1}{N} \sum_{j=-m}^{m} x(i+j) \] (2.9) The data output was in ellipticity $\theta$ (mdeg). The mean molar ellipticity per residue $[\theta]_{MR}$ was calculated using Equation 2.10. \[ [\theta]_{MR} = 10 \cdot \frac{\theta}{(C_{MR} \cdot l)} \] (2.10) where $l$ is the pathlength in cm, and $C_{MR}$ is the mean residue concentration, which was calculated from the concentration of peptide, $C$, in molar units and the number of residues $N$ in the peptide using Equation 2.11. \[ C_{MR} = C \cdot N \] (2.11) The data were further analysed using CDPro.$^{327,328}$ The programme compares a far-UV CD spectrum to the far-UV CD spectra of different proteins whose crystal structures and therefore secondary structures are known. Three different reference sets were used (SP29, SP43 and SDP48). The reference sets tested included data of 29, 43 or 48 proteins within the range of 178-260 nm (SP29) and 190-240 nm (SP43 and SDP48). A detailed comparison of the different reference sets has been made by Sreerama and Woody.$^{329}$ Their results indicate that far-UV CD data in the wavelength range of 190-240 nm can give reliable results when a larger reference set is used.$^{329}$ Whitmore and Wallace$^{309}$ give a complete list of the proteins in each reference set in their paper about the analysis of protein secondary structures and features of the DichroWeb, a web application of CDPro. The corresponding names of the datasets in DichroWeb are RDB1 (SP29), RDB4 (SP43) and RDB7 (SDP48). For GLP-1, the reference dataset SP43 showed the most consistent results. Therefore, it was used to calculate secondary structure content using three different algorithms (SELCON3\textsuperscript{327,330}, CDSSTR\textsuperscript{329,331,332} and CONTINLL\textsuperscript{333,334}). ### 2.11 Fourier-transform Infrared Spectroscopy (FT-IR) The Fourier-transform IR spectra of different peptide samples were measured with a Perkin Elmer FT-IR spectrometer (Spectrum 400) equipped with an Attenuated Total Reflectance (ATR) crystal. For each sample, small volumes (8 x 0.75 µL) were repeatedly dried on the crystal surface using a gentle, filtered air stream. The resolution employed was 4 cm\textsuperscript{-1} and the signal was accumulated using 32 repetitions. The spectra were recorded from 2000 to 1000 cm\textsuperscript{-1} and analysed in the amide I region (1720 - 1580 cm\textsuperscript{-1}) using the Perkin Elmer Spectrum Software. ### 2.12 Extrinsic and Intrinsic Protein Fluorescence A Hitachi F-7000 fluorescence spectrophotometer plate reader was used for all extrinsic or intrinsic protein fluorescence time point measurements. Emission spectra were collected using top reading of the plate. #### 2.12.1 Tryptophan Fluorescence The intrinsic fluorescence of 150 µM Am-GLP-1 at different pH values and at different time points was recorded. 100 µL aliquots were pipetted into wells of a 96-well half-area plate mode of black polystyrene, with flat wells and non-binding surface (Corning 3993, US). Emission spectra were collected from 285 to 500 nm using an excitation wavelength of 277 nm (scan speed: 1200 nm min\textsuperscript{-1}, excitation bandpass: 2.5 nm, emission bandpass: 2.5 nm, voltage: 900 V, response: 2.0 s, data point collection: 1 nm). 2.12.2 8-Anilinonaphthalene-1-sulfonic Acid (ANS) Binding Assay 8-anilinonaphthalene-1-sulfonic acid (ANS) has been used to detect the presence of exposed hydrophobic patches in the aggregated species.\textsuperscript{335} ANS was purchased from Sigma-Aldrich (A1028-5G, Lot # MKCJ6296, purity $\geq$ 97 %). Measurements were taken at the beginning of the ThT assay and one after 144 h of aggregation. Typically, 50 µL of peptide sample was mixed with 2.5 µL 1 mM ANS stock directly in a 96-well half-area plate made of white polystyrene and non-binding surface (Corning 3693, US). The final concentrations were 143 µM (peptide) and 48 µM (ANS). The emission spectra were acquired from 420 to 600 nm using an excitation wavelength of 350 nm (scan speed: 240 nm min\textsuperscript{-1}, excitation bandpass: 1 nm, emission bandpass: 2.5 nm, voltage: 800 V, response: 0.01 s, data point collection: 1 nm). Preparation of ANS Stock Solution A 1 mM ANS stock solution was prepared by dissolving dry ANS powder in deionized water. After the ANS was completely dissolved, the stock solution was filtered using a 0.22 µm PVDF syringe filter. The stock was stored at -20 °C. The concentration was determined spectrophotometrically using a molar extinction coefficient at 350 nm of 5000 M\textsuperscript{-1} cm\textsuperscript{-1}.\textsuperscript{335} 2.12.3 \textit{Ex-situ} ThT Fluorescence Measurements \textit{Ex-situ} ThT measurements were taken before the aggregation assay and after 144 h of aggregation. Typically, 50 µL of peptide sample was mixed with 1 µL 2.5 mM ThT stock to a final concentration of 147 µM GLP-1 and 49 µM ThT in wells of a 96-well half-area plate made of black polystyrene, with flat wells and non-binding surface (Corning 3993, US). Emission spectra were collected from 450 to 600 nm using an excitation wavelength of 440 nm (scan speed: 240 nm min\textsuperscript{-1}, excitation bandpass: 5 nm, emission bandpass: 5 nm, voltage: 800 V, response: 0.01 s, data point collection: 1 nm). 2.13 Fibril separation For the fibril separation experiment, 6 x 120 µL of GLP-1 or Am-GLP-1 at a concentration of 150 µM were prepared. The samples were aggregated at 37 °C with agitation for 144 h in a BMG Fluostar plate reader. After the incubation, the tryptophan fluorescence was measured using 3 x 100 µL of the aggregated peptide sample (Section 2.12.1). Subsequently, the samples were split in half, 2.5 µL of 1 mM ANS stock or 1 µL of 2.5 mM ThT stock was added to 50 µL of peptide sample, and the fluorescence spectra recorded as described in Sections 2.12.2 and 2.12.3. In addition, 360 µL of aggregated peptide sample was placed into a 0.6 mL Eppendorf tube and centrifuged for 20 min at 17000 g and 25 °C. The supernatant was then carefully separated from the pellet using a pipette, Figure 2.3. The separated pellet was subsequently suspended in the appropriate buffer to reach a final volume of 360 µL. After a repetition of this process, the tryptophan, ANS and ThT fluorescence were measured as described in Section 2.12.2 and 2.12.3. Figure 2.3. Separation of peptide aggregates from supernatant using centrifugation. The separation of the supernatant was repeated twice. 2.14 Imaging 2.14.1 Atomic Force Microscopy (AFM) Peptide samples in solution were taken directly after the peptides were dissolved and filtered and at different time points during the aggregation assay or at the end. Typically, 5 µL of each sample was spread onto freshly cleaved mica. After the sample dried, it was rinsed with 2 x 300 µL deionised water and dried using a gentle nitrogen stream. The AFM images were acquired with a PicoPlus AFM instrument with a PicoSPM II controller from Molecular Imaging (Agilent Technologies, USA) in AC mode (Tapping mode), equipped with a MikoMasch NSC26/No Al cantilever, between 65 and 130 Hz frequency, force constant varying from 0.6 to 2.0 N m$^{-1}$ (Innovative Solutions Bulgaria Ltd., Sofia, Bulgaria). All images were taken in air and at room temperature. The images were analysed with the open-source software Gwyddion.$^{336}$ The stated width of the measured aggregates is equivalent to the full width half maximum (FWHM). Therefore, the profiles were fitted with a Gaussian and the standard deviation of the function multiplied by 2.35.$^{337,338}$ 2.14.2 Scanning Electron Microscopy (SEM) SEM does not have the highest possible magnification of available microscopy techniques, but it has the advantage that it enables scanning over a broad range of magnifications and therefore it is less likely to miss important details in the sample. For example, if the sample spot has a diameter of 4 mm, for three 10 x 10 µm$^2$ pictures with AFM only a few millionths of the whole sample surface is imaged. As for every other microscopy technique using dried samples, the images are, of course, influenced by the drying process. Typically, 5 µL of GLP-1 or Am-GLP-1 in buffer were spread onto microscope glass slides which were cleaned before use with acetone and isopropanol. The samples were either left to dry or the drop was gently blown away with a stream of nitrogen after it had been on the surface for 2 min. The slides were rinsed with 2 x 300 µL of deionized water and dried under a gentle stream of nitrogen before the samples were coated with a 10 nm thick platinum layer (Quorum Technologies Q150T ES Turbo-Pumped Sputter/Carbon Coater). The samples were imaged using a Tescan Mira3 FEG-SEM. The In-Beam SE detector was used with SEM HV 5.0 kV and WD 4 m. 2.15 Net Charge and pI Determination The net charge was determined using the Henderson-Hasselbalch equation and the isoelectric point calculation.\textsuperscript{339} For residues of the amino acids with a negative charge the contribution can be calculated using Equation 2.12 and their individual $pK_a$ values: $$\sum_{i=1}^{n} \frac{-1}{1 + (10^{pK_a - pH})}$$ \hspace{1cm} (2.12) For positively charged residues the charge contribution can be calculated using the appropriate $pK_b$ values as shown in Table 2.2 and Equation 2.13: $$\sum_{i=1}^{n} \frac{1}{1 + (10^{pH - pK_b})}$$ \hspace{1cm} (2.13) The final charge is the sum over all negative charges plus the sum of all the positive charges which are, of course, both pH dependent. \| Name \| 1-Letter Symbol \| $pK_a$ \| $pK_b$ \| Side chain $pK_a$ \| Side Chain $pK_b$ \| \|---------------\|-----------------\|--------\|--------\|-------------------\|-------------------\| \| Arginine \| R \| 2.17 \| 9.04 \| \| 12.48 \| \| Aspartic Acid \| D \| 1.88 \| 9.60 \| 3.65 \| \| \| Glutamic Acid \| E \| 2.19 \| 9.67 \| 4.25 \| \| \| Glycine \| G \| 2.34 \| 9.60 \| \| \| \| Histidine \| H \| 1.82 \| 9.17 \| \| 6.00 \| \| Lysine \| K \| 2.18 \| 8.95 \| \| 10.53 \| Table 2.2. $pK_a$ values of ionisable groups in proteins. $pK_a$ is the negative of the logarithm of the dissociation constant of the -COOH group. $pK_b$ is the negative of the logarithm of the dissociation constant of the -NH$_3^+$ group.\textsuperscript{340} 2.16 Ultra-Performance Liquid Chromatography (UPLC) GLP-1 was reconstituted in 25 mM sodium phosphate buffer at pH 7.5 to a final peptide concentration of approximately 300 µM. The UPLC was performed using an Acquity UPLC Waters System, with a BEH C18 2.1 x 100 mm, 3.5 µm (300 Å) column attached. The method used is shown in Table 2.3. \| Flow rate \| 0.3 ml/min \| \|-----------\|------------\| \| Run time \| 40 min \| \| Mobile phase A \| 95% water, 5% acetonitrile (ACN), 0.03% trifluoroacetic (TFA) \| \| Mobile phase B \| 95% acetonitrile (ACN), 5% water, 0.03% trifluoroacetic (TFA) \| Gradient of the run \| Time (min) \| Mobile phase A (%) \| Mobile phase B (%) \| \|------------\|--------------------\|--------------------\| \| 0 \| 75 \| 25 \| \| 30 \| 10 \| 90 \| \| 40 \| 0 \| 100 \| Table 2.3. UPLC method. 2.17 Singular Value Decomposition (SVD) A singular value decomposition (SVD) of far-UV CD and FT-IR data was performed using Matlab. A SVD factorises an $m \times n$ real matrix $M$ (it is possible for a complex matrix as well but not relevant in this case) into an $m \times m$ real unitary matrix $U$, an $m \times n$ rectangular diagonal matrix with non-negative real numbers on the diagonal $\Sigma$, and an $n \times n$ real unitary matrix $V$. $$M = U \Sigma V^* \quad (2.14)$$ The diagonal entries $\sigma_i = \Sigma_{ii}$ are the singular values of $M$ and the columns of $U$ and the columns $V$ are called the left-singular vectors and the right-singular vectors. The contribution of the different principal components of the analysed spectra was calculated by multiplying $U \cdot \Sigma \cdot V^$, with all values in $\Sigma$ set to 0 except of $\sigma_i$, as shown in Section 1.15. 2.18 Size-Exclusion Chromatography Analytical size-exclusion chromatography (SEC) was performed by Eva Brichtová using an AKTA FPLC system (GE Healthcare). A Superdex 200 Increase 10/300 column (GE Healthcare) was used and samples were loaded using 100, 200 or 500 µL loops. Each sample was filtered through a 0.22 µm filter prior to loading. The system was run at a flow rate of 0.75 mL min$^{-1}$ at room temperature and UV absorbance at 280 nm was measured using a 0.5 cm flow cell. For the calibration of the column, globular protein standards (GE Healthcare) were used under the same buffer conditions as in the experiments with samples of lipidated peptides (IPP4 and IPP5). The gel phase distribution parameter, $K_{av}$, of each protein standard was calculated using $$K_{av} = \frac{V_e - V_0}{V_c - V_0} \quad (2.15)$$ Where $V_c$ is the elution volume of a protein standard, $V_0$ is the void volume of the column and $V_e$ is the total volume of the column. The logarithm of the molecular weight of each protein standard, Table 2.4, was plotted against its $K_{av}$ and from its linear regression the molecular weight of IPP4 and IPP5 was determined. The Stoke’s radius, $R_{St}$, was determined using a calibration plot of $(-\log(K_{av}))^{-1/2}$ against $R_{St}$ and its linear regression, Figure 2.4. However, the commercially-available SEC calibration kits contain only globular proteins. Therefore, the values of molecular weights of oligomeric species are only estimates. \| Standard \| $M_W$ [Da] \| Stoke’s radius [Å] \| $V_{elution}$ [mL] \| \|------------------\|----------------\|--------------------\|-------------------\| \| Blue Dextran 2000\| N/A (void volume) \| N/A \| 8.1 \| \| Aldolase \| 158 000 \| 48.1 \| 12.2 \| \| Ovalbumin \| 44 000 \| 30.5 \| 14.1 \| \| Ferritin \| 440 000 \| 61 \| 9.7 \| \| Conalbumin \| 75 000 \| \| 13.6 \| \| Thyroglobulin \| 669 000 \| 85 \| 8.8 \| \| Ribonuclease A \| 13 700 \| 16.4 \| 17.7 \| \| Carbonic Anhydrase\| 29 000 \| \| 16.0 \| Table 2.4. SEC calibration standards.* Molecular weights (MW), Stoke’s radius, and elution volume on a Superdex® 200 Increase 10/300 column. The calibration standards were obtained from GE Healthcare and the samples were run in 25 mM sodium phosphate buffer, pH 7.5 at a flow rate of 0.75 mL min$^{-1}$. Table adapted from Eva Brichtová. Figure 2.4. Calibration curve for SEC column Calibration curve for the Superdex 200 Increase 10/300 column. Calibrations conducted in 25 mM sodium phosphate at pH 7.5 using proteins standards, Table 2.4. Calibration for the molecular weight (A) and the Stoke’s radius (B) were performed at room temperature, with a flow rate of 0.75 mL min$^{-1}$ and 100 µM of each protein was injected using a 200 µL injection loop. Figures adapted from Eva Brichtová. 3 PHYSICAL STABILITY OF GLP-1 3.1 Introduction Peptide therapeutics represent an increasingly important class of pharmaceutical drugs. However, despite efficacy and improvements in in vivo half-lives, there remain some key challenges in the development, formulation and use of these biologics. The physical stability of peptides is a common problem that, in some cases, results in major obstacles in the development pipeline of the potential drug. Poor physical stability can result in the formation of amorphous or highly structured aggregates that prevent use of the peptide or which may result in an adverse immunogenic response. The problems of physical stability are often exacerbated at the high concentrations of peptide used for subcutaneous injection. Excipients, that are commonly selected from screening experiments, are frequently used to minimise aggregation, however, they are sometimes ineffective. In order to rationally design peptide sequences/modification strategies that result in peptides with intrinsically higher degrees of physical stability, or rationally select excipients to combat aggregation, a much greater understanding of the mechanisms underpinning the aggregation of therapeutic peptides is required. The 31-residue (7-37) therapeutic peptide GLP-1 is known to suffer from low physical stability and forms a range of aggregates under different conditions, for example, linear, rigid, amyloid-like fibrils and other species.$^5$ A detailed investigation of its aggregation behaviour at pH values between 7.5 and 8.2, established that in addition to the on-pathway oligomers that can go on to form fibrillar structures, GLP-1 can form off-pathway oligomeric species at pH 7.5, which dramatically affect the kinetics of aggregation slowing down the rate of fibrillation.\textsuperscript{5} In addition, it was shown that at all pH values investigated, freshly prepared solutions of GLP-1 contained small soluble oligomers as well as monomers. The presence of these small oligomers was particularly pronounced at pH 7.5 or 7.7 where the peptide has a higher propensity to form off-pathway oligomers and slow aggregation kinetics. In addition, the aggregation of GLP-1 has been investigated at pH 3.0 and pH 3.5, Section 1.10, and it was established that amyloid fibril formation also takes place at these acidic pH values, and that, similar to what was previously observed at pH 7.5–8.2, even small changes in pH can result in a switch in the self-assembly mechanism from predominantly on-pathway oligomers being populated to conditions where off-pathway species become populated. In this Chapter, the aggregation of GLP-1 over a wide range of pH values and peptide concentrations is studied in further detail. In particular, the reproducibility of the aggregation assays was initially assessed. Once reproducibility had been established, time-course experiments, in which samples were taken at different times during the aggregation reaction and analysed using a range of biophysical approaches, were undertaken. Far-UV CD and FT-IR were used to provide information on the secondary structure at different times. The spectra from both techniques were subsequently analysed using a single-value decomposition method to discover more about how the structure evolved with time. AFM was used to image any species in the aggregating sample large enough to be detected using this method, providing information on higher-order structures. The time-course experiments led to a deeper understanding of the differences between samples which showed predominantly on-pathway behaviour in comparison to samples where off-pathway oligomers were populated. The observed differences in terms of the evolution of the secondary structure, the size of the aggregates, as well as evidence for aggregates with different structures, is discussed in detail. 3.2 Aggregation of GLP-1 at Neutral and Basic pH 3.2.1 GLP-1 Lag Time Comparison of Data collected by KLZ and FJB In initial experiments performed at the start of the PhD, some of the GLP-1 ThT aggregation assays that had been performed previously by Dr Karolina Zapadka (KLZ) were repeated. This was undertaken for a number of different reasons. First, to verify the results of experiments performed by KLZ, second to ensure good training in the assays, and third to check for any issues of reproducibility between different researchers. The peptide concentration dependence measurements of the aggregation of GLP-1 were repeated at pH 7.5 and 8.2. The data are shown in Figure 3.1A & B and Figure 3.2A & B and show the expected trend where $t_{\text{lag}}$ and $t_{1/2}$ increase with increasing peptide concentration at pH 7.5, but decrease with increasing peptide concentration at pH 8.2, as had been reported previously. The variance between measurements recorded in triplicate was, however, slightly more significant compared to the data previously obtained Dr Karolina Zapadka, Figure 1.18E & G. No additional peptide concentration dependence measurements at pH 3.0 and 3.5 were undertaken in order to save peptide from the same batch for other experiments. Figure 3.1. ThT assay data following the aggregation of GLP-1 at different peptide concentrations. All samples were measured at 37 °C and at the following peptide concentrations: 25 µM (pink), 50 µM (orange), 75 µM (blue), 100 µM (dark blue), 125 µM (green), and 150 µM (dark green). A) GLP-1 aggregated in 25 mM phosphate buffer at pH 7.5 B) GLP-1 aggregated in 25 mM Tris buffer at pH 8.2. Figure 3.2. Comparison of the kinetic parameters obtained from ThT aggregation assays performed by FJB and KLZ. Lag times of GLP-1 at different peptide concentrations. The error bars show the standard deviation. A) GLP-1 aggregated in 25 mM phosphate buffer at pH 7.5. The graph shows data previously obtained by Dr Karolina Zapadka (KLZ), and two sets of repeated triplicate measurements of GLP-1 performed by FJB, set I and set II). B) Lag times of GLP-1 aggregation in 25 mM Tris buffer at pH 8.2. The graph shows data previously obtained by Dr Karolina Zapadka (KLZ), and a triplicate measurement of GLP-1 performed by FJB. 3.2.2 Reproducibility of GLP-1 ThT Assays with Different GLP-1 Batches One additional measurement was undertaken using a different batch (Bachem - B2) of GLP-1 which was previously used in the experiments published by Zapadka et al.$^5$ A comparison of the lag times obtained from the aggregation kinetics at pH 7.5 for the different batches is shown in Figure 3.3A. The measured values are in good agreement with the data previously obtained by Dr Karolina Zapadka$^5$ which shows that results of the ThT aggregation assays can be reproduced. N.B., both datasets also show the unusual increase of the lag time with increasing peptide concentration typical under these conditions. However, the differences in lag time between Batch 2 and Batch 3 are an important reminder that batch-to-batch variation must always be considered in the study of peptide aggregation, Figure 3.3B. In the rest of this Thesis, all samples of the different peptide analogues were taken from a single batch, which in the case of GLP-1 was Batch B3. ![Figure 3.3. Comparison of the aggregation lag times of different batches of GLP-1 at pH 7.5.](image) A) Lag times for GLP-1 aggregation in 25 mM phosphate buffer at pH 7.5. The graph shows repeated measurements recorded by FJB (grey diamonds) and previously obtained data from Dr Karolina Zapadka (black solid circles). B) Lag times for GLP-1 aggregation recorded by FJB. Peptides taken from two different batches (Batch B2 and B3) and aggregated in 25 mM phosphate buffer at pH 7.5. The error bars shown in A & B correspond to the standard deviations of the kinetic parameters determined from one experiment where each peptide concentration was run in triplicate. 3.2.3 GLP-1 Aggregation Kinetics Around pH 7.5 in Tris and Phosphate Buffer To compare the influence of different buffers, GLP-1 aggregation was measured in phosphate buffer (PB) at pH 7.5, and Tris at pH 7.2 and 7.5, all at 37 °C and at a buffer concentration of 25 mM. All measurements in 25 mM phosphate buffer, pH 7.5 show the same trend as previously reported, where the lag time increases with increasing peptide concentration. In Tris buffer at pH 7.5 (37 °C), the trend was not as pronounced and values of $t_{\text{lag}}$ varied less, Figure 3.4, however, there was still some evidence to suggest the formation of off-pathway oligomers under these conditions. Under slightly more acidic conditions, at pH 7.2, the lag time of GLP-1 aggregation increases again with increasing peptide concentration from approximately 30 to 60 h, Figure 3.4, and it is interesting to note that it is slower than at pH 7.5. These results suggest that the identity of the buffer plays a rather small role in GLP-1 aggregation kinetics compared with the pH. The small differences that were observed most likely can be explained by the different ionic strengths of the phosphate and Tris buffers at the same pH. ![Graph showing comparison of the lag time of GLP-1 aggregation in different buffers around pH 7.5](image) Figure 3.4. Comparison of the lag time of GLP-1 aggregation in different buffers around pH 7.5 Lag times of GLP-1 aggregation at different peptide concentrations. The graph shows data previously obtained by Dr Karolina Zapadka (black solid diamonds), as well as other measurements performed by FJB: two sets of repeated triplicate measurements in phosphate buffer, pH 7.5 (blue solid and open hexamers), triplicate measurements in Tris buffer at pH 7.5 (37 °C) (green solid triangle) and a triplicate measurement in Tris buffer at pH 7.2 (37 °C) (orange solid triangle). The error bars show the standard deviation. 3.3 Solubility and Net Charge of GLP-1 From previously conducted ThT assays on the aggregation of GLP-1, it was seen that GLP-1 aggregates not only under neutral and basic but also under acidic conditions. Additionally, the unusual pH and concentration dependence seen at pH 7.5$^5$ was also shown to exist at pH 3.5, Section 1.10. Understanding why such behaviour occurred under certain conditions but not all, for example, at pH 3.0 and 8.2, was one of the main motivations of this study. To provide information on how the solubility and net charge of GLP-1 vary with pH, the solubility and the pI of GLP-1 were determined experimentally, and the net charge was calculated at different pH values. After dissolving approx. 0.2 mg of GLP-1 in approx. 50 µL of buffer at different pH values to get a final concentration of approx. 1200 µM, samples were centrifuged to get rid of undissolved peptide, and the peptide concentration determined spectrophotometrically. The results showed an apparent minimum in solubility around pH 4.5 and 5. As expected, the solubility correlates reasonably with the net charge and shows a minimum when the net charge is zero/very low. However, the pH values of the minimum solubility are slightly more acidic in comparison to both the calculated pI value 5.4 and the experimentally measured pI of 5.8 using iCIEF, Figure 3.5B & C. Figure 3.5. Solubility measurement, net charge calculation and pI measurement for GLP-1 using capillary isoelectric focusing. A) Peptide concentration measured after dissolving approximately 0.2 mg GLP-1 into 50 µL buffer. The open circles indicate a concentration of at least 1000 µM. The error bars show the standard deviation of three peptide concentration measurements. B) Calculated net charge of GLP-1 peptide using the sequence and the Henderson-Hasselbalch equation, Section 2.15. C) pI measurement for GLP-1 using iCIEF. 3.4 Time-Course Experiments In order to further investigate the mechanism by which GLP-1 aggregates to form amyloid fibrils at pH 3.0, 3.5, 7.5 and 8.2, a series of experiments were conducted aimed at characterising the size and structure of species in solution at different time points during the aggregation reaction. In particular, time points were chosen to focus on changes occurring in the lag phase of the aggregation kinetics. The size of the species formed was assessed using atomic force microscopy (AFM) and dynamic light scattering (DLS); the secondary structure assessed using far-UV CD and FT-IR. In addition, GLP-1 aggregation under acidic conditions was measured in both citrate and phosphate buffer as citrate has a strong absorbance in the FT-IR experiments in a similar region to the peptide and also leads to higher background noise in the far-UV CD spectra. 3.4.1 Imaging of Peptide Aggregates To learn more about the size and structure of GLP-1 aggregates formed during the time course of the aggregation process AFM images were taken. A small sample was taken during a ThT assay at each time point marked with a red downwards facing triangle as shown in Figure 3.6A. A comparison of the results obtained at different times and pH values shows that a large number of different species are populated, before, during and after aggregation depending upon conditions. These species are classified into eight different types. Curly and tangled fibrillar structures formed immediately after the monomeric peptide was dissolved are called Type s. Oligomer-like structures also observed at the start of the aggregation reaction are referred to as Type o. The most common species observed was mainly straight fibrils, however, even these are heterogeneous and have varying heights and widths. Here, the differences in height are used to distinguish six different types of fibrils. Fibrils with heights ranging from 0.5 - 1.5 nm are classified as Type a, between 1.5 - 2.5 nm as Type b, between 2.5 - 3.5 nm as Type c, between 3.5 - 5 nm as Type d, between 5 - 10 nm (Type e) and over 10 nm as Type f. The most commonly observed fibrils were Types c and e and these are likely to be assembled from multiples of thinner fibrils. Many, even thicker fibrillar structures were observed, however, as they were normally simple multiples of the previously defined fibril types, no additional types were introduced. N.B. The definition of the different types of fibrils does not mean that the fibrils of the same type are identical if formed under other conditions. It rather indicates that they share similar dimensions. At pH 3.0, GLP-1 was measured in citrate and phosphate buffer. In citrate buffer no aggregates could be observed directly after the preparation and filtration of the samples, Figure 3.6B. However, after only 4 hours, thin and curvy fibrils were observed, Figure 3.6C. Additionally, some entangled aggregates can be seen embedded into the thin mesh of fibrils. In total, at least four different fibrillar species with other profiles can be seen. The thinnest fibril (Type a) has a width of approx. $15 \pm 2$ nm and a height of $1.2 \pm 0.1$ nm. The width of the second smallest fibril (Type b) shows only a slight increase to $16.7 \pm 0.2$ nm. However, it nearly doubles in height to $2.0 \pm 0.2$ nm. The width of the third (Type c) and fourth type of fibril observed (Type d) are $18 \pm 1$ nm and $22 \pm 2$ nm, respectively, and their heights are $2.8 \pm 0.2$ nm and $4.8 \pm 0.2$ nm, respectively, Figure 3.7C. After seven hours, the fibrils are less curvy, and the aggregates can be found in larger patches, Figure 3.6D. Analysis shows that after seven hours, fibrils of type c, d remain but a new fibrillar structure (Type e) appears. Interestingly, the fibrils of Type c observed after seven hours have a similar height of $2.9 \pm 0.2$ nm as fibrils of Type c formed after four hours but are approx. 5 nm smaller in width ($13 \pm 1$ nm). This is also true of fibrils of Type d which, after 7 hours, also have smaller widths by approx. 7 nm. As soon as the plateau phase was reached in the ThT assay and at the end point, the mica sheet was entirely covered by a dense mesh of rigid fibrils, making it challenging to differentiate and analyse single fibrils in detail, Figure 3.6E & F. Figure 3.6. AFM images of GLP-1 species formed at different time points during peptide aggregation in citrate buffer at pH 3.0. A) ThT assay run in triplicate of 150 µM GLP-1 in 25 mM citrate buffer at pH 3.0 and 37 °C. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation and filtration (B), 4 (C), 7 (D), 24 (E) and 168 (F) h. Measurement of height and width of fibrils shown in Figures 3.6C & D and 3.7A & B. The profiles were analysed using the AFM data analysis program Gwyddion. A) AFM image of GLP-1 aggregates (Type a) after 4 h of incubation, showing the positions on the fibrils where the profiles were measured. B) AFM image after 7 h of incubation showing thicker fibrils (Type e). Indicated are the positions where the profiles are measured. C) Complete plot of fibril profiles of different fibril types (Type a, b, c, d & e) taken after 4 h and 7 h. See Table 3.1 and Table 3.2 for further details. GLP-1 aggregation in phosphate at pH 3.0 shows similar results to those obtained in citrate buffer: no fibrils or aggregates were observed at the earliest time point, Figure 3.8B. In the lag phase, after 2.5 and 7 hours, thin and partly curvy fibrils formed, Figure 3.8C & D. In detail, two different types of fibrils (Type c and d) were measured after 2.5 hours with heights of $2.7 \pm 0.3$ nm $4.1 \pm 0.3$ nm, respectively and similar widths between 17-18 nm, Figure 3.9A & C. After 7 hours of incubation, fibrils of Type e formed, which were slightly lower in height ($5.6 \pm 0.5$ nm) and thicker ($28 \pm 2$ nm) than fibrils of Type e after 2.5 hours, Figure 3.9B & C. After the steep growth phase, the surface of the mica sheet was again covered with a thick mesh of fibrils, Figure 3.8E & F. Figure 3.8. AFM images of GLP-1 species formed at different time points during peptide aggregation in phosphate buffer at pH 3.0. A) ThT assay run in triplicate of 150 µM GLP-1 in 25 mM phosphate buffer at pH 3.0 and 37 °C. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation/filtration (B), as well as after 2.5 (C), 7 (D), 24 (E) and 168 (F) h. Measurement of height and width of fibrils shown in Figures 3.8C and 3.90A & B. The profiles were analysed using the AFM data analysis program Gwyddion. A) AFM image of sample after 2.5 h of incubation. Indicated are the places where the profiles of the thinnest fibrils (Type c) were measured. B) AFM image showing a sample after 7 h of incubation. Indicated are the six positions on fibrils of Type e where a profile was measured. C) Complete plot of fibril profiles of different fibril types (Type c, d & e) taken after 2.5 h and 7 h. See Table 3.1 and Table 3.2 for further details. The AFM imaging of GLP-1 at different time points during aggregation in citrate buffer at pH 3.5 showed curly and tangled fibril-like aggregates immediately after the sample preparation, Figure 3.10B. The height and width of these short fibril-like aggregates was measured as $2.2 \pm 0.1$ nm and $15 \pm 1$ nm, respectively (Type s), Figure 3.11A. Some of these aggregates even formed closed ring-like structures. After 6 hours, the time point corresponding to the end of the growth phase, the sample formed fibrils with three different profiles, Figure 3.10C, Type a, b and e. The thinnest fibril (Type a) has a height of $1.5 \pm 0.2$ nm whilst Type b heights were $3.0 \pm 0.2$ nm, they both had similar widths of approx.14 nm. Type a and b fibrils are probably the predecessor for some longer, straight, and partly twisted fibrils (Type e), Figures 3.10C and 3.11E. It is interesting to note that the width of the latter decreases from approx. 23 nm to less than 18 nm during the lag phase. After 23 hours, Type a fibrils disappear and only mostly straight, longer and more rigid fibrils were detected, Figures 3.10D-F and 3.11E. In Figure 3.12D, the tip of a thick fibril of Type f is analysed which appears to be assembled out of thinner fibrils of Type c and e. The findings for GLP-1 at pH 3.5 in phosphate buffer show similar aggregates as in citrate buffer. Again, short and curly fibril-like structures (Type s) are formed immediately after the preparation of the samples, Figure 3.12B. The formation of ring-like structure also seems independent of the buffer. It is worth highlighting that similar as for the citrate buffer at pH 3.5 also in phosphate buffer, the thinnest fibrils (Type b) measured at the second time point are lower and thinner in comparison to the earlier formed curly and tangled fibril-like aggregates. However, during the lag phase and at the beginning of the growth phase, the images show more amorphous structures, Figure 3.12C & D. At the beginning of the plateau and at the end of the aggregation assay, the fibrils are rigid and similar to those observed in citrate buffer, Figure 3.12E & F. Figure 3.10. AFM images of GLP-1 species formed at different time points during peptide aggregation in citrate buffer at pH 3.5. A) ThT assay run in triplicate using 150 µM GLP-1 in 25 mM citrate buffer at pH 3.5. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation/filtration (B), as well as after 6 (C), 23 (D), 30 (E) and 144 (F) h. Note, sample shown in F was diluted to ~50 µM before imaging. Figure 3.11. AFM images and analysis of the height and width of GLP-1 aggregates formed in citrate buffer at pH 3.5. AFM images of GLP-1 aggregates formed in citrate at pH 3.5 illustrating the sections of the fibrils analysed. The profiles were analysed using the AFM data analysis program Gwyddion. A) Short curly fibrils (Type s) imaged before the incubation at $t = 0$ h. Indicated are the six positions on the fibrils where a height/width profile was measured. B) AFM image recorded after 6 h indicating the nine places where profile measurements were taken on Type a fibrils. C) AFM image after 30 h of incubation indicating the six positions on the Type e fibrils where profiles were measured. D) AFM image after 143 h showing Type d, e and f fibrils and the six positions on the fibrils where profiles were measured. E) Complete plot of fibril profiles of different fibril types (Type s, a, c, e & f) taken between 0 and 143 h. See Table 3.1 and Table 3.2 for further details. Figure 3.12. AFM images of GLP-1 species formed at different time points during peptide aggregation in phosphate buffer at pH 3.5. A) ThT assay run in triplicate using 150 µM GLP-1 in 25 mM phosphate buffer at pH 3.5 and at 37 °C. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation/filtration (B), as well as after 3 (C), 8 (D), 48 (E) and 143 (F). Samples in (F) were diluted to ~50 µM before imaging. Measurement of height and width of fibrils shown in Figures 3.12B, D, E & F and 3.13A-D. The profiles were analysed using the AFM data analysis program Gwyddion. A) AFM image of short curly fibrils (Type s) imaged before incubation. The six positions used to calculate the height/width of the fibrils are shown. B) AFM image of aggregates after 6 h of incubation (Type b). Shown are the six positions used to measure the height/width of the fibrils. C) AFM image of aggregates (Type c) after 48 h of incubation. The six positions used to measure the height/width of the fibrils are shown. An AFM artefact most likely causes the double peak. D) AFM image after 143 h incubation (Type c). The six positions used to measure the height/width of the fibrils are shown. E) Complete plot of fibril profiles of different fibril types (Type s, b, & c) taken between 0 and 143 h. See Table 3.1 and Table 3.2 for further details. It is interesting to note that the ThT assay used to assess the aggregation of the samples of GLP-1 in phosphate buffer at pH 3.5 for the AFM experiments shows some differences in lag time compared to previous measurements in phosphate buffer at pH 3.5. The differences are most likely caused by the disturbance of the aggregation process resulting from the opening and closing of the plate reader during the sampling, as well as inserting a pipette to remove sample. The aggregation of two samples of GLP-1 was also measured at pH 6.5, a pH close to the pI of GLP-1 (Figure 3.5C) and, in this case, no increase in ThT fluorescence even after the 140 h of incubation was observed, Figure 3.14A. AFM images were taken at the beginning and at the end of ThT assay to confirm that fibrils had not formed, Figure 3.14B & C. Figure 3.14. AFM images of GLP-1 species formed at different time points during peptide aggregation in phosphate buffer at pH 6.5. A) ThT assay run in duplicate of 150 µM GLP-1 in 25 mM phosphate buffer at pH 6.5 and 37 °C. Triangles indicate timepoints at which AFM samples were taken. B and C) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The AFM was taken within one hour after sample/preparation filtration (B) and after 144 (C) hours. At pH 7.5, immediately after sample preparation, samples of GLP-1 contained small, thin and curly fibril-like structures (Type s), Figure 3.15B. These had heights of $1.2 \pm 0.1$ nm and widths of $12 \pm 1$ nm, and were smaller than their curly counterparts under acidic conditions, Figure 3.16A. At the end of the lag phase, the thin curvy structures convert to short and straight fibrils, Figure 3.15C. They have profiles that are typical of fibrils of Type b, Figure 3.16B. The short and straight fibrils of Type b most likely grow and form the mature fibrils of Type c to f, which are present in the samples taken from the midpoint of the growth phase, at the start of the plateau phase and at the end of the aggregation assay, Figure 3.15D-F. At the start of the aggregation reaction, at pH 8.2, small oligomeric species (Type o) were observed with diameters of $33 \pm 3$ nm and heights of $1.9 \pm 0.2$ nm, Figures 3.17B and 3.18A. After 5 hours, these species vanish and short fibrils (Type b) appear, Figures 3.17C and 3.18B. The distribution and pattern of the aggregates suggests that this species is the predecessor of the short fibrils and, therefore, an on-pathway species, Figure 3.18A & B. After an additional four hours, these short fibrils grew only moderately in terms of height whilst their widths decreased and a few longer fibrils appeared, Figure 3.17D. The fibrils observed in the growth phase and in the plateau appear region appeared rigid, Figure 3.17E & F, and were similar to the fibrils observed at late time points for GLP-1 at pH 3.0, 3.5 and 7.5. Figure 3.15. AFM images of GLP-1 species formed at different time points during peptide aggregation in phosphate buffer at pH 7.5. A) ThT assay run in triplicate using 150 µM GLP-1 in 25 mM phosphate buffer at pH 7.5 and 37 °C. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation/filtration (B), as well as after 11 (C), 23 (D), 35 (E) and 145 (F) h. Figure 3.16. AFM images and analysis of the height and width of GLP-1 aggregates incubated in phosphate buffer at pH 7.5. Measurement of height and width of fibrils shown in Figures 3.15B-F and 3.16A, B & D. The profiles were analysed using the AFM data analysis program Gwyddion. A) AFM image of aggregates of GLP-1 before incubation (Type s). The six positions where profiles were measured are shown. B) AFM image after 11 h of incubation (Fibril b). The six positions where profiles were measured are shown. (C) Plot of the height/width profiles of fibrils measured using data shown in panel (B). The height/width of the fibrils was measured above the blue shaded plateau. D) AFM image of aggregates formed after 143 h incubation. The six positions where profiles were measured are shown. E) Complete plot of fibril profiles of different fibril types (Type s, b, c, d, e & f) taken between 0 and 145 h. See Table 3.1 and Table 3.2 for further details. Figure 3.17. AFM images of GLP-1 species formed at different time points during peptide aggregation in Tris buffer at pH 8.2. A) ThT assay run in triplicate of 150 µM GLP-1 in 25 mM Tris buffer at pH 8.2. Triangles indicate timepoints at which AFM samples were taken. B)-F) 3x3 µm AFM pictures with inverse colour scheme (nm). Inset scale bar is 0.5 µm. The first time point was taken within one hour after preparation/filtration (B), as well as after 5 (C), 9 (D), 21 (E) and 94 (F) h. Figure 3.18. AFM images and analysis of height and width of GLP-1 aggregates incubated in Tris buffer at pH 8.2. Measurement of height and width or diameter of small oligomers and fibrils shown in Figures 3.17B, C, D & F and 3.18A-D. The profiles were analysed using the AFM data analysis program Gwyddion. A) AFM image of GLP-1 aggregates (Type o) before the incubation. The six positions where profiles were measured are shown. B) AFM image after five h of incubation showing fibrils of Type b. The six positions where profiles were measured are shown. C) AFM image of intermediate fibrils imaged after nine h of incubation (Type c). The six positions where profiles were measured are shown. D) AFM image of thick fibrils (Type c) observed after 94 h incubation. The six positions where profiles were measured are shown. E) Complete plot of fibril profiles of different fibril types (Type o, b, & c) taken between 0 and 94 h. See Table 3.1 and Table 3.2 for further details. \| Time point (h) \| Fibril type \| Height (nm) \| Height SD (nm) \| Width (nm) \| Width SD (nm) \| \|---------------\|-------------\|-------------\|----------------\|------------\|---------------\| \| Citrate buffer pH 3.0 \| \| \| \| \| \| \| 4 \| a \| 1.2 \| 0.1 \| 14.9 \| 1.6 \| \| 4 \| b \| 1.9 \| 0.2 \| 16.7 \| 1.2 \| \| 4 \| c \| 2.8 \| 0.2 \| 17.9 \| 1.2 \| \| 4 \| d \| 4.8 \| 0.2 \| 21.8 \| 1.6 \| \| 7 \| c \| 2.9 \| 0.2 \| 12.9 \| 0.7 \| \| 7 \| d \| 4.3 \| 0.1 \| 14.0 \| 0.7 \| \| 7 \| e \| 7.6 \| 0.5 \| 19.4 \| 1.8 \| \| Phosphate buffer pH 3.0 \| \| \| \| \| \| \| 2.5 \| c \| 2.7 \| 0.3 \| 17.3 \| 2.1 \| \| 2.5 \| d \| 4.1 \| 0.3 \| 17.9 \| 2.0 \| \| 7 \| e \| 5.6 \| 0.5 \| 27.5 \| 2.1 \| \| Citrate buffer pH 3.5 \| \| \| \| \| \| \| 0 \| s \| 2.2 \| 0.1 \| 15.4 \| 1.3 \| \| 6 \| a \| 1.5 \| 0.2 \| 13.7 \| 1.3 \| \| 6 \| c \| 3.0 \| 0.2 \| 14.6 \| 0.5 \| \| 6 \| e \| 5.6 \| 0.7 \| 23.4 \| 1.5 \| \| 23 \| c \| 2.5 \| 0.3 \| 12.9 \| 1.6 \| \| 23 \| e \| 5.9 \| 1.0 \| 17.0 \| 0.8 \| \| 30 \| e \| 6.0 \| 0.6 \| 17.6 \| 0.6 \| \| 143 \| d \| 3.6 \| 0.0 \| 12.4 \| 0.2 \| \| 143 \| e \| 8.1 \| 0.8 \| 17.7 \| 0.2 \| \| 143 \| f \| 10.8 \| 0.8 \| 24.3 \| 2.9 \| \| Phosphate buffer pH 3.5 \| \| \| \| \| \| \| 0 \| s \| 2.8 \| 0.4 \| 14.3 \| 3.3 \| \| 8 \| b \| 1.6 \| 0.3 \| 16.6 \| 1.2 \| \| 48 \| c \| 3.0 \| 0.4 \| 21.1 \| 0.7 \| \| 143 \| c \| 3.4 \| 0.1 \| 13.6 \| 0.5 \| \| Phosphate buffer pH 7.5 \| \| \| \| \| \| \| 0 \| s \| 1.2 \| 0.1 \| 12.1 \| 1.2 \| \| 0 \| s \| 1.7 \| 0.1 \| 11.1 \| 0.9 \| \| 11 \| b \| 1.6 \| 0.1 \| 16.2 \| 1.1 \| \| 11 \| b \| 1.6 \| 0.4 \| 26.2 \| 1.0 \| \| 23 \| c \| 3.0 \| 0.2 \| 16.2 \| 0.2 \| \| 23 \| e \| 6.6 \| 0.4 \| 29.9 \| 1.1 \| \| 35 \| b \| 2.5 \| 0.2 \| 20.9 \| 2.6 \| \| 35 \| d \| 4.1 \| 0.5 \| 22.5 \| 0.5 \| \| 35 \| e \| 7.2 \| 0.6 \| 21.2 \| 0.3 \| \| 35 \| f \| 15.0 \| 1.1 \| 27.0 \| 1.1 \| \| 143 \| d \| 4.2 \| 0.2 \| 18.2 \| 0.7 \| \| 143 \| e \| 7.3 \| 0.3 \| 21.1 \| 0.6 \| \| 143 \| f \| 15.4 \| 0.4 \| 27.7 \| 0.3 \| \| Tris buffer pH 8.2 \| \| \| \| \| \| \| 0 \| o \| 1.9 \| 0.2 \| 33.0 \| 2.5 \| \| 5 \| b \| 1.8 \| 0.1 \| 14.3 \| 1.2 \| \| 9 \| b \| 1.7 \| 0.2 \| 12.0 \| 0.4 \| \| 9 \| c \| 2.4 \| 0.3 \| 15.4 \| 0.2 \| \| 94 \| c \| 3.1 \| 0.2 \| 35.1 \| 4.0 \| Table 3.1. Heights and widths of different fibril profiles. The values for the height and width were determined from the fibril profiles using a Gaussian fit. The width of the fibril is equivalent to the FWHM of the Gaussian. \| \| pH 3.0 \| pH 3.5 \| pH 7.5 \| pH 8.5 \| \|----------------\|------------------------------------------------------------------------\|------------------------------------------------------------------------\|------------------------------------------------------------------------\|------------------------------------------------------------------------\| \| Buffer \| Phosphate buffer (PB): Approx. round spots with a diameter of 15-100 nm and a height of 1-10 nm \| Few impurities or contaminations \| Few impurities or contaminations, < 2 nm width \| \| Data not shown \| \| \| \| \| \| t < 1h \| Citrate buffer (CB): No fibrils \| CB: Type s, curly, ring-like structures, height ~2.5 nm, width ~15 nm, length 50 – 400 nm, clumping. PB: similar as in CB. \| Type s, 50-500 nm length, curly, clumping Values of height (~1.5 nm) and width (~12 nm) smaller than for Type s at pH 3.5. \| Oligomer-like structures ~33 nm diameter, ~2 nm height. \| \| \| PB: No fibrils \| \| \| \| \| Lag phase \| CB: Mainly curved fibrils, Type a, b, c, and d, with branches, non-sticky. Length 1-3 µm \| CB: Mainly curved, Type A, with branches, clumping. PB: Amorphous structure. \| Short straight fibrils, Type b \| Transition from oligomer-like structure to short straight fibrils of Type b \| \| \| PB: Amorphous structure. \| \| \| \| \| End of Lag phase \| CB: Mainly straight fibrils Type c, d, and e. Tightly packed, don’t stick, not twisted \| CB: Long and curved fibrils, Type c and e \| Type c, and e 0.25-3.0 µm length, straight, twisted: ~0.27 µm per turn \| Mainly fibrils of Type b, ~ 30-200 nm length. Very few Type c. straight. \| \| \| PB: Type c, 1-10 µm length, curvy, clumping \| \| \| \| \| Midpoint / t = 0 plateau \| CB: t = 0 plateau: Type e, straight, not twisted, Dense mash. PB: t = 0 plateau: Type e, 2-3 µm length, curled and straight mixed, clumping. \| PB: Midpoint: straight, Type c, length ~1 µm \| t = 0 plateau: Type c, d, e, and f. >9 µm length, straight, twisted, no clumping, stick to each other \| \| \| \| \| \| \| \| \| t = final plateau \| CB: Straight, Type e, Dense mesh. PB: Dense mesh, Type c or thicker, straight, clumping. \| CB: Type c, e, and f, twisted. \| Dense mesh, straight, sticky. \| Type c and multiples of it. Width 45-55 nm, hight 6-10 nm, length ~ 9 µm, straight \| \| \| \| \| \| \| Table 3.2. Description of GLP-1 aggregates imaged by AFM under different conditions. Different peptide aggregates are defined as oligomer-like aggregates (Type o), curly and tangled fibril-like aggregates (Type s) and fibrils with a height of 0.5 - 1.5 nm (Type a), 1.5 - 2.5 nm (Type b), 2.5 - 3.5 nm (Type c), 3.5 - 5 nm (Type d), 5 - 10 nm (Type e) and >10 nm (Type f). 3.4.2 Disturbance of Aggregation Kinetics The aim of the time-course experiments was to follow the aggregation kinetics of GLP-1 under different pH and buffer conditions. However, taking samples during a ThT assay introduces some disruption to the system which might influence the kinetics of peptide aggregation. The samples for AFM imaging were taken using a pipette which induced a gentle mixing of the samples and every time point involved an opening and closing of the plate reader. To learn more about the influence of these factors, the ThT assay data in Section 3.4.1 were analysed using a sigma function (Equation 2.5) and compared to the expected lag times of undisturbed samples, Figure 3.2A & B. The data shows that under neutral and basic conditions, the aggregation kinetics are in good agreement with the expected lag times of undisturbed samples, Figure 3.19. At pH 7.5 the lag time is most influenced by sample removal and significantly shorter, Figures 3.17A and 3.19. ![Figure 3.19](image) Figure 3.19. Assessment of the effect of sampling on GLP-1 aggregation kinetics. Comparison of lag times of GLP-1 aggregation measured under different conditions. All measurements were conducted in 25 mM buffer, at 37 °C and in triplicate. Kinetics measured with disruption from sample acquisition for AFM experiments are shown as solid green circles (phosphate), solid red squares (citrate), and solid blue diamonds (Tris). Lag times calculated from a kinetic run which was completely undisrupted by sample removal and opening/closing at pH 3.0 are shown as a solid green triangle. Lag times for aggregation at pH 7.5 and 8.2, during which the plate reader was opened and closed but for which no sample was removed are shown as an open green circle (phosphate) and open blue triangle (Tris), respectively. Reference measurements (no sample removal and no opening/closing) are shown as a solid black circle (phosphate), triangle (Tris) and square (citrate). The error bars show the standard deviation of a triplicate measurement. Under acidic conditions, the lag times of GLP-1 aggregation in phosphate buffer at pH 3.0 and 3.5, are influenced by sample removal and show different aggregation kinetics compared to the reference data, Figures 3.8A and 3.19. Interestingly, the kinetics of GLP-1 aggregation in citrate buffer at pH 3.0 shows nearly no influence of sample removal, whereas at pH 3.5 they are affected, Figure 3.19. ### 3.4.3 Changes in Secondary Structure During Aggregation Far-UV CD and FT-IR time-course experiments were undertaken to elucidate the change in the secondary structure during the aggregation process. To enable the measurement of the FT-IR spectra under acidic conditions, phosphate buffer was used as citrate is known to absorb in the infrared in the same range as GLP-1. The samples for the far-UV CD and FT-IR measurements were taken at the same time and from the same plate as that used for the acquisition of samples for the AFM experiments. The change in secondary structure was probed by far-UV CD and FT-IR at two or four different pH values, respectively, and compared with the lag time measured from the ThT assays under the same conditions, Section 3.4.2. At all the pH values studied, there is an overall change from secondary structures containing both $\alpha$-helical and $\beta$-sheet structure to one that is largely $\beta$–sheet in nature at the end of the aggregation reaction as expected for the conversion of monomeric GLP-1 into amyloid fibrils. Figure 3.20 shows the results of far-UV CD measurements at different time points during the aggregation of GLP-1 at pH 3.0 and 3.5 in 25 mM phosphate buffer. These experiments show how the main change in secondary structure of GLP-1 occurs after the lag phase and during the growth phase. Figure 3.20. Changes in secondary structure in GLP-1 during peptide aggregation at pH 3.0 and 3.5 in phosphate buffer shown by far-UV CD. Far-UV CD spectra of 150 µM GLP-1 measured at 25 °C. The x-axis and y-axis show the wavelength (nm) and the molar ellipticity ($10^3 \cdot \text{deg} \cdot \text{cm}^2 \cdot \text{dmol}^{-1}$), respectively. The different colours represent different time points in hours. The measured lag time is shown in red. Time points showing the first major changes of the secondary structure are shaded in blue. A) 25 mM phosphate buffer pH 3.0. B) 25 mM phosphate buffer pH 3.5. FT-IR spectra were recorded at different time points during aggregation at pH 3.5, Figure 3.21A & B, and the data indicate an even later shift from $\alpha$-helical to $\beta$-sheet structure between 8 and 23 h instead of 6 to 8 h, as seen in the far-UV CD data, Figure 3.21B. At pH 7.5, FT-IR measurements show that the major change in secondary structure occurs after the lag time and during the growth phase, Figure 3.21C. These results are in good agreement with the previously conducted far-UV CD time-course measurements, Figure 1.22C. In contrast, at pH 8.2, major changes in secondary structure occur earlier and within the lag phase, Figure 3.21D. Again, this is in good agreement with the earlier far-UV CD time-course measurements conducted by Dr Karolina Zapadka, Figure 1.22D. Figure 3.21. Changes in secondary structure in GLP-1 during peptide aggregation at different pHs shown by FT-IR. FT-IR spectra of 150 µM GLP-1 measured at different time-points. The x-axis and y-axis show the wavenumber (cm$^{-1}$) and the absorbance (normalised), respectively. The different colours represent different time points in hours. The measured lag time is shown in red. Time points showing the first major changes of the secondary structure are shaded in blue. A) 25 mM phosphate pH 3.0. B) 25 mM phosphate pH 3.5. C) 25 mM phosphate, pH 7.5. D) 25 mM Tris, pH 8.2. An SVD analysis of the far-UV CD and FT-IR data was performed in order to assess whether any species with secondary structure significantly different to either the monomer or fibril could be identified, and its spectrum elucidated. In all conditions, the SVD analysis demonstrates that the spectra obtained at different time points during the aggregation reaction can be deconvoluted mainly into two spectra. Typical examples of single-value deconvolution of the far-UV CD and FT-IR data are shown in Figures 3.22 and 3.23, respectively. In both cases, the data of GLP-1 at pH 3.0 at nine different time points are shown. The far-UV CD spectra in Figure 3.22A can be deconvoluted mainly into two spectra. The first, Figure 3.22B, represents the fibrillar end point, and the second represents the starting monomer, Figure 3.22C. For the FT-IR spectra, the data can be deconvoluted mainly into two spectra, however, in this case, it is not possible to assign these two spectra to the monomer or fibrillar end point. Here, the first spectrum represents an average of both states, Figure 3.23B, and the second spectrum describes the change needed to get from the monomer to the fibrillar end point, Figure 3.23C. The fact that the first component shows an average value is most likely because the difference of the spectra is relatively symmetric between both states. The cumulative percentages of SVD components of the far-UV CD and FT-IR spectra are shown in Figure 3.24. At pH 3.0 and 8.5, the SVD analysis of the far-UV CD data shows that the system is over 90% determined by two-states, whilst at pH 3.5 and 7.5, the values are slightly lower than this. This suggests that the system populates another state under these conditions, although not to a very high level, Figures 3.22 and 3.23D. The SVD analysis of the FT-IR data shows an even higher percentage for the sum of the first two SVD components but still lower values at pH 3.5 and 7.5 in comparison to the samples at pH 3.0 and 8.5. However, even if the system can be described by only two sigma and their vectors, this does not mean that there are no oligomeric species present, just that, if they become significantly populated that their spectra must be similar to either that of monomer or fibril. In general, both datasets, far-UV CD and FT-IR, show high cumulative percentages already for the first sigma. The value of the first sigma of FT-IR is even higher in comparison to the first sigma of far-UV CD. This is most likely because the FT-IR data also includes a contribution from the buffer. A subtraction of the buffer spectrum was not possible due to the drying process and unknown amounts of buffer on the observation plate in the instrument. Figure 3.22. Singular value decomposition of the far-UV CD spectra of GLP-1 at pH 3.0 at different times during aggregation. Singular value decomposition of the far-UV CD spectra of 150 µM GLP-1 in 25 mM phosphate buffer at pH 3.0, measured at nine different time points. A) Complete far-UV CD spectra. B) The first component of the analysed far-UV CD spectra. The data were calculated by multiplying U·Σ·V$, with all values in Σ set to 0 except σ₁. The first component represents the far-UV CD spectra measured for aggregated GLP-1. C) The second component of the CD spectra is calculated as in B but with σ₂ as sole value instead of σ₁. The spectra represent the monomer/non-aggregated structure of GLP-1. D) Calculated third component based on σ₃. All components higher than the third show values close to 0 (data not shown). Figure 3.23. Singular value decomposition of FT-IR spectra of GLP-1 at different time points during aggregation at pH 3.0. Singular value decomposition of FT-IR spectra of 150 µM GLP-1 in 25 mM phosphate buffer at pH 3.0, measured at nine different time points. A) Complete FT-IR spectra. B) The first component of the analysed FT-IR spectra. The data was calculated by multiplying $U \cdot \Sigma \cdot V^$, with all values in $\Sigma$ set to 0 except $\sigma_1$. The first component represents an FT-IR spectra showing average spectra for non-aggregated and aggregated GLP-1 peptide structure. C) The second component of the FT-IR spectra is calculated as in B but with $\sigma_2$ as sole value instead of $\sigma_1$. The spectra represent the change between monomer/non-aggregated and aggregated structure of GLP-1. D) Calculated third component based on $\sigma_3$. All components higher than the third show values close to 0 (data not shown). Figure 3.24. Cumulative percentage of single-value decomposition (SVD) components. A) Cumulative percentage of SVD components of far-UV CD spectra. 150 μM GLP-1 in 25 mM buffer measured at 25°C. The measured samples were aggregated in phosphate buffer at pH 3.0, phosphate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.5. B) Cumulative percentage of SVD components of FT-IR spectra. 150 μM GLP-1 in 25 mM buffer measured at 25 °C. The measured samples were aggregated in phosphate buffer at pH 3.0, phosphate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.5. 3.4.4 Size of GLP-1 Aggregates in Solution To elucidate the size of the aggregates formed during GLP-1 aggregation, DLS measurements were performed at the same time points as the AFM, far-UV CD and FT-IR data. The conducted measurements at pH 3.0, 3.5 and 6.5 were used together with previous data obtained for GLP-1 at pH 7.5, 7.7 and 8.2\textsuperscript{5} to establish how the size of species varies over time over a wide range of pH values. It is essential to mention that the data are presented as both intensity and number distributions. The intensity measurements have a stronger signal for larger particle sizes so tend to be dominated by these species, however, this measurement does not depend upon any model used. N.B., the Zetasizer software calculates the number distribution based on the intensity distribution using assumptions about the samples' shape, density, and optical properties. Throughout this section measurements given are for the diameter of species present. Freshly prepared samples of GLP-1 at pH 3.0, show a peak corresponding to monomer and possibly small oligomers at 5-6 nm, in addition to a peak indicating species with a size of approx. 1000-2000 nm caused by a small number of particles which scatter the light with high intensity. Still, the smaller molecular weight peak represents only 5-10% of the sample concentration and disappears completely after the first measurement, presumably as monomers and small oligomers are converted into larger aggregates and ultimately fibrils. In general, there are large differences between the single measurements at different time points, Figure 3.25A & B. This is most likely caused by ongoing aggregation reactions of the samples which are not at equilibrium or simply the settlement of the aggregates at the bottom of the cuvette during the measurement. To be consistent with the previous experiments, 150 µM GLP-1 was used, and it should be noted that this is lower than the optimal concentration needed for DLS measurements and this may also contribute to the variation in signal between time points. At pH 3.5, the first peak of the earliest time points shows even smaller particles around 3-4 nm, which corresponds with approximately 5% of the total peptide concentration. Additionally, larger particles are also present. They have a diameter of about 50-200 nm, tenfold smaller than the larger aggregates observed at pH 3.0. After 3, 6 and 8 h smaller aggregates can be observed, with diameters of approximately 10 - 100 nm, Figure 3.25C & D. At pH 6.5, two measurements were conducted. Immediately after the peptide was dissolved and filtered, the intensity data shows species and aggregates around 3-4 and 50-200 nm. After the ThT assay (144 h), during which no increase of ThT fluorescence was observed, the monomer/dimer peaks vanish and the number of larger aggregates between 30 and 700 nm increases. Additionally, a few aggregates with diameters larger than 2000 nm are present, Figure 3.25E. At time point zero the majority of the aggregates are between 3-4 nm and after the ThT assay between 20-80 nm, Figure 3.25E. In general, it is assumed that the smaller molecular weight species between 2 – 6 nm are most likely monomer or dimer, and this is only observed for the first measurement of the freshly dissolved peptide solution. This is similar to the findings for GLP-1 at pH 7.5, 7.7 and 8.2.\textsuperscript{5} These results suggest that the monomer/dimer rapidly converts into other species. At pH 3.5, the data at time points within the lag phase, show large numbers of oligomeric-like aggregates around 10 – 100 nm. Similarly sized oligomeric-like aggregates (20 – 100 nm) were found at pH 6.5 at the end of the ThT assay. As the results of the AFM and ThT assays showed no evidence for fibrillar species, this suggests that the oligomeric-species observed at both pH 3.5 and 6.5 are related and likely to be off-pathway, not converting directly into amyloid fibrils. At pH 6.5, both these species are highly stable and do not convert back into monomer, on-pathway species or fibrils. Alternatively, fibrils may not be stable under these conditions. Figure 3.25. Results of DLS measurements to determine the size of GLP-1 species in solution at different time points during aggregation. DLS measurements of 150 µM GLP-1 A) Intensity vs. size of particles (diameter) in 25 mM phosphate buffer at pH 3.0. B) Number of particles vs. size of particles (diameter) in 25 mM phosphate buffer at pH 3.0. A & B) Time points taken after 0 h (dark red), 3 h (red), 6 h (dark orange), 8 h (orange), 21 h (dark green), 25 h (bright green), 30 h (bright blue), 122 h (blue) and 143 h (dark blue). C) Intensity vs. size of particles (diameter) in 25 mM phosphate buffer at pH 3.5. D) Number of particles vs. size of particles (diameter) in 25 mM phosphate buffer at pH 3.5. C & D) Time points taken after 0 h (dark red), 3 h (red), 6 h (dark orange), 8 h (orange), 23 h (dark green), 30 h (bright green), 48 h (bright blue) and 144 h (blue). E) Intensity vs. size of particles (diameter) in 25 mM citrate buffer at pH 6.5. F) Number of particles vs. size of particles (diameter) in 25 mM citrate buffer at pH 6.5. E & F) Time points taken after 0 h (red) and 141 h (black). 3.5 Discussion Problems associated with the physical stability of many potentially otherwise very efficacious therapeutic peptides has hindered or prevented their use in the clinic. Amongst other forms of physical instability, many peptides are known to form amyloid-like fibrils at their high formulation concentrations. In order to be able to better develop peptide-based drugs with improved physical stability profiles, a better understanding of the underlying mechanisms of aggregation and amyloid formation are required. The therapeutic peptide GLP-1 has been shown to form amyloid fibrils and this has been studied in detail at pH 7.5-8.2.$^5$ An unusual change in the aggregation kinetics between pH 7.5 and 8.2 has been attributed to the population of off-pathway oligomers at pH 7.5, in addition to the on-pathway oligomers which convert into the amyloid fibrils. There is increasing evidence for, and awareness of, off-pathway species,$^{5,89,130,343–349}$ however, few detailed studies of such species and their impact on aggregation kinetics have yet to be published. Following on from the work on GLP-1 at pH 7.5 - 8.2, here an investigation of the physical stability of GLP-1 at basic, neutral and acidic pH values is reported. The focus was on time-course measurements during which a number of biophysical techniques were employed that report on the structure and size of species in solution at various times during the aggregation reaction. The objectives of the study were two-fold, i) to understand in more detail the conditions in which off-pathway species become significantly populated in order for us to better understand the nature of these species, and ii) to gain further information on species present in solution at different time points under conditions which favour the population of on- and off-pathway oligomers, particularly focussing on processes that occur within the lag time. 3.5.1 Physical Evidence for Off-Pathway Oligomeric Aggregates The unusual concentration dependence of GLP-1 aggregation kinetics at pH 7.5 has been previously explained by the influence of off-pathway oligomeric aggregates.$^5$ The experiments in this Chapter were conducted to understand why such an unusual behaviour can be found not only at pH 7.5 but at pH 3.5 suggesting that off-pathway oligomers are also populated under acidic conditions at pH 3.5, but interestingly not at pH 3.0. For both pH 3.5 and 7.5, the study also reveals further evidence for off-pathway species. For example, analysis of the far-UV CD and FT-IR data with SVD showed that an additional species with characteristics different to either the monomer and fibrils is more evident and populated at pH 3.5 and 7.5 in comparison to pH 3.0 and 8.2. In addition, and based on the results of the AFM experiments, results suggest that such a putative off-pathway oligomer may be the short and curly fibril-like aggregates observed at early time points at some pH values. These species appear to have hydrodynamic radii of about 20-80 nm as observed by DLS at pH 3.5 and 6.5. ### 3.5.2 Characteristics of GLP-1 Aggregates and Fibrils Formed Under Acidic and Basic Conditions. As mentioned in the previous section, short and curly fibril-like species have been seen under both conditions known to show off-pathway behaviour. Under acidic conditions, the curly fibril-like aggregates are thicker in comparison to the thinnest types of fibrils observed in the same sample, consistent with the idea that these aggregates are off-pathway because they would have to undergo dissociation and a significant change in structure to transform them into the thinnest types of fibrils observed. While showing the same characteristics as the short curly fibrils formed under acidic conditions, the dimensions of the curly fibril-like aggregates imaged at neutral pH are thinner than the curly fibril-like aggregates imaged at pH 3.5. Their dimensions are similar to the height and width of the observed thin fibrils at pH 7.5. Although these aggregates are similar in width to other fibrils formed, they are still likely to be off-pathway, as again they would need to undergo a structural transformation in order to form the more rigid structure adopted by fibrils. The aggregation of GLP-1 under basic conditions (pH 8.2) follows kinetics typical of a nucleation-elongation mechanism. The AFM data suggests that the nucleation may occur in small on-pathway, oligomer-like aggregates with a diameter slightly bigger than the width of the fibril formed from the nucleus. In general, during the lag phase and partly at the beginning of the growth phase, several different sized fibrils have been detected, for example, at pH 3.0. Their dimensions suggest that fibrils are multiples of the thinnest fibril type, Type a, which is possibly a protofibril. Fibrils of Type b are most likely formed from two Type a species. The number of protofibrils in fibrils of Type b, c and d is estimated to be 2, 4, and 8, respectively. However, it cannot be excluded that some fibrils are formed from different numbers of protofibrils. As fibrils of Type c and e appear under most or even all pH conditions, it is reasonable to speculate that all fibrillar species share the same overall assembly pattern. ### 3.5.3 Challenges and Further Results from the Time-Course Measurements The time-course measurements lead to important insights regarding the nature of the aggregates formed by GLP-1 and the changes in secondary structure during the aggregation process. However, especially under acidic conditions, it is evident that the removal of samples for the AFM and other measurements has an influence on the aggregation. Additionally, it cannot be excluded that the phosphate buffer shows different behaviour than the citrate buffer. While the aggregates formed in citrate or phosphate buffer were similar, the measured lag times showed some differences. These all make it more challenging to draw conclusions from the data collected under acidic conditions. The data recorded under neutral and basic conditions is, in contrast, more reliable. At pH 7.5, the secondary structure stays in the $\alpha$-helical conformation during the whole lag phase, suggesting that off-pathway oligomers formed may have $\alpha$-helical structure. In the basic regime, the secondary structure changes early from $\alpha$-helical to $\beta$-sheet, this transformation happens even before the lag time and before any significant ThT signal was observed. These results suggest that an intermediate, non-fibrillar species which has considerable $\beta$-sheet content but which cannot bind to ThT is populated. 3.5.4 The Relationship Between Aggregation Propensity and pI and Net Charge The aggregation kinetics show that the lag time for fibril formation at pH 3.0-3.5 varies between 5 and 30 h and the half times vary from 10-40 h, depending upon pH and peptide concentration, Figures 1.17 and 1.18. These values are comparable to those measured at pH 7.5-8.2. The approx. net charge GLP-1 carries under these conditions is +3 to +4 at low pH, compared to -1 to -2 under slightly basic conditions. Despite having higher net charge values under acidic conditions, collectively, the results of the aggregation assays conducted at different pH values show that there is some symmetry in the behaviour, i.e., aggregation propensity, lag time and peptide concentration dependence, around the pI value of GLP-1. The simplest explanation of this phenomenon is that off-pathway oligomers which affect the kinetics are populated close to the pI, i.e., under conditions where the net charge on the peptide is close to zero. It is interesting to note that at pH 6.5, the pH closest to the pI, GLP-1 appears to populate off-pathway species that do not convert into fibrils as no fibrils were detected either by ThT fluorescence or in AFM imaging. 3.5.5 Conclusions In summary, the extensive study of GLP-1 presented here has led to a more detailed understanding of the aggregation kinetics of GLP-1 under several conditions. Starting from the observation that the unusual peptide concentration dependence of the aggregation kinetics is not restricted to neutral and basic conditions but can also be found under acidic conditions, it can be concluded that off-pathway oligomer formation occurs at pH 3.5, 6.5 and 7.5. Time-course studies at these pH values reveal the possible structure of these oligomers. As there were no observed changes in secondary structure during the lag phase and before there is any significant ThT fluorescence under these conditions, this suggests that this type of oligomer has $\alpha$-helical structure. The pH range over which there is evidence of off-pathway oligomer formation suggests that off-pathway oligomers are populated under conditions close to the pI of the peptide and therefore that net charge plays a significant role in determining the species formed (on versus off-pathway oligomers) and therefore the rate of aggregation. 4 THE INFLUENCE OF C-TERMINAL AMIDATION ON THE PHYSICAL STABILITY OF GLP-1 4.1 Introduction The physical stability of therapeutic peptides and proteins is of great importance as their physical instability, i.e., their tendency to self-associate into aggregated states, is a significant problem for the pharmaceutical industry. In previous work, it was shown that the kinetics of aggregation of GLP-1 depends critically on pH and that a switch in aggregation mechanism takes place over a narrow pH range near pH 3 to 3.5 and pH 7.5 to 8. This has been attributed to a change in mechanism from one in which on-pathway oligomers dominate, to one in which off-pathway oligomeric species become populated and drastically affect the kinetic behaviour. In this Chapter, a detailed study on the effect of C-terminal amidation on the physical stability of GLP-1 is undertaken. The purpose of this study is to assess the influence of chemical modification, in this case the amidation of the C-terminus of a therapeutic peptide, on its physical stability. In comparison to other modifications, amidation represents a rather small change to the peptide and is often used in combination with other modifications. It is also found in naturally occurring peptides and, for some neuropeptides, amidation is crucial for their full biological activity.\textsuperscript{350} Here, the physical stability of GLP-1 and GLP-1 amidated at the C-terminus (Am-GLP-1) are compared and the differences and similarities in their physical stability highlighted. The focus is on their behaviour at different pH values and the peptide concentration dependence of their aggregation kinetics. Numerous biophysical measurements including ThT assay, far-UV CD, SEM, ANS and tryptophan fluorescence were used to gain insight into the mechanism of aggregation into amyloid fibrils and the nature of species populated during fibrillation under different conditions. 4.2 Molecular Weight and Purity of GLP-1 and Am-GLP-1 The molecular weight and purity of GLP-1 and Am-GLP-1 were determined using LC-MS measurements. The UV absorbance at 210 nm from the liquid-chromatography step shows a single narrow peak for both peptides, Figures 4.1A and 4.2A, indicating the samples have high purity. The same peak as observed with UV absorbance was observed in the total ion current (TIC) data, Figures 4.1B and 4.2B. However, both peptides also show additional smaller peaks at longer elution times. These observed ions do not absorb in the UV and are most likely hydrophobic in nature, hence the longer retention time. At the current time, the identity of these smaller peaks is not known, however, it is currently under investigation as part of a new PhD project within the Jackson group. From the mass spectrometry data, it is possible to calculate the molecular weight of the peptide from the measured m/z of the protonated peptide ions. The data shows that GLP-1 is mainly present as a +3 molecular ion (1119.42 m/z). Minor peaks can also be seen for the +4 molecular ion (839.72 m/z), and +2 molecular ion (1678.91 m/z). From these data, the determined molecular weight of GLP-1 is $3355.3 \pm 0.5$ Da which is in agreement with the theoretical value of 3355.66 Da as well as the molecular mass of 3355.71 Da measured using electrospray ionisation-mass spectrometry reported by Bachem, Figure 4.1. The mass spectrum of Am-GLP-1 is similarly to GLP-1 mainly present as a +3 molecular ion (1119.1 m/z), Figure 4.2. The other peaks represent the +5 molecular ion (671.87 m/z), +4 molecular ion (839.55 m/z), and +2 molecular ion (1678.43 m/z). The molecular weight determined is $3354.68 \pm 0.5$ Da which agrees with the theoretical value of 3354.68 Da as well as the relative molecular mass of 3354.93 Da obtained using electrospray ionisation-mass spectrometry by Bachem. Figure 4.1. LC-MS of GLP-1. A) UV absorbance signal at 210 nm. The peak at 0.79 min is caused by the injection of the sample. It is influenced by the different percentage of acetonitrile in the sample in comparison to the LC gradient as well as the presence of salt in the sample. The x-axis is given in minutes. B) Total ion current (TIC) chromatogram. The x-axis is given in minutes. C) Mass spectrum of peak eluting at 2.59 min. Figure 4.2. LC-MS of Am-GLP-1. A) UV absorbance signal at 210 nm. The peak at 0.79 min is caused by the injection of the sample. It is influenced by the different percentage of acetonitrile in the sample in comparison to the LC gradient as well as the presence of salt in the sample. The x-axis is given in minutes. B) Total ion current (TIC) chromatogram. The x-axis is given in minutes. C) Mass spectrum of peak eluting at 2.57 min. 4.3 The Influence of C-terminal Amidation on Peptide Solubility The solubility of Am-GLP-1 was measured and compared to that of GLP-1, and significant differences were observed. GLP-1 shows a minimum in solubility around pH 4.5 whilst for Am-GLP-1 it is around pH 7.5, Figure 4.3A. The observed minimum in solubility for Am-GLP-1 is much broader than the one observed for GLP-1 and stretches from pH 5.0 to 8.5 in comparison to pH 4.0 to 5.5 for GLP-1, Figure 4.3A. These differences are likely to be due to the difference in net charge as amidation results in the removal of the negative charge at the carboxy terminus at pH values above the p$K_a$ (2.3) of the C-terminal glycine carboxyl group. Figure 4.3B shows the net charge of GLP-1 and Am-GLP-1 at different pH values calculated using the Henderson-Hasselbalch equation and standard p$K_a$ and p$K_b$ values for N- and C-terminus and ionisable side chains. The details of the calculation are shown in Section 2.15 and Table 2.2. Ignoring other influences, such as changes in conformation, amidation of the C-terminus leads to a steady net charge difference of 1 between GLP-1 and Am-GLP-1 at most pH values until below pH 2.3 when the C-terminus of GLP-1 becomes protonated and the two peptides have the same net charge. It is also clear that the net charge curve for the two peptides cuts the zero net charge line at different positions and with different slopes, Figure 4.3B. It means that the data predicts the net charge of GLP-1 to be within a range between ± 0.5 from approx. pH 5.0 to 6.0 in comparison to the wider range of pH 6.0 to 9.0 in the case of Am-GLP-1. This correlates well with the solubility data for GLP-1 and Am-GLP-1 shown in Figure 4.3A. The pI values of GLP-1 and Am-GLP-1, calculated theoretically using standard p$K_a$ values, are 5.4 and 7.6, respectively and can be compared to the values determined experimentally using imaged capillary isoelectric focussing (iCIEF) shown in Figure 4.3C. For GLP-1, a pI of 5.9 was determined, which is in good agreement to the theoretical value of 5.4. In the case of Am-GLP-1, the difference between the calculated pI of 7.6 and the measured value of 6.8 is slightly larger. This difference may be due to the fact that Am-GLP-1 has a very broad minimum of net charge around the pI in comparison to GLP-1. Small alterations of the net charge, for example caused by changes in conformation, may therefore have a bigger influence on the pI. Figure 4.3. Solubility, net charge of Am-GLP-1 and GLP-1.* A) Peptide concentration measured after dissolving approximately 0.2 mg in 50 µL of buffer: GLP-1 (black closed circles) or Am-GLP-1 (grey closed squares). The open circles indicate a concentration of at least 1000 µM. The error bars show the standard deviation of three peptide concentration measurements. B) Calculated net charge versus pH based on the peptide amino-acid sequence and standard pKₐ values. Note the rather flat intersection of the net-charge curve of Am-GLP-1 and the zero value. C) pI measurement for Am-GLP-1 and GLP-1 using imaged capillary isoelectric focussing. 4.4 The Peptides Have a Lower Aggregation Propensity Close to Their pI Values The aggregation kinetics of the GLP-1 peptides were measured using a ThT assay. In Figure 4.4A & B, two three-dimensional aggregation landscapes are shown which are composed of ThT data measured over time at different pH values between pH 3.0 and 8.7 and where the peptide concentration was kept constant at 75 µM. These data allow one to quickly visualise the aggregation propensity of GLP-1 and Am-GLP-1 over a wide range of pH values giving a broad overview of the influence of pH on the aggregation behaviour of both peptides. There is a strong correlation between the net charge and solubility of the peptides and their propensity to aggregate. GLP-1 shows a minimum in aggregation around its pI and, as net charge and solubility increases between pH 5.5 and 7.5, this results in a shortening of the lag times. Am-GLP-1 also shows a similar relationship between net charge, solubility and aggregation propensity and has a minimum of aggregation between pH 6.0 and 8.2, which corresponds to the range in which the net charge on the peptide is between +0.5 and -0.5. Starting from these observations, four different pH values were chosen at which the aggregation of Am-GLP-1 was investigated in further detail. In particular, the effect of peptide concentration on the aggregation kinetics was measured thereby enabling us to compare it with our previously published data on GLP-1.$^5$ Figure 4.4. Aggregation landscapes for GLP-1 and Am-GLP-1. A) ThT assays of peptide aggregation for GLP-1 at 75 µM from pH 3.0 to 8.7 at 37 °C. The buffers are citrate (pH 3.0 - 6.0), phosphate (pH 6.5 – 7.5) and Tris (pH 7.7 – 8.7, 37 °C) with a buffer concentration of 25 mM. For each pH the results of triplicate runs are shown. The x-axis shows the pH value, z-axis time (h) and the y-axis ThT fluorescence (a.u.) where the signal between 0-500 is blue, 500-1000 (red), 1000-1500 (green) and 1500-2000 (purple). B) ThT fluorescence for Am-GLP-1 at 75 µM from pH 3.0 to 8.7 at 37 °C. For each pH the results of triplicate runs are shown. The axes are the same as in Figure 4.3C. 4.5 Aggregation Kinetics of Am-GLP-1: Peptide Concentration Dependence To learn more about the influence of the amidation of the C-terminus on the physical stability of GLP-1, kinetic aggregation assays were performed for Am-GLP-1 at different peptide concentrations. The aggregation kinetics were monitored using ThT fluorescence and all measurements were run in triplicate. and the experiments repeated at least two times on different days. The pH values were chosen taking into account the previous ThT fluorescence measurements on Am-GLP-1 (Figure 4.3), as well as the previous measurements conducted on GLP-1 at pH 3.0, 3.5, 7.5 and 8.2, Figures 3.1 and 1.17. Four pH values, 3.0, 4.0, 8.2 and 8.7, were chosen and measurements were performed at six different peptide concentrations between 25-150 µM, Figure 4.5A-D. In many cases, it was possible to describe and fit the ThT fluorescence data to a sigmoidal curve with a flat lag phase, a steep growth phase and a plateau. The kinetic parameters $t_{1/2}$ and $t_{\text{lag}}$ were determined from a standard sigmoidal fit of the data to Equations 2.4 and 2.5, respectively. Figure 4.5A shows the ThT aggregation data for Am-GLP-1 in 25 mM citrate buffer at pH 3.0 and both the lag time and $t_{1/2}$ decrease with increasing peptide concentration (Figure 4.6A & C) typical of a nucleation-polymerisation mechanism with predominantly on-pathway oligomers. It is interesting to note that at low peptide concentrations the data fit well to a sigmoidal function, however, at higher peptide concentrations the data fit less well. Data for Am-GLP-1 aggregation in citrate buffer at pH 4.0 are shown in Figure 4.5B. Under these conditions, the lag time and $t_{1/2}$ are independent of the peptide concentration, in contrast to the results obtained at pH 3.0. It is possible to explain these results by the population of off-pathway oligomeric species under these conditions, as has been shown for GLP-1 at pH 7.5. At pH 4.0, the ThT data shows some deviation from the standard sigmoidal behaviour. First, at low peptide concentrations, the growth phase of Am-GLP-1 shows two distinct regions – an initial very steep slope which changes to a slope that is less steep before the plateau region is reached, Figure 4.5E. In addition, at higher peptide concentrations, a linear increase in the baseline within the lag phase was observed before it changes over to the typical sigmoidal growth phase, Figure 4.5F. At intermediate peptide concentrations the aggregation can alternate between the two types of behaviour leading to a higher variance between runs, Figure 4.5B, than seen at pH 3.0. Figure 4.5. ThT aggregation assays of Am-GLP-1 at different peptide concentrations and pH values. All samples were measured at the following peptide concentrations: 25 µM (pink), 50 µM (orange), 75 µM (blue), 100 µM (dark blue), 125 µM (green), and 150 µM (dark green). The data were fitted with Equation 2.4, the best fits are shown by the solid lines. All experiments performed at 37 °C. A) Am-GLP-1 in 25 mM citrate buffer at pH 3.0 B) Am-GLP-1 in 25 mM citrate buffer at pH 4.0. C) Am-GLP-1 in 25 mM Tris buffer at pH 8.2. D) Am-GLP-1 in 25 mM Tris buffer at pH 8.7. E) 25 µM Am-GLP-1 at pH 4.0 in detail. F) 150 µM Am-GLP-1 at pH 3.0 and 4.0 in detail. Figure 4.6. Kinetic parameters from the aggregation kinetics of GLP-1 and Am-GLP-1. The parameters were determined at six different peptide concentrations between 25 – 150 µM. The error bars show the standard deviation. A) and C) $t_{1/2}$ and $t_{lag}$ of GLP-1 at pH 3.0 (red open triangles) and pH 3.5 (orange open circles) as well as Am-GLP-1 at pH 3.0 (red closed triangles) and pH 4.0 (green closed hexagons). All samples in 25 mM citrate buffer. B) and D) $t_{1/2}$ and $t_{lag}$ of GLP-1 at pH 7.5 in phosphate buffer (green open triangles) and Tris at pH 8.2 (dark blue open squares) as well as Am-GLP-1 at pH 8.2 (dark blue closed squares) and pH 8.7 (blue closed diamonds). GLP-1 data measured by Dr Karolina Zapadka.$^5$ Figure 4.7. Apparent growth rate results. A) Apparent growth rate ($k$) of GLP-1 at pH 3.0 (red open triangles) and pH 3.5 (orange open circles) as well as Am-GLP-1 at pH 3.0 (red closed triangles) and pH 4.0 (green closed hexagons). All samples in 25 mM citrate buffer. B) Apparent growth rate ($k$) of GLP-1 at pH 7.5 in phosphate buffer (green open triangles) and Tris at pH 8.2 (dark blue open squares) as well as Am-GLP-1 at pH 8.2 (dark blue closed squares) and pH 8.7 (blue closed diamonds). Error bars show the standard deviation between triplicate runs for Am-GLP-1. The apparent growth rates are taken from the sigmoidal fit of the aggregation kinetics shown in Figure 4.5A-D. For GLP-1, the apparent growth rates were measured by Dr Karolina Zapadka.$^5$ The data for Am-GLP-1 at pH 8.2 and 8.7 are shown in Figure 4.5C and D, respectively. At pH 8.2, the kinetic data are typical of a nucleation-polymerisation mechanism where lag time decreases with increasing peptide concentration up to a concentration of 100 µM. Above this concentration an increase in $t_{1/2}$ and lag time with increasing peptide concentration is observed, Figure 4.6C & D. The shape of the ThT fluorescence data can be described by a sigmoidal curve with a slight linear increase in fluorescence in the final plateau region. The lag phase itself is completely flat and does not show any increase in fluorescence before the growth phase, Figure 4.5C. At the most basic pH measured, pH 8.7, the variation of the data between runs is pronounced, Figure 4.6C & D. The variation of the apparent growth rate with peptide concentration is generally low. For both, GLP-1 and Am-GLP-1, the range of values varies by less than threefold and there is no real trend with peptide concentration, Figure 4.7. Some higher variations in the apparent growth rates are seen for Am-GLP-1 at pH 4.0 and 8.7, but, under these conditions, there are larger standard deviations in these values due to pronounced variations between runs, Figure 4.7A & B. \| Conc. (µM) \| pH 3.0 t\textsubscript{1/2} (h) \| SD \| pH 4.0 t\textsubscript{1/2} (h) \| SD \| pH 8.2 t\textsubscript{1/2} (h) \| SD \| pH 8.7 t\textsubscript{1/2} (h) \| SD \| \|------------\|----------------------------------\|----\|----------------------------------\|----\|----------------------------------\|----\|----------------------------------\|----\| \| 25 \| 19.0 \| 0.0\| 9.4 \| 0.2\| 126.0 \| 0.0\| 115.3 \| 7.2\| \| 50 \| 18.2 \| 0.5\| 8.3 \| 0.3\| 82.2 \| 12.6\| 111.3 \| 32.4\| \| 75 \| 13.6 \| 0.4\| 10.0 \| 0.3\| 60.3 \| 2.2\| 91.5 \| 34.6\| \| 100 \| 14.2 \| 0.2\| 11.0 \| 0.3\| 73.0 \| 1.7\| 84.8 \| 41.2\| \| 125 \| 13.6 \| 0.1\| 9.8 \| 0.6\| 100.9 \| 7.7\| 82.0 \| 17.8\| \| 150 \| 11.8 \| 0.5\| 10.1 \| 0.1\| 109.6 \| 14.0\| 70.3 \| 5.5\| \| Conc. (µM) \| t\textsubscript{lag} (h) \| SD \| t\textsubscript{lag} (h) \| SD \| t\textsubscript{lag} (h) \| SD \| t\textsubscript{lag} (h) \| SD \| \|------------\|--------------------------\|----\|--------------------------\|----\|--------------------------\|----\|--------------------------\|----\| \| 25 \| 14.7 \| 0.1\| 7.6 \| 0.2\| 115.7 \| 0.0\| 108.9 \| 8.5\| \| 50 \| 13.9 \| 0.6\| 6.4 \| 0.3\| 68.8 \| 15.5\| 106.2 \| 35.1\| \| 75 \| 9.7 \| 0.5\| 7.7 \| 0.2\| 51.9 \| 3.5\| 85.0 \| 35.7\| \| 100 \| 10.2 \| 0.2\| 5.7 \| 0.5\| 64.1 \| 1.8\| 78.8 \| 43.2\| \| 125 \| 8.2 \| 0.3\| 6.0 \| 0.9\| 90.6 \| 8.1\| 74.4 \| 16.9\| \| 150 \| 7.6 \| 0.3\| 8.3 \| 0.1\| 100.2 \| 16.8\| 62.7 \| 6.9\| \| Conc. (µM) \| k (h\textsuperscript{-1}) \| SD \| k (h\textsuperscript{-1}) \| SD \| k (h\textsuperscript{-1}) \| SD \| k (h\textsuperscript{-1}) \| SD \| \|------------\|---------------------------\|----\|---------------------------\|----\|---------------------------\|----\|---------------------------\|----\| \| 25 \| 0.47 \| 0.01\| 1.10 \| 0.05\| 0.19 \| 0.00\| 0.32 \| 0.07\| \| 50 \| 0.47 \| 0.02\| 1.07 \| 0.07\| 0.16 \| 0.04\| 0.46 \| 0.19\| \| 75 \| 0.52 \| 0.01\| 0.88 \| 0.07\| 0.24 \| 0.05\| 0.31 \| 0.06\| \| 100 \| 0.50 \| 0.01\| 0.38 \| 0.05\| 0.24 \| 0.07\| 0.37 \| 0.15\| \| 125 \| 0.37 \| 0.01\| 0.57 \| 0.24\| 0.20 \| 0.02\| 0.27 \| 0.04\| \| 150 \| 0.48 \| 0.02\| 1.15 \| 0.08\| 0.23 \| 0.06\| 0.27 \| 0.05\| Table 4.1. Kinetic parameters from the sigmoidal fits of the Am-GLP-1 ThT assay data shown in Figures 4.5 and 4.6. SD is the standard deviation. ### 4.6 The Variance Between Triplicate Runs Increases with Lag Time At pH 3.0, the observed variance between triplicate runs for Am-GLP-1 is low, however, at higher pH values it increases such that by pH 8.2 the variation is significant and at pH 8.7 it is pronounced, Figures 4.5 and 4.6. The possibility that the increase in variance is caused by impurities in the peptide preparations can be excluded because the same batch of peptide is used for all pH values. The large variance is associated with longer lag times,\textsuperscript{352} conditions which favour the population of off-pathway oligomers. 4.7 Additional Analysis of Kinetic Aggregation Data Using a Nucleated-Polymerisation Model An additional analysis of the ThT assay data of Am-GLP-1 and previously published data of GLP-1\textsuperscript{5} was performed by normalising the data and fitting it to an analytical approximation of a nucleated-polymerisation and elongation model with fragmentation (NEF) as a secondary nucleation mechanism, Equation 2.6.\textsuperscript{83,353,354} It is assumed that there is no fibril seeding and the complete peptide concentration is monomeric at the beginning of the reaction. In Equation 2.6, $\delta$ and $\kappa$ represent the effective rate for nucleated polymerisation without secondary pathways (primary nucleation) and the rate of multiplication of the filament population (secondary nucleation), respectively, Section 2.9.3. Both $\delta$ and $\kappa$ are not individually linked to one specific physical process or step in the reaction mechanism but are instead the product of several different steps. The primary nucleation rate, $\delta$, is related to the size of the nucleus, the primary nucleation and elongation rates, as well as dependent upon the total peptide concentration, Equation 2.7. In comparison, the secondary nucleation rate, $\kappa$, is related to the primary nucleation rate and the fragmentation rate constant, in addition to being dependent upon the total peptide concentration, Equation 2.8. These relationships are the direct consequence of the solution of a Master equation based on physical principles.\textsuperscript{83,353,354} For Am-GLP-1 and GLP-1, at all four pH values studied, it was not possible to fit the data globally using datasets acquired at different peptide concentrations using constant primary and secondary nucleation rates. Therefore, the data for each peptide concentration were fitted separately to Equation 2.6, Figures 4.8A-D and 4.9A-D. Figure 4.8. Fits of Am-GLP-1 ThT data to the NEF model. All samples were measured at the following peptide concentrations: 25 µM (pink), 50 µM (orange), 75 µM (blue), 100 µM (dark blue), 125 µM (green), and 150 µM (dark green) and all experiments performed at 37 °C. The data were normalised and fitted using Equation 2.6. The model is based on nucleation, elongation and fragmentation steps. The best fits are shown by the solid lines. All fits showed high $R^2$ values with the vast majority showing values above 0.97. A) Am-GLP-1 in 25 mM citrate buffer at pH 3.0 B) Am-GLP-1 in 25 mM citrate buffer at pH 4.0. C) Am-GLP-1 in 25 mM Tris buffer at pH 8.2. D) Am-GLP-1 in 25 mM Tris buffer at pH 8.7. Figure 4.9. Fits of GLP-1 ThT data to the NEF model. The original data were acquired by Dr Karolina Zapadka. All samples were measured at the following peptide concentrations: 25 µM (pink), 50 µM (orange), 75 µM (blue), 100 µM (dark blue), 125 µM (green), and 150 µM (dark green) and all experiments performed at 37 °C. The data were normalised and fitted using Equation 2.6. The model is based on nucleation, elongation and fragmentation steps. The best fits are shown by the solid lines. All fits showed high $R^2$ values with the vast majority showing values above 0.97. A) Am-GLP-1 in 25 mM citrate buffer at pH 3.0 B) Am-GLP-1 in 25 mM citrate buffer at pH 4.0. C) Am-GLP-1 in 25 mM Tris buffer at pH 8.2. D) Am-GLP-1 in 25 mM Tris buffer at pH 8.7. The primary nucleation rates, $\delta$, of Am-GLP-1 are shown in Figure 4.10A & B. $\delta$ varies tenfold across pH values for both GLP-1 and Am-GLP-1, but they vary differently with pH. For Am-GLP-1, there is a clear difference in the rates between the samples at acidic and basic pH values. The longer lag times observed under basic conditions are the result of small $\delta$ values at basic pH values in comparison to the acidic samples. Consistent with the decrease in the lag time at pH 3.0 with increasing peptide concentration, the primary nucleation rate $\delta$ increases with increasing peptide concentration. In contrast, at pH 4.0 the values are approximately constant and independent of peptide concentration. The values of the secondary nucleation rate, $\kappa$, calculated for Am-GLP-1 at all pH values are similar, Figures 4.10C and 4.11B. The values are closely related to the steepness of the apparent growth phase in the ThT data. Although some trends can be observed between $\kappa$ and peptide concentration, for example, $\kappa$ increases with increasing peptide concentration at pH 3.0, in general the errors associated with $\kappa$ are large and it can be considered to be generally independent of peptide concentration. At pH 8.2, the secondary nucleation rate is lower than it is for the acidic samples. For Am-GLP-1, particularly large variations in $\delta$ and $\kappa$ were calculated at pH 8.7, Figures 4.10C and 4.11A. This may be due to the variance in the maximum ThT signal, Figure 4.5D, which the method assumes is equivalent to the amount of peptide in a fibrillar form capable of binding ThT. The primary nucleation rate even showed negative values at a peptide concentration between 25 and 50 $\mu$M which is theoretically not possible but caused by the slight negative slope of the initial baseline in the ThT data, Figure 4.8D. The negative values of the primary nucleation rate are the reason why the data points at 25 and 50 $\mu$M disappear in a log-linear plot, Figure 4.11A. As with the Am-GLP-1 data, the data for GLP-1\textsuperscript{5-35}\textsuperscript{[5,35]} at each pH value and peptide concentration were fitted individually to Equation 2.6. Figure 4.9 shows the best fit of the ThT data to Equation 2.6, whilst the parameters $\delta$ and $\kappa$ from the analysis are shown in Figure 4.10B and D, respectively. The range of values of $\delta$ for GLP-1 are similar to Am-GLP-1 but the pH dependence differs. However, some similarities with the Am-GLP-1 data were observed: $\delta$ increases with peptide concentration at pH 3.0. At other pH values, $\delta$ is relatively independent of peptide concentration. Figure 4.10. Kinetic parameters from the aggregation kinetics of the NEF model of GLP-1 and Am-GLP-1. The parameters were determined at six different peptide concentrations between $25 - 150 \mu M$. The error bars show the standard deviation of a triplicate measurement. A) Linear plot of the primary nucleation rates, the effective rate for nucleated polymerisation without secondary pathways of Am-GLP-1 at pH 3.0 (red closed triangles), 4.0 (green closed hexagons), 8.2 (dark blue closed squares) and 8.7 (blue closed diamonds). B) Linear plot of the primary nucleation rates, the effective rate for nucleated polymerisation without secondary pathways of GLP-1 at pH 3.0 (red open triangles), 3.5 (orange open circles), 7.5 (green open triangles) and 8.2 (dark blue open squares). C) Linear plot of the secondary nucleation rates i.e., the rate of multiplication of the filament population of Am-GLP-1. D) Linear plot of the secondary nucleation rates i.e., the rate of multiplication of the filament population of GLP-1. GLP-1 data reanalysed from Zapadka et al.$^5$ Figure 4.11. Primary and secondary nucleation rates for Am-GLP-1 ThT data fitted to the NEF model. A) Log-linear plot of the primary nucleation rates, the effective rate for nucleated polymerisation without secondary pathways. B) Linear-log plot of the secondary nucleation rates i.e., the rate of multiplication of the filament population. The data is shown for pH 3.0 (red closed triangles), pH 4.0 (green closed hexagons), pH 8.2 (dark blue closed squares) and pH 8.7 (blue closed diamonds). The error bars show the standard deviation of a triplicate measurement. The pH dependence of $\kappa$ is different for GLP-1 and Am-GLP-1. However, the values are in the same range. The data for GLP-1 at pH 3.5 and 7.5 does appear to show a decrease of $\kappa$ with increasing peptide concentration suggesting that off-pathway events are happening, Figure 4.12. Here too, the error bars are large, but the trend appears to be real. The analysis of the ThT-assay data of GLP-1 and Am-GLP-1 shows that, if the aggregation kinetics are following a NEF-model, the primary ($\delta$) and secondary ($\kappa$) nucleation rates vary with pH as expected. Similar it shows that some of the aggregation parameters like the size of the nucleus, primary nucleation, elongation and fragmentation rates are under most conditions peptide concentration-independent because, under specific conditions, constant $\delta$ and $\kappa$ values have been observed with increasing peptide concentration.\textsuperscript{17,274} However, under some conditions, a decrease of $\kappa$ was detected with increasing peptide concentration. Figure 4.12. Primary and secondary nucleation rates for GLP-1 ThT data fitted to the NEF model. A) Log-linear plot of the primary nucleation rates, the effective rate for nucleated polymerisation without secondary pathways. B) Linear-log plot of the secondary nucleation rates i.e., the rate of multiplication of the filament population. The data are shown for pH 3.0 (red open triangles), pH 4.0 (orange open circles), pH 8.2 (green open triangles) and pH 8.7 (dark blue open squares). GLP-1 data reanalysed from Zapadka et al.\textsuperscript{5} The error bars show the standard deviation of a triplicate measurement. 4.8 General Solution to Predict the Maximum Influence of Off-Pathway Species on Monomer Concentration It is well-established that the kinetics of aggregation of a system that follows a nucleation-propagation mechanism is monomer concentration dependent with higher peptide concentrations leading to a decrease in the lag time. That is why the measured peptide concentration dependence for Am-GLP-1 at pH 4.0, pH 8.2 and pH 8.7 (37 °C), where the lag time is constant or even increases with peptide concentration, are so unusual. It has been suggested that this behaviour is due to the population of off-pathway oligomers.\textsuperscript{5} Here, a mathematical proof that the population of off-pathway oligomers cannot lead to an increase in the lag time with increasing peptide concentration is presented. Assuming that the presence of off-pathway oligomers populated during the aggregation reaction affects the monomer concentration $[M]$, the degree to which the off-pathway species reduce the effective monomer concentration can be estimated. It is possible to show that for two different monomer starting concentrations $[M_1]_0$ and $[M_2]_0$, where $[M_2]_0 > [M_1]_0$, it is true that at every time point the concentration $[M_2](t) > [M_1](t)$. This means that the concentration of monomers accessible to the on-pathway process is at any time always higher in case of $[M_2]$ than $[M_1]$. Mathematically, this becomes clear if the condition $[M_2]_0 > [M_1]_0$ is inserted into the integrated rate law (Equation 4.2), which leads to the Inequation 4.3. Using an $n$th order rate law \[ -\frac{d[M]}{dt} = [M]^n \] Integrated rate law \[ \frac{1}{[M]^{n-1}} = \frac{1}{[M]_0^{n-1}} + kt \] \[ \frac{1}{[M_2]_0^{n-1}} + kt < \frac{1}{[M_1]_0^{n-1}} + kt \] Following Inequation 4.3, $[M_2](t)$ is always bigger than $[M_1](t)$ if the reaction follows the same rate equation and $[M_2]_0 > [M_1]_0$. It is also independent of the order of the reaction. However, when off-pathway species exist then the amount of monomer available is reduced compared to the amount of monomer that would be populated in the absence of off-pathway oligomers. 4.9 Fibril Morphology and Higher Structures Because ThT assays provide indirect evidence of fibrillation, scanning electron microscopy (SEM) was used to verify that amyloid-like fibrils of Am-GLP-1 were formed, as well as to gain information on their morphology. 4.9.1 SEM Control Measurements of Pure Buffer To be able to differentiate between artefacts caused by the buffer or the deionised water used for rinsing and peptide aggregates, controls were undertaken where a glass sheet with buffer only on it was subsequently dried and imaged. Exactly the same method was used as for the protein samples: the samples containing buffer were allowed to dry exactly like the peptide samples, they were also rinsed with deionised water and subsequently dried with a gentle stream of nitrogen. For all three buffer samples, white round deposits can be observed at lower magnifications, Figures 4.13A, 4.14A and 4.15A. These deposits consist of crystal-like species on the glass sheet as seen for phosphate buffer at pH 3.0, Figure 4.13B and C, or similar crystal-like, sharp but randomly distributed fragments as imaged for phosphate buffer at pH 4.0, Figure 4.14C and D, or Tris buffer at pH 8.2 (37 °C), Figure 4.15D. It is most likely that these fragments are caused by salt residues from the dried buffers. Images without deposits (the uncovered region of the glass microscopy sheet surface) are shown at different magnifications in Figures 4.13D, 4.14B and 4.15B and C. Typically some thin scratches in the glass sheet can be seen. Figure 4.13. SEM images of phosphate buffer at pH 3.0. The preparation of the samples was exactly the same as for the peptide samples. A) Image at lower magnification shows white deposits and uncovered areas. B and C) Typical images of the deposits seen in Figure 4.13A at different magnifications. D) Images showing the uncovered surface of the glass microscopy slide at a higher magnification. Figure 4.14. SEM images of phosphate buffer at pH 4.0. A) Image at lower magnification shows the white deposits and uncovered areas. B) Image showing the uncovered surface of the glass microscopy sheet at higher magnification. C and D) Typical images of the deposits seen in Figure 4.14A at different magnifications. Figure 4.15. SEM images of Tris buffer at pH 8.2. pH value measured in solution at 37 °C A) Image at lower magnification shows the white deposits and uncovered areas. B and C) Images showing the uncovered surface of the glass microscopy sheet at different magnifications. D) Typical image of the deposits seen in Figure 4.15A at high magnification. 4.9.2 Fibril Morphology and Higher-Order Structure Varies with pH Samples of Am-GLP-1 at four different pH values, at the end of the ThT aggregation assay, were imaged in three different ways. First, 5 µL of a sample of 150 µM of aggregated Am-GLP-1 was allowed to dry on a microscopy glass sheet. The first spot that was imaged was chosen in a region where there was dense fibril cover. Further images were then taken directly next to the dense fibril cluster where the density of packing was not as high and therefore it was easier to observe single fibrils. In addition, a second 5 µL sample was placed onto an additional glass sheet where it was left for 2 mins before it was gently blown away with nitrogen. This has the advantage that it prevents a high concentration of fibrils covering any other aggregates that might be present. It can, however, favour aggregated species that adhere faster to the glass surface. Typical images of aggregates of Am-GLP-1 formed at pH 3.0, 4.0, 8.2 and 8.7 at 37 °C using the first two methods are shown in Figures 4.16A-D and 4.17A-D, whilst images recorded after the samples were blown dry with nitrogen are shown in Figure 4.18. The SEM images of Am-GLP-1 aggregates were analysed in detail using Fiji (Figures 4.19, 4.20 and 4.21), an image processing package based on ImageJ2. It is worth noticing that SEM imaging does not enable the measurement of the height of the samples. Therefore, the analysis is restricted to distance measurement based on the grey scale of the sample images. Additionally, it is essential to keep in mind that SEM samples have been coated with a 10 nm thick platinum layer. At pH 3.0, in the most densely covered region, most fibrils are parallel to each other and longer than 2 µm, Figure 4.16A. A few short fibrils are misaligned and spread over the surface in a disordered way. The width of the fibrils is 21 ± 3 nm. In the less densely covered region two different, straight, slightly thicker (width: 42 ± 3 and 61 ± 3 nm), 200-900 nm long fibrils are observed, Figure 4.16B. There are also some shorter fragments with a length of 50-300 nm and 26 ± 4 nm width, which are randomly distributed. Figure 4.16. SEM images of aggregated forms of Am-GLP-1 under acidic conditions. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample were pipetted on to a glass microscopy sheet and subsequently dried. All images have the same magnification. A & B) Am-GLP-1 aggregated in 25 mM citrate buffer at pH 3.0. C & D) Am-GLP-1 aggregated in 25 mM citrate buffer at pH 4.0. The images show the most typical of those obtained. A & C) show images of regions where there is a high local concentration of fibrils (Region 1). B & D) show images of less densely populated regions of the surface (Region 2). B) Three different types of fibrils were observed and analysed. These are indicated by coloured arrows (I blue, diameter approx. 26 nm, II orange, diameter approx. 42 nm, and III, green, diameter approx. 61 nm) D) Typical fibril class I (blue arrow, diameter approx. 22 nm) and oligomeric structure O (orange arrow, diameter between 10 - 50 nm). Figure 4.17. SEM images of aggregated forms of Am-GLP-1 under basic conditions. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample was pipetted on to a glass microscopy sheet and subsequently dried. All images have the same magnification. A & B) Am-GLP-1 aggregated in Tris buffer at pH 8.2. C & D) Am-GLP-1 aggregated in Tris buffer at pH 8.7. The images show the most typical of those obtained. A & C) show images of regions where there is a high local concentration of fibrils (Region 1). B & D) show images of less densely populated regions of the surface (Region 2). B) Three different types of fibrils are observed and were analysed (I/II/III). These are indicated by coloured arrows (I blue, diameter approx. 20 nm, II orange, diameter approx. 24 nm, and III, green, diameter approx. 30 nm). D) Fibrils type I (blue, diameter approx. 31 nm) and II (orange, diameter approx. 76 nm). Figure 4.18. SEM images of aggregated forms of Am-GLP-1 samples dried with nitrogen. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample were pipetted on to a glass microscopy sheet and the drop was blown away with a gentle nitrogen stream after 2 min on the surface. Different types of analysed aggregates are marked with an arrow. All panels are at the same magnification. Different species are labelled and indicated with arrows. A) Am-GLP-1 aggregated in 25 mM citrate buffer at pH 3.0. Typical fibril type I indicated with a blue arrow (diameter approx. 20 nm). B) Am-GLP-1 aggregated in 25 mM citrate buffer at pH 4.0. Fibrils type I (blue, diameter approx. 22 nm), oligomer-like aggregates are marked O in orange and amorphous aggregates marked A in green. C) Am-GLP-1 aggregated in Tris buffer at pH 8.2. Amorphous aggregates marked A in green. D) Am-GLP-1 aggregated in Tris buffer at pH 8.7. Fibril type I (blue, diameter approx. 53 nm) and circular oligomer O (orange, diameter approx. 70 nm) are marked. Figure 4.19. Width or diameter of Am-GLP-1 fibrils and oligomers determined using grey scale profiles. The grey scale profiles were analysed using Fiji. A) A typical example of grey scale profiles to determine the widths of fibrils. Am-GLP-1 incubated at pH 8.2 at 37 °C. B) Grey scale profiles of two circular or ring-like oligomers. For each oligomer three profiles at three different angles were taken. The profiles of Oligomer A and B are shown in blue and grey, respectively. Am-GLP-1 incubated at pH 8.7 at 37 °C. C) Width or diameter of eleven different aggregate types as observed in Figures 4.16, 4.17 and 4.18. Figure 4.20. Measurement of major and minor axis of Am-GLP-1 oligomers formed in 25 mM citrate buffer at pH 4.0. A) Binary image of Figure 4.16D. B) Histogram of the oligomer major axis size distribution. To avoid counting fibril fragments, only aggregates with a circularity value higher than 0.5 were considered. The distribution follows a Gaussian with a mean value of 18.5, a standard deviation of 9.1 and $R^2 = 0.93$. C) Relation between minor and minor axis of the detected oligomers. For the nitrogen-dried samples, thin fibrillar species (approx. diameter $19 \pm 2$ nm, within error of that measured for the type I fibrils observed in the earlier experiment), can be seen. These are approx. 200-500 nm in length, Figure 4.18A. Overall, at pH 3.0, it appears as if high concentrations of fibrils of Am-GLP-1 have a tendency to stick to each other, as shown by the fibrils with diameters which are twice and three times the size of the thinnest fibrils observed. The morphology of Am-GLP-1 fibrils at pH 4.0 shows different patterns. In regions of high coverage, the fibrils are dense but form a randomly distributed mesh appearing sponge-like, with little holes in between, which consists of 15-25 nm thick and 30-200 nm long fibrils, Figure 4.16C. Smaller oligomers with a diameter of 10 - 45 nm (Figure 4.20A-C) and some longer thin fibrils (22 ± 3 nm wide and 500-1000 nm long) were typically found next to the thick patch of fibrils, Figure 4.16D. From the analysis, it becomes clear that the oligomers are not perfectly round as the minor and major axis lengths stand in a relation of approximately 0.35, Figure 4.20C. For the nitrogen-dried sample, similar thin fibrils were observed as well as oligomer-like species and larger aggregates, Figure 4.18B. At pH 8.2, the image taken in the region with high fibril coverage shows that the fibrils appear to organise into bundles (Figure 4.17A). In less densely covered regions, the fibrils can be seen more easily and are twisted. At least two different species have been measured, which are either 24 ± 1 nm or 30 ± 2 nm thick. The total length of one turn of the thinner fibril is slightly shorter than 200 nm, whereas the thicker fibril turns with a periodicity of 85 ± 10 nm, Figure 4.21. Most of these fibrils are longer than 2 µm and, therefore, longer than those formed under acidic conditions, Figure 4.17B. Figure 4.21. Grey scale profiles along Am-GLP-1 fibrils. A) Am-GLP-1 fibrils formed in 25 mM Tris buffer at pH 8.2 (37°C). B) Grey scale profiles of curly fibrils II (grey) and III (blue) along their longitudinal axis. They show a turn length of 85 ± 10 nm (grey) and slightly less than 200 nm (blue) which has been measured using the distance of the maximum amplitudes. There are also some thin (width: $20 \pm 1$ nm), slightly curved fibrils, which are shorter than 100 nm, Figure 4.16B. The image of the sample dried with nitrogen shows a high number of oligomer-like species or really short fibril fragments which are not thicker than 10 nm and only 20-40 nm long. Some of them appear to arrange into larger clusters with a width up to 200 nm, Figure 4.18C. Fibrils of Am-GLP-1 formed at pH 8.7 appear to be similar in terms of length and width to those obtained at pH 8.2. They appear, however, slightly less rigid and allow covered fibrils to trace through the top layer of fibrils especially if they cross each other as shown in Figure 4.17C. In the less dense region, Figure 4.17D, they also form bundle-like structures with a width of 50-200 nm that are mostly longer than 500 nm. Donut-like shaped oligomers with a diameter of 70 $\pm 4$ nm can be seen in the nitrogen-dried sample shown in Figures 4.18D and 4.19B. The SEM pictures of Am-GLP-1 show the whole complexity of the aggregation reaction and the different higher-order structures that can be formed at different pHs. Two other main observations are striking. First, the images taken from glass sheets on which the sample drop was blown away after 2 min show differences in the ability of different species to stick to the glass surface. Am-GLP-1 aggregated under acidic conditions shows fibrils sticking to the glass sheet within two minutes, Figure 4.18A & B, whereas both glass sheets covered with sample aggregated under basic conditions, Figure 4.18C & D, did not show fibrils after the two minutes but instead had oligomers covering the surface. This is possibly driven by the different net charge on the peptide and therefore on the aggregated species formed under acidic and basic conditions. Second, only samples with dominant off-pathway species populated during aggregation, as shown by the aggregation kinetics, show significant amounts of oligomeric species, as is the case of Am-GLP-1 at pH 4.0, 8.2 and 8.7 (Figures 4.16D and 4.18C, D). In our previous study, aggregates of GLP-1 were imaged using atomic force microscopy.\textsuperscript{5,351} Similar results were obtained, with the most common fibrils forming structures around 15-25 nm in width or multiples of this. The results of the SEM data for Am-GLP-1 reported here and the previously published AFM data for GLP-1 are summarised in Table 4.2 and Table 3.2, respectively. \| pH \| Region 1 \| Region 2 \| Nitrogen dried \| \|----\|--------------------------------------------------------------------------\|--------------------------------------------------------------------------\|--------------------------------------------------------------------------------\| \| 3.0\| Fibrils \| Fibrils a) \| Fibrils \| \| \| width: 15-25 nm \| width: 26 ± 3 nm \| width: 19 ± 2 nm \| \| \| length: > 2000 nm \| length: 50-300 nm fragmented, straight \| \| \| \| \| Fibrils b/c) \| \| \| \| \| width: 42 ± 3 / 61 ± 3 nm \| \| \| \| \| length: 200-900 nm straight \| \| \| 4.0\| Fibrils \| Oligomers \| Oligomer like dots \| \| \| width: 15-25 nm \| diameter: 10-45 nm \| diameter: 8-15 nm \| \| \| length: 30-200 nm spongy / cavernous / porous \| Mean value of major axis: 19 ± 9 nm \| \| \| \| \| Fibrils \| \| \| \| \| width: 22 ± 3 nm \| width: 22 ± 3 nm \| \| \| \| length: 500-1000 nm \| length: > 500 nm \| \| 8.2\| Fibrils \| Fibrils a) \| Oligomer like fragments \| \| \| width: 15-25 nm \| width: 20 ± 1 nm \| width: 10 nm thick \| \| \| length: > 2000 nm twisted \| length: < 100 nm straight \| length: 20-40 nm \| \| \| \| Fibrils b/c) \| Bigger clusters \| \| \| \| width: 24 ± 1 / 30 ± 2 nm \| consisting out of the fragments \| \| \| \| length: > 2000 nm straight, twisted \| diameter: < 200 nm \| \| 8.7\| Fibrils \| Fibril bundles \| Oligomers \| \| \| width: 15-25 nm \| width: 50 - 200 nm \| diameter: 70 ± 4 nm \| \| \| length: > 2000 \| length: > 500 nm slightly twisted \| Donut shaped \| \| \| twisted, similar to pH 8.5 but they seem to break more easily in general or during the drying process especially if they cross other fibrils \| \| Fibrils \| \| \| \| \| width: 53 ± 4 nm \| Table 4.2. Description of Am-GLP-1 aggregates imaged by SEM 4.10 Conformational Differences Between Aggregates Formed Under Acidic and Basic Conditions The results from SEM imaging showed that Am-GLP-1 forms different high-order structures at different pH values. For a deeper insight into these structures, ANS and tryptophan fluorescence experiments were conducted for both peptides to probe whether a) hydrophobic patches are exposed and b) the environment around the tryptophan, in the aggregates. ANS is known to bind to hydrophobic patches in proteins and peptide aggregates and increase its fluorescence.\textsuperscript{350} Immediately after the peptide was dissolved and the sample filtered, the ANS fluorescence signal is low, Figure 4.22A. The same samples measured after 144 h of incubation at 37 °C are shown in Figure 4.22B. All basic and neutral samples show no change after aggregation, however, all four acidic samples show a clear increase in fluorescence signal indicative of ANS binding. This suggests that under acidic conditions species are formed which have hydrophobic patches exposed and binding of ANS is favourable. It is possible that the different results obtained at acidic \textit{versus} neutral/basic pH may be due to the difference in the net charge of the peptides under these conditions. ANS, which is negatively charged, binding is likely to be more favourable to peptide aggregates at low pH values where the peptide is positively charged under the conditions. Thus, it is difficult to be quantitative about the relative amounts of aggregated species with exposed hydrophobic patches present at different pH values. Interpretation of these data is also not straightforward as, although it is frequently assumed that ANS binds specifically to oligomers, experiments shown in Section 4.11 show that it also binds to fibrils under certain conditions. The tryptophan fluorescence data shows that, before the aggregation assay, the signals of all samples are similar with a wavelength of maximum fluorescence ($\lambda_{\text{max}}$) around 350 nm, Figures 4.22C & D and 4.23. At pH 3.0 and 4.0, the wavelength of maximum fluorescence changes from 350 to 335 nm over the time course of aggregation compared to a much smaller change from 350 to 345 nm at pH 8.2 and 8.7, Figure 4.23. A shorter wavelength for $\lambda_{\text{max}}$ is known to indicate that the tryptophan is more buried and has less contact with the aqueous solvent.\textsuperscript{355} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{figure4_22.png} \caption{ANS and Trp fluorescence of Am-GLP-1 and GLP-1 before and after aggregation} \end{figure} ANS binding and tryptophan (Trp) assay of 150 µM Am-GLP-1 and GLP-1 samples at room temperature. Am-GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 and Tris buffer at pH 8.7. GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2. The pH of the Tris buffers used during the fluorescence measurements changed from pH 8.2 to 8.5 and pH 8.7 to 9.0 because of the temperature change from 37 °C (aggregation assay) to room temperature (spectroscopic analysis). The buffer concentration was 25 mM. A) ANS fluorescence of Am-GLP-1 and GLP-1 samples before the aggregation assay. B) ANS fluorescence of Am-GLP-1 and GLP-1 samples after aggregation. C) Trp fluorescence of Am-GLP-1 and GLP-1 samples before the aggregation assay. D) Trp fluorescence of Am-GLP-1 and GLP-1 samples after aggregation. 4.11 Specificity of ANS Binding to Oligomers/Fibrils ANS is known to bind to hydrophobic patches and one common assumption is that ANS binds only to oligomeric intermediates and not to monomers or fibrils.\textsuperscript{356-358} If this is true, it would enable the measurement of the relative amount of oligomers in different samples at different pH values and times. However, there is some evidence that ANS might also bind, albeit more weakly, to fibrils. Consequently, it is important to establish whether the increase in ANS fluorescence measured at the end of the aggregation assays is caused by oligomers in equilibrium with fibrils or due to direct binding of the ANS to the fibrils. To test this, an aggregation assay (without ThT which can interfere with ANS fluorescence) with GLP-1 and Am-GLP-1 was run. At the end of the incubation period, part of the sample was mixed with ANS or ThT and the fluorescence measured, in addition to the tryptophan fluorescence. The other half of the sample was centrifuged, and the pellet carefully separated from the supernatant, this was washed with buffer and recentrifuged, then the pellet was resuspended in the same volume of the buffer used initially. Figure 4.24. ANS fluorescence of GLP-1 and Am-GLP-1 aggregates formed after aggregation and after separation of insoluble/soluble fractions. ANS binding assay of 150 µM Am-GLP-1 and GLP-1 samples. Am-GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 and Tris buffer at pH 8.7 (9.0 at 25 °C). GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2 (8.5 at 25 °C). The pH of the Tris buffers used during the fluorescence measurements changed from pH 8.2 to 8.5 and pH 8.7 to 9.0 because of the temperature change from 37 °C (aggregation assay) to room temperature (spectroscopic analysis). All buffers were used at a concentration of 25 mM. A) ANS fluorescence after 140 h of incubation at 37 °C in plate reader B) ANS fluorescence of supernatant 1. C) ANS fluorescence of supernatant 2. D) ANS fluorescence of the samples with dissolved pellet. Figure 4.25. ANS fluorescence experiments to determine the specificity of ANS binding: maximum fluorescence signal. Maximum ANS fluorescence of 150 µM Am-GLP-1 or GLP-1 samples after 140 h of incubation at 37 °C in a plate reader, as well as of the supernatant 1, supernatant 2 and the pellet dispersed in buffer. A) Am-GLP-1 incubated in 25 mM citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 (8.5 at 25 °C) and Tris buffer at pH 8.7 (9.0 at 25 °C). B) GLP-1 incubated in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2 (8.5 at 25 °C). It was anticipated that the centrifugation steps should effectively separate the fibrils from soluble oligomers and monomer. The ANS, ThT and tryptophan fluorescence were measured for supernatant 1, supernatant 2 and the final resuspended pellet sample. 4.11.1 ANS Fluorescence: Higher Under Acidic Conditions The ANS data, Figure 4.24A, clearly shows that for both GLP-1 and Am-GLP-1 after aggregation, there are only significant levels of ANS fluorescence at acidic pH values. At neutral or basic pHs, the ANS fluorescence is low, Figure 4.24A. At pH 3.0, the first and second supernatants after centrifugation still show 50-70% of the ANS fluorescence in comparison to sample measured before any separation step, Figure 4.24B & C. This suggests that either the centrifugation is insufficient to separate monomers/oligomers from fibrils, or that the fibrils also bind to ANS and increase its fluorescence. GLP-1 at pH 3.5 and Am-GLP-1 at pH 4.0 show no ANS fluorescence in the supernatants but fluorescence in the final resuspended pellet sample. This indicates that ANS may well bind to fibrils, increasing its fluorescence, Figure 4.24D. Alternatively, this could also be caused by any oligomeric aggregates binding to species that are pelleted during the centrifugation step. A plot of the maximum ANS fluorescence for all samples and measurements is shown in Figure 4.25A & B. 4.11.2 Comparison to Tryptophan Fluorescence and Change of $\lambda_{\text{max}}$ The strength of the tryptophan fluorescence can be used as an estimate of the amount of peptide in solution. Similar to the ANS data, the tryptophan fluorescence is stronger at acidic pH values, Figure 4.26A. The peaks at neutral or basic conditions are approx. 3-4 times lower than in acidic conditions, Figure 4.26A. Again, the data shows a high fluorescence signal in supernatant 1 at pH 3.0, Figure 4.26B, indicating that the centrifugation step either failed to pellet all of the aggregated material, or that not all the peptide had formed insoluble aggregates. Similarly, there is a clear peak at pH 8.2, Figure 4.26B. This shows that for GLP-1 at pH 8.2, large aggregates/fibrillar species were not completely separated by the centrifugation step, or that there was still a measurable equilibrium between soluble and insoluble species under these conditions. In addition, the fluorescence of tryptophan, particularly the $\lambda_{\text{max}}$ value, is known to be influenced by its solvent exposure and degree to which it is buried within a hydrophobic environment. Therefore, it can be used as a probe of the environment of the tryptophan side chain in the different aggregated states. Following Vivian and Callis (2001), the wavelength of emission of Trp is primarily determined by the electrical potential difference across the long axis of the tryptophan's indole ring. For example, positive charges create a redshift when acting on the benzene ring end and a blue shift when acting on the pyrrole ring. For negative charges, the reverse is true. Figure 4.26. Tryptophan fluorescence experiments: after aggregation and centrifugation steps. Tryptophan fluorescence assay of 150 µM Am-GLP-1 and GLP-1 samples. Am-GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 (8.5 at 25 °C) and Tris buffer at pH 8.7 (9.0 at 25 °C). GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2 (8.5 at 25 °C). The used buffer concentration was 25 mM. A) Tryptophan fluorescence after 140 h of incubation at 37°C in plate reader B) Tryptophan fluorescence of supernatant 1. C) Tryptophan fluorescence of supernatant 2. D) Tryptophan fluorescence of the samples with resuspended pellet. Figure 4.27. Tryptophan fluorescence experiments: $\lambda_{\text{max}}$. Tryptophan $\lambda_{\text{max}}$ of 150 $\mu$M Am-GLP-1 and GLP-1 samples after 140 h of incubation at 37 °C and in 25 mM buffer in a plate reader before and after two centrifugation and separation steps. A) Am-GLP-1 in citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 (8.5 at 25 °C) and Tris buffer at pH 8.7 (9.0 at 25 °C). B) GLP-1 in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2 (8.5 at 25 °C). The influence of water is, in most cases, difficult to anticipate, but if one or both faces of the benzene ring are water exposed, the wavelength of the fluorescence peak is more likely close to 350 nm and therefore red-shifted as is seen for monomeric samples of Am-GLP-1 and GLP-1. The $\lambda_{\text{max}}$ of both peptides, GLP-1 and Am-GLP-1, was also determined after the aggregation assay, Figure 4.27A. Both peptides show a pH dependence of $\lambda_{\text{max}}$. After aggregation, the maximum wavelength is around 335-340 nm under acidic conditions (pH 3.0 to 4.0) and 340-345 nm under neutral or basic conditions. The tryptophan fluorescence of the resuspended pellet (Figure 4.27B) shows a similar pH dependence of $\lambda_{\text{max}}$ values compared to the measurements of Am-GLP-1 and GLP-1 directly after the aggregation assay and without the centrifugation step, Figure 4.23. Therefore, it is most likely that the structure of the samples is conserved during the centrifugation steps. 4.11.3 Separated Aggregates Interact with ANS and ThT Additional information about the formation of fibrils comes from ex-situ ThT experiments. As expected, there is no general difference in the intensity of the ThT fluorescence signal between the acidic and basic samples, Figure 4.28A, as amyloid-like fibrils are formed under both conditions. Interestingly, Am-GLP-1 at pH 3.0 and GLP-1 at pH 3.0 and pH 8.2 both show strong ThT fluorescence in supernatant 1, Figure 4.28B, indicating that there must be species containing extensive β-structure in these samples. This may be short fibrils that have not centrifuged down into the pellet or soluble oligomers with sufficient β-structure to bind to ThT. In contrast, the samples of Am-GLP-1 at pH 4.0, 8.2 and 8.7 as well as GLP-1 at pH 3.5 and 7.5 show significant levels of ThT fluorescence only in the final pellet. From the comparison of ANS with the ex-situ ThT fluorescence, ANS shows a low fluorescence gain under acidic conditions. It could be caused by a higher fraction of oligomeric aggregates under neutral and basic conditions, or ANS binding is influenced more by net charge and therefore pH compared to ThT. The behaviour of the ANS fluorescence and its pH dependence is, overall, similar to the intrinsic fluorescence of tryptophan. Figure 4.28. Ex-situ ThT fluorescence experiments: after aggregation and centrifugation. Ex-situ ThT fluorescence assay of 150 µM Am-GLP-1 and GLP-1 samples. Am-GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer pH 4.0, Tris buffer at pH 8.2 (8.5 at 25 °C) and Tris buffer at pH 8.7 (9.0 at 25°C). GLP-1 incubated at 37 °C in citrate buffer at pH 3.0, citrate buffer at pH 3.5, phosphate buffer at pH 7.5 and Tris buffer at pH 8.2 (8.5 at 25 °C). All buffers prepared at a concentration of 25 mM. A) Ex-situ ThT fluorescence after 140 h of incubation at 37 °C in plate reader B) Ex-situ ThT fluorescence of supernatant 1. C) Ex-situ ThT fluorescence of supernatant 2. D) Ex-situ ThT fluorescence of the samples with resuspended pellet. 4.12 Influence of the C-terminal Amidation on Secondary Structure The fluorescence data presented in Section 4.10 & 4.11 shows that the hydrophobicity of the aggregates as well as the environment around the tryptophan side chain in the aggregates, most likely fibrils, changes depending on the pH. To assess whether these changes are also accompanied by changes in secondary structure, far-UV CD spectroscopy was undertaken on both peptides both before and after aggregation over a range of pH values. In Figures 4.29A, 4.30A and 4.31A, the far-UV CD spectra of GLP-1 and Am-GLP-1 are shown before aggregation under acidic, close to neutral and basic conditions. While the far-UV CD spectra were recorded, the HT voltage was always kept below 500 V to guarantee that enough photons are being sampled. At pH values between 3 and 4, both peptides have the same secondary structure, but this structure differs with pH, Figure 4.29A. Figure 4.29. Secondary structure of GLP-1 and Am-GLP-1 at acidic pH before and after aggregation. A) Far-UV CD spectra for GLP-1 and Am-GLP-1 in 25 mM citrate buffer at pH 3.0, 3.5 and 4.0 before aggregation. B) Far-UV CD spectra of the same samples as in Figure 4.29A after 144 h aggregation in the plate reader under the same conditions as the ThT assay. There is a significant increase in $\alpha$-helical structure and a decrease of all other structures on increasing the pH from 3.0 to 4.0. At pH values close to neutral, both peptides have the same secondary structure and this does not change between pH 5.0 and 7.0, Figure 4.30A. At basic pH values, there is a significant difference in the far-UV CD spectra between the two peptides but the secondary structure is independent of pH over the range from pH 8.0 to 9.0 (At 37 °C, during the incubation, pH values of the Tris buffer samples change to pH 7.7, 8.2 and 8.7) C), Figure 4.31A. The differences in secondary structure between GLP-1 and Am-GLP-1 observed at higher pH values are likely due to the difference in net charge under these conditions as a consequence of C-terminal amidation. At pH 8.5, the net charge is estimated to be -1.2 for GLP-1 and -0.2 for Am-GLP-1, Figure 4.3B (a change of 600%). In comparison, it is interesting to note that at pH 3.0 the net charge of GLP-1 and Am-GLP-1 are estimated to be 3.8 and 4.7, respectively. Here, the net charge of Am-GLP-1 is only 24% higher than for GLP-1. This increases to a relative change of 45% at pH 4.0 as the net charge of GLP-1 and Am-GLP-1 is calculated to be 2.2 and 3.2, respectively, under these conditions. Figure 4.30. Secondary structure of GLP-1 and Am-GLP-1 at acidic and neutral pH before and after aggregation. A) Far-UV CD spectra for GLP-1 and Am-GLP-1 in 25 mM citrate buffer at pH 5.0 and 6.0 as well as in 25 mM phosphate buffer at pH 7.0 before aggregation. B) Same samples as in Figure 4.29C after 144 h of aggregation in the plate reader. After aggregation, there is a large change in the far-UV CD spectra of both peptides at most pH values indicative of β-sheet formation (maxima and minima at ~202 and ~218 nm), Figures 4.29B, 4.30B and 4.31B. There are different intensities in signal between the samples, with the signal being particularly low at pH 4.0-6.0. This is attributed to inaccuracy in determining the peptide concentration due to low concentrations resulting from precipitation. In these cases, the peptide concentration has probably been overestimated because of light scattering in the aggregated sample. In the basic regime, differences between the secondary structures of the aggregates formed by GLP-1 and Am-GLP-1 are observed, as well as changes in maxima/minima with pH, Figure 4.31B. Although overall the aggregates look like they have largely β-sheet structure, there is evidence that the secondary conformation within the fibrils differs. Figure 4.31. Secondary structure of GLP-1 and Am-GLP-1 at neutral and basic pH before and after aggregation. A) Far-UV CD spectra for GLP-1 and Am-GLP-1 in 25 mM Tris buffer at pH 8.0, 8.5 and 9.0 before aggregation and at 25 °C. B) Far-UV CD of the same samples as in Figure 4.29E after 144 h aggregation at pH 7.7, 8.2 or 8.7 in the plate reader under the same conditions as the ThT assay. The far-UV CD spectra were recorded at 25 °C, whilst the aggregation assays were performed at 37 °C. Thus, the pH values in the Tris buffers were 0.3 pH units higher when the far-UV CD spectra were acquired compared to the pH at which aggregation took place in the plate reader. The data were analysed using CDPro, which estimates the different fractions of regular $\alpha$-helix, distorted $\alpha$-helix, regular $\beta$-sheet, distorted $\beta$-sheet, turns and disordered structures.\textsuperscript{327,328,359} It is worth noting that the analysis with CDPro is based on previously gained structural data from peptides and proteins. Therefore, the analysis always has to be taken to a certain degree qualitatively. However, CDPro still enables a comparison between different sets of far-UV CD data of peptides collected in a systematic manner. For reasons of simplicity, the regular and distorted fractions of either $\alpha$-helix or $\beta$-sheet were combined into one single value of $\alpha$-helix and $\beta$-sheet, respectively. Figure 4.32A & C clearly show how the different elements of secondary structure change with pH for the monomeric peptides before aggregation. There is an increase in $\alpha$-helicity and concomitant decrease in $\beta$-sheet for both peptides between pH 3.0 and 4.5. Overall, especially between pH 6.0 and 9.0 (25 °C), Am-GLP-1 has a slightly higher propensity to form helical structure than GLP-1, Figure 4.32A. These data also show that at pH 3.0, both, Am-GLP-1 and GLP-1 form more $\beta$-sheet than $\alpha$-helical structure within the largely monomeric solution (the system is referred to as being in \textbf{State B}). Am-GLP-1 shows the same behaviour additionally at pH 8.5 and 9.0 (25 °C). All other monomeric solutions show higher fractions of $\alpha$-helix (the system is referred to as being in \textbf{State A}). Figure 4.32B & D show the different amounts of secondary structure after aggregation as a function of pH. A clear increase in $\beta$-sheet structure can be seen for both peptides over most pH values as expected for amyloid-like fibril formation. The raw data used for the CDPro analysis were also plotted as 3D surfaces, Figures 4.33 and 4.34. The main difference between the Am-GLP-1 and GLP-1 secondary structure data can be seen as the blue embayment around 225 nm and at neutral pH, which is only present for the amidated version of the peptide, Figure 4.33A & B. Figure 4.32. Fractions of secondary structure of GLP-1 and Am-GLP-1 before and after aggregation as a function of pH. The fractions are calculated from the far-UV CD spectra using CDPro. A) Fraction of $\alpha$-helical and $\beta$-sheet structure of Am-GLP-1 and GLP-1 after the peptides were dissolved, filtered and measured within 15 min. The conditions under which either Am-GLP-1 or GLP-1 and Am-GLP-1 show a higher fraction of $\beta$-sheet are marked with a black arrow (State B). All other conditions show higher fractions of $\alpha$-helical structure (State A) B) Fraction of $\alpha$-helical and $\beta$-sheet structure of Am-GLP-1 and GLP-1 after aggregation. C) Fraction of turn and disordered structure (D/O) of Am-GLP-1 and GLP-1 after the peptides were dissolved, filtered and measured within 15 min. D) Fraction of turn and disordered structure (D/O) of Am-GLP-1 and GLP-1 after aggregation. The errors shown are the standard deviation of the results using three different algorithms to calculate the secondary structure, Section 2.10. Figure 4.33. Three-dimensional far-UV CD spectral landscape illustrating the differences in secondary structure of GLP-1 and Am-GLP-1 at different pH values using freshly prepared samples. Far-UV CD spectra recorded directly after the peptides were dissolved in aqueous buffer. Each graph shows the far-UV CD spectra at 13 different pH values from pH 3.0 to 9.0 at 25 °C. The buffers were citrate (pH 3.0 - 6.0), phosphate (pH 6.5 - 7.5) and Tris (pH 8.0 - 9.0, 25 °C) and all the buffer concentrations were 25 mM. The far-UV CD spectra were recorded at 25 °C, whilst the aggregation assays were performed at 37 °C. Thus, the pH values in the Tris buffer were 0.3 °C pH units higher when the far-UV CD spectra were acquired compared to the pH values of 7.7, 8.2 and 8.7 at which aggregation took place in the plate reader. All measurements were done at a peptide concentration of approx. 150 µM or slightly below if the solubility was low. A) Secondary structure of GLP-1 B) Secondary structure of Am-GLP-1. Figure 4.34. Three-dimensional far-UV CD spectral landscape illustrating the differences in secondary structure of GLP-1 and Am-GLP-1 at different pH values after 144 h of aggregation. Far-UV CD spectra recorded after the ThT aggregation assay. Each graph shows the far-UV CD spectra of 13 different samples aggregated at pH values from pH 3.0 to 8.7 at 37 °C. The buffers were citrate (pH 3.0 - 6.0), phosphate (pH 6.5 - 7.5) and Tris (pH 7.7 - 8.7) and all buffer concentrations were 25 mM. All measurements were done at a peptide concentration of approx. 150 µM or slightly below if the solubility was low. During the spectroscopic analysis the pH of the Tris buffers used during the aggregation assay changed from pH 7.7 to 8.0, 8.2 to 8.5 and pH 8.7 to 9.0 because of the temperature change from 37 °C (aggregation assay) to room temperature (spectroscopic analysis). A) Far-UV CD spectrum of GLP-1 B) Far-UV CD spectrum of Am-GLP-1. 4.13 Discussion To assess the effect of amidation of the C-terminus on the aggregation behaviour of the therapeutic peptide GLP-1 measurements on the solubility, charge and aggregation kinetics of Am-GLP-1 were made over a wide range of pH values. In addition, ANS assays, tryptophan assays and far-UV CD measurements, characterising the hydrophobicity, burial of tryptophan residues, secondary structure both before and after aggregation, were also undertaken. Finally, the nature of species present at the end of the aggregation was assessed using imaging techniques. A number of systematic differences between the behaviour of GLP-1 and Am-GLP-1 were observed and, in some cases, these could be linked to changes in charge state. Collectively, the data provides more information on the mechanism of self-assembly of GLP-1 based peptides, confirms the presence of off-pathway species populated during fibrillation and illustrates how sensitive aggregation reactions are to small changes in the intrinsic properties of the peptide as well as the environment. 4.13.1 The Mechanism of Aggregation: The Role of On- versus Off-Pathway Oligomers In these studies, with GLP-1 and Am-GLP-1, three different types of aggregation behaviour in terms of how the kinetic parameters $t_{1/2}$ and $t_{\text{lag}}$ depend on peptide concentration have been observed. These are assigned to one of three classes. Class I: lag time and $t_{1/2}$ decrease with increasing peptide concentration. This is what has been observed for many other peptides$^85$ and is consistent with standard nucleation-elongation models, Figure 1.7A. Class II. The lag time and $t_{1/2}$ do not vary significantly with peptide concentration. This is in agreement with either i) a critical micelle concentration (CMC) model in which the peptide monomer concentration is kept approximately constant above a threshold concentration (the CMC) above which excess peptide monomers arrange in off-pathway aggregates, for example micelles, Figure 1.7C.$^{86,360}$ Alternatively, it is also consistent with ii) an off-pathway model as shown by Powers & Powers$^89$ in which, if aggregation is dominated by elongation and the release of the monomers from the off-pathway species, $t_{1/2}$ does not change with peptide concentration. This is illustrated in Figure 1.7D. Class III. The kinetic parameters (lag time and $t_{1/2}$) increase with increasing peptide concentration. This is a particularly interesting case and rather unusual behaviour which suggests that not only are off-pathway species formed but that the off-pathway species actively interferes with the formation of nuclei or fibrils, Figure 1.7E.\textsuperscript{347} This behaviour was observed at pH 3.5 and 7.5 for GLP-1 and pH 8.2 for Am-GLP-1, Figure 4.6. It is also known that a lipidated analogue of GLP-1 (Liraglutide)\textsuperscript{91} as well as several other peptides (single-chain Aβ dimer or lysozyme)\textsuperscript{347} show this unusual behaviour. Fitting of ThT data to an NEF model, generates values for $\delta$, a measure of the rate of primary nucleation and $\kappa$, a measure of the rate of secondary nucleation. $\delta$ varies tenfold across pH values for both GLP-1 and Am-GLP-1, but they vary differentially. From these data, it is clear that the primary nucleation rate increases with increasing peptide concentration under conditions showing typical nucleation-polymerisation behaviour, for example, at pH 3.0 for both peptides. However, For GLP-1 at pH 3.5 and 7.5 (conditions where off-pathway oligomers are thought to be populated), it decreases with increasing peptide concentration, suggesting that off-pathway events are happening. Under the same conditions, $\kappa$ also decreases with increasing peptide concentration which is the expected behaviour if off-pathway oligomers not only depopulate the monomer concentration but actively suppress secondary nucleation. Previously, the behaviour of increasing lag time with increasing peptide concentration was attributed to the formation of off-pathway species alone along with a unimolecular step \textit{en route} to fibril formation.\textsuperscript{5} However, if both pathways are independent of each other and don’t interfere actively during the aggregation process, this model would result in $t_{\text{lag}}$ remaining constant and only $t_{1/2}$ would increase with increasing peptide concentration as has been shown by Powers & Powers in their work on off-pathway aggregation\textsuperscript{89}, Figure 1.7D. A shorter mathematical approach to prove that an off-pathway system as described in Figure 1.7D cannot lead to longer lag times with increasing peptide concentration is shown in Section 4.8. There, it is mathematically shown that the amount of available monomer concentration available for the on-pathway route, if the on-pathway is independent of the off-pathway species, cannot be smaller at any time point as the monomer concentration of a sample starting with a lower total monomer concentration at the same time point. It always results in a more rapid formation of both, on- and off-pathway aggregates, and can only approach a constant lag time if the off-pathway acts as a sink for free monomer, Section 1.5.2. 4.13.2 Role of Net Charge on Solubility and Aggregation Propensity One important factor influencing the interaction of monomers, oligomers, or fibrils with the solution or each other is the net charge of the peptide. Therefore, net charge on the peptide has the potential to influence the aggregation kinetics and even completely change the aggregation pathway. Amidation of GLP-1 leads to a change in the net charge over pH values between pH 3 and 9 and results in the peptide having a particularly wide-ranging minimum in charge around its pI value, Figure 4.3B. This can be explained by the distance from the pI to the p$K_a$ of the next ionisable group. The pI of Am-GLP-1 is shifted to a value which is further away from the p$K_a$ values of other ionisable groups such that the net charge stays close to zero over a wider pH range compared to GLP-1. The data shows the expected dependence between net charge and solubility, Figure 4.3A & B, but also establishes that there is a correlation between net charge and aggregation propensity as measured by $t_{1/2}$ and lag time, Figure 4.35A & B. This is discussed further in the next section. Figure 4.35. Correlation of net charge with aggregation propensity and secondary structure for GLP-1 and Am-GLP-1. The net charge was calculated as described in Section 2.15. The error bars shown are the standard deviation of the results of three different algorithms used to calculate the secondary structure, Section 2.10. A) $t_{1/2}$ values of GLP-1 and Am-GLP-1 aggregated at pH values between pH 3.0 and 8.7 plotted versus the net charge. B) $t_{lag}$ values of GLP-1 and Am-GLP-1 aggregated at pH values between pH 3.0 and 8.7 plotted versus the net charge. All measurements were done at a peptide concentration of approx. 150 µM or slightly below if the solubility was low. C) The fraction of α-helical-structure in the monomeric peptide as calculated from far-UV CD spectra (Figure 4.33) is shown versus net charge. D) The fraction of β-sheet structure in the monomeric peptide as calculated from the far-UV CD spectra (Figure 4.33) versus net charge. 4.13.3 Less Electrostatic Repulsion Does Not Lead to Higher Aggregation Propensity The results on the aggregation of Am-GLP-1 and GLP-1, Figures 4.4A and B and 4.5, give a broad overview of the aggregation propensity of both peptides at different pH values as well as at different peptide concentrations. It is clear that net charge strongly influences aggregation affecting the kinetic parameters $t_{\text{lag}}$ and $t_{1/2}$, Figure 4.35. Somewhat surprisingly, the results clearly show that both peptides have a lower aggregation propensity at pH values close to their pIs. This is in contrast to some models that predict that decreasing the net charge on a peptide increases its aggregation propensity as a result of decreasing the otherwise unfavourable electrostatic interactions that have to be overcome in order to achieve self-assembly.\textsuperscript{132–136} From earlier studies on GLP-1, this unusual kinetic behaviour was attributed to the formation of off-pathway species during the aggregation of this family of peptides under specific conditions.\textsuperscript{5} The off-pathway oligomers are populated close to the pI of the peptide and act as an off-pathway sink of monomer thus reducing aggregation rates. 4.13.4 Specificity of ANS Fluorescence One of the methods in this project used to gain more information about peptide oligomers and the structure of peptide aggregates in general is ANS fluorescence, which is widely used to probe the existence of partially structured folding intermediates.\textsuperscript{356–358} However, the data shown here suggest that ANS fluorescence is not always highly specific to such intermediates. The data shows either i) that aggregates that interact with ANS cannot be separated from ThT-binding fibrils by centrifugation, or ii) the fibrils themselves have some affinity for ANS and can increase its fluorescence. Thus, care must be taken in interpreting the results of ANS experiments and one should not assume that ANS fluorescence is solely due to its binding to intermediate states/oligomers. The data also demonstrates that the ANS-assay is strongly affected by pH showing a clear difference in behaviour between acidic and basic pH values. Such a behaviour could be explained by either i) two different forms of aggregates being formed in acidic and basic conditions with different propensities to bind to ANS, or ii) different binding affinities of ANS to similar species under acidic and basic conditions due to the influence of net charge. Under basic conditions, the ANS binding is so low that the assay is not able to prove whether in the case of GLP-1 at pH 8.2, a significant amount of peptide was in an oligomeric or fibrillar form in the different samples. If the washed pellets consist only of fibrils which bind to ThT and the fibrils are not disturbed during the centrifugation or washing step, then the results suggest that ANS also binds to fibrils as well as oligomers. However, it cannot completely be excluded that some of the larger oligomers also pellet with the fibril. If this is the case, then the ANS fluorescence might still be due to oligomer binding only. There is also some evidence, for example at pH 7.5, that ANS can bind under certain conditions specifically to oligomeric intermediates, but such findings have to be taken with care due to the previously described caveats. These experiments all highlight the limitations of using ANS and the care that needs to be taken when interpreting ANS fluorescence data in the context of protein/peptide aggregation. 4.13.5 Structure of the Monomeric Peptides It is clear that the net charge on the peptide influences both solubility and aggregation propensity. This leads to the question of whether net charge alone is responsible for the difference in aggregation behaviour observed for GLP-1 and Am-GLP-1 or whether the effects are indirect, i.e., the net charge influences other properties of the peptide such as secondary structure that is responsible for the change in aggregation propensity. A number of experiments on freshly prepared samples of GLP-1 and Am-GLP-1 shed light on the structure of the monomeric peptides in solution. From the ANS and tryptophan fluorescence data, it is likely that the monomer of both peptides studied has little fixed tertiary structure in either acidic or basic conditions, Figure 4.22A-D. In contrast, the secondary structure of the two peptides differs at specific pH values, Figures 4.29, 4.30 and 4.31. The far-UV CD data show that the secondary structure of both peptides is similar at acidic pH values and also shows that both peptides undergo similar pH-dependent changes in secondary structure in the acidic region. Notably, for both peptides there is an increase of $\alpha$-helical structure on increasing the pH from 3.0 to 4.0 or 4.5, Figure 4.32A. This is probably caused by protonation of Asp9 or one or more of the three glutamic acid residues at positions 3, 15 and 21, which are likely to have $pK_a$ values around 3.7 and 4.3, respectively.\textsuperscript{340} Significantly, there is a correlation between the secondary structure of the monomeric peptides at the start of the aggregation reaction and the net charge, Figure 4.35C & D. Higher net charges favour an extended $\beta$-conformation over a more compact $\alpha$-helical structure presumably because this minimizes electrostatic repulsion between like charges on the same peptide molecule. This, in turn, leads to the question if the amount of $\alpha$-helical \textit{versus} $\beta$-sheet structure in the monomeric peptide and the rate of fibril formation, as shown by $t_{1/2}$ and $t_{lag}$, is correlated, Figure 4.36. For both peptides there is no general correlation found between the amount of $\alpha$-helical and $\beta$-sheet structure and the rate of fibril formation, Figures 4.36A & B and 4.37A & B. What can be seen is a difference for Am-GLP-1 under conditions where the peptide is positively charged and negatively charged with the exception of pH 6.0, which is close to the pI. Under conditions at which Am-GLP-1 has a negative net charge all samples show a high $\alpha$-helical content and longer lag times than for positively charged Am-GLP-1. The data also shows a relationship between the difference of $\alpha$-helical and $\beta$-sheet structure, $\Delta$, and the rate of aggregation observed under conditions where the peptide follows a nucleation-polymerisation model. For Am-GLP-1 this is at pH 3.0 and for GLP-1, it is at pH 3.0, 8.5 and 8.7, and under most of these conditions there are clear negative $\Delta$ values (\textbf{State B}), Figures 4.36C & B and 4.37C. Other conditions show either values of $\Delta$ close to zero or positive values (\textbf{State A}), Figures 4.36C and 4.37C. Figure 4.36. Correlation of aggregation propensity ($t_{\text{lag}}$ and $t_{1/2}$) and secondary structure for GLP-1. Data of $t_{\text{lag}}$, determined from data shown in Figure 4.5, plotted versus the fraction of $\alpha$-helical and $\beta$-sheet structure, Figure 4.32. The data are shown for GLP-1 aggregated at pH values between 3.0 and 8.7. The far-UV CD spectra used to determine the secondary structure were recorded at 25 °C, whilst the aggregation assays were performed at 37 °C. Thus, the pH values in the Tris buffer were 0.3 °C pH units higher when the far-UV CD spectra were acquired compared to the pH values of 7.7, 8.2 and 8.7 at which aggregation took place in the plate reader. Peptides in samples represented by a solid symbol have a positive net-charge. The error bars shown are the standard deviation of a triplicate measurement of $t_{\text{lag}}$ and the results of three different algorithms used to calculate the secondary structure, Section 2.10. A) $t_{\text{lag}}$ of GLP-1 plotted versus its corresponding fraction of $\alpha$-helical structure. B) $t_{\text{lag}}$ of GLP-1 plotted versus its corresponding fraction of $\beta$-sheet structure. C) $t_{\text{lag}}$ versus difference of fraction of $\alpha$-helical and $\beta$-sheet structure $\Delta$ of GLP-1. Samples under of the conditions in the blue shaded area (State B) showed constant or increasing $t_{\text{lag}}$ with increasing peptide concentration. In the orange shaded region (State A), the samples followed typical nucleation-elongation kinetics. Figure 4.37. Correlation of aggregation propensity ($t_{\text{lag}}$ and $t_{1/2}$) and secondary structure for Am-GLP-1. Data of $t_{\text{lag}}$, determined from data shown in Figure 4.5, plotted versus the fraction of $\alpha$-helical and $\beta$-sheet structure, Figure 4.32. The data are shown for Am-GLP-1 aggregated at pH values between 3.0 and 8.7. The far-UV CD spectra used to determine the secondary structure were recorded at 25 °C, whilst the aggregation assays were performed at 37 °C. Thus, the pH values in the Tris buffer were 0.3 °C pH units higher when the far-UV CD spectra were acquired compared to the pH values of 7.7, 8.2 and 8.7 at which aggregation took place in the plate reader. Peptides in samples represented by a solid symbol have a positive net-charge. The error bars shown are the standard deviation of a triplicate measurement of $t_{\text{lag}}$ and the results of three different algorithms used to calculate the secondary structure, Section 2.10. A) $t_{\text{lag}}$ of Am-GLP-1 plotted versus its corresponding fraction of $\alpha$-helical structure. B) $t_{\text{lag}}$ of Am-GLP-1 plotted versus its corresponding fraction of $\beta$-sheet structure. C) $t_{\text{lag}}$ versus difference of fraction of $\alpha$-helical and $\beta$-sheet structure $\Delta$ of Am-GLP-1. Samples under of the conditions in the blue shaded area (State B) showed constant or increasing $t_{\text{lag}}$ with increasing peptide concentration. In the orange shaded region (State A) the samples followed typical nucleation-elongation kinetics. 4.13.6 The Secondary Structure of the Monomeric Peptides Influences Aggregation Propensity and Mechanism The far-UV CD spectra show that monomers can be found in at least two different conformational states (or ensembles). From CDPro analysis, State A is defined by a higher percentage of $\alpha$-helical than $\beta$-sheet structure whilst State B has a higher $\beta$-sheet content than $\alpha$-helical structure, Figures 4.32 and 4.38. The $\alpha$-helical structure is favoured under conditions where the peptide has a low net positive charge whilst higher $\beta$-sheet structure is favoured at pH values where the peptide has either a high positive or negative charge, Figure 4.35C & D. In three out of the eight different peptide and pH conditions studied, the peptides were observed in State B. In all of these three cases, a decrease of the lag time and $t_{1/2}$ with increasing peptide concentration was observed in the ThT assays (Class I). Figure 4.38. Two different monomer conformations (state $M_A$ and $M_B$) and how these relate to the pI and their role in forming on- and off-pathway oligomers. A) Two different conformational states of the monomeric peptide as shown by far-UV CD and their relative predominance at difference pH values. Samples with more or the same amount of $\alpha$-helical than $\beta$-sheet structure are shown in orange (State A) and samples with more $\beta$-sheet than $\alpha$-helical structure are shown in blue (State B). The experimentally determined pI values for GLP-1 and Am-GLP-1 are 5.9 and 6.8, respectively and are shown in grey. B) Conditions in which peptide monomer is in State B follow a predominantly on-pathway mechanism. C) Conditions in which the peptide monomer is in State A have more complex kinetics and show the population of off-pathway species which may or may not actively interact with on-pathway species. In all the other conditions studied, the peptides were in State A. Under these conditions either a constant (Class II) or even increasing (Class III) lag time and $t_{1/2}$ was observed with increasing peptide concentration. The conditions under which State A was observed was always closer to the pI in comparison to conditions where the monomeric peptide is in State B, Figures 4.35C & D and 4.38. ### 4.13.7 Structure/Properties of Off-Pathway Oligomers The observation of different aggregation behaviours for two different monomer ensembles, states A and B, leads to the proposal that monomers with higher $\alpha$-helical content result in the formation of off-pathway aggregates. These more helical monomers tend to form under conditions where the peptide has a relatively low net charge in comparison to the monomers in state B which have a higher percentage of $\beta$-sheet structure and which form at pH values where the peptide has a higher net charge, Figure 4.35. This leads to the conclusion that the net and/or local charge influences the secondary structure of the monomeric peptide, which in turn affects the aggregation behaviour. Thus, the charge state of the peptide influences the propensity of the peptide to aggregate either directly but also likely through induced changes in secondary structure. Based on these results and correlations, it is possible to speculate that the off-pathway oligomers have more $\alpha$-helical structure and the on-pathway oligomers more $\beta$-structure. Although it is not possible to get structural information directly on the oligomeric states, it is interesting to note that all samples which start with higher $\alpha$-helical content compared to $\beta$-sheet are more likely to populate off-pathway oligomers. One might therefore speculate that off-pathway species are more helical than their on-pathway counterparts. Under some conditions, over time $\alpha$-helical content approaches zero, suggesting that the off-pathway oligomers are converted into $\beta$-sheet structures and the amount of the off-pathway oligomers is too small to be distinguished by far-UV CD. 4.13.8 The Structure of Fibrils of GLP-1 and Am-GLP-1 are Sensitive to pH SEM images at different pH values were recorded to learn more about the structure and morphology of fibrils of Am-GLP-1 formed under different conditions. These images, and previous AFM images of fibrils of GLP-1 at different pH values,\textsuperscript{351} show that the higher-order structures of the aggregates formed by GLP-1 and Am-GLP-1 vary significantly with pH. Am-GLP-1 showed different fibril morphologies within the densely covered region of the dried sample, Figures 4.16A & C and 4.17A & C, suggesting that the fibrils formed under different conditions may have distinct surface characteristics which may lead to different higher-order structures. Under acidic conditions, the fibrils tend to stick faster to the glass surface in comparison to fibrils formed under basic conditions. Figure 4.18. This phenomenon could be caused by different surface properties, e.g., hydrophobicity, or simply by different net charge. More evidence that GLP-1 and Am-GLP-1 fibrils have different surface properties when formed under acidic or basic conditions comes from the ANS and tryptophan fluorescence data. The ANS data shows that fibrils of both peptides formed under acidic conditions bind ANS therefore indicating that there are hydrophobic patches on the surface of the aggregates formed under these conditions. In addition, binding may be facilitated by favourable electrostatic interactions between the positive charge on the peptide and the negatively charged dye at low pH.\textsuperscript{361} In contrast, at higher pH no ANS binding is observed. This may be due to the lack of exposed hydrophobic patches formed in the fibrils under these conditions or may simply be a consequence of the lack of favourable electrostatic interactions as the peptide and therefore aggregate has a different net charge. The results of the tryptophan fluorescence experiments indicate that the Trp side chains in GLP-1 and Am-GLP-1 are buried after aggregation under acidic and basic conditions, but the observed change in $\lambda_{\text{max}}$ is larger under acidic conditions, Figure 4.22E. This could be due to differences in the structure of the fibril formed or differences in the higher-order structures formed under acidic and basic pH. Far-UV CD data supports a model in which the intrinsic structure of the fibrillar species varies with pH, as despite the fact that there is strong evidence of $\beta$-sheet structure in all cases, the far-UV CD spectra of the aggregated species do vary, Figures 4.29B and 4.31B. ### 4.13.9 Conclusions Here, we have shown that a C-terminally amidated variant of GLP-1 aggregates to form amyloid-like fibrils over a wide range of condition similar to previous results on GLP-1. The structure, particularly the higher-order structure, of the fibrils formed by Am-GLP-1 varies with pH. However, the pH dependence of aggregation for Am-GLP-1 differs from that observed for GLP-1, which can be attributed to the result of their different pI values and therefore different net charge at different pHs. As with GLP-1, there is strong evidence that Am-GLP-1 also forms off-pathway oligomeric species (as well as on-pathway oligomers that lead to fibril formation) under certain conditions. These off-pathway species, which act to slow but not prevent fibril formation, are populated near to the pI of the peptides, where the net charge on the molecule is close to zero. This results in the opposite effect to that has been reported in earlier studies on other peptides, where low net charge minimises electrostatic repulsion between peptides and thus accelerates the rate of fibril formation. Interestingly, correlations between the net charge on the peptide and the secondary structure it forms in its monomeric state, low positive net charge favouring more $\alpha$-helical conformations, higher positive or negative net charges favouring more extended $\beta$-structures are observed. The consequence is that there is a correlation between the secondary structure in the monomer and its aggregation propensity – more helical structures favouring the formation of off-pathway oligomers resulting in slower aggregation, whilst more $\beta$-structures seem to favour the formation of on-pathway oligomers (or disfavour the formation of off-pathway species) and enhance aggregation propensity. Collectively, these studies show how sensitive aggregation reactions are to even small changes in the chemical nature of a peptide as well as to external factors such as pH. In addition, these results suggest that all members of the GLP-1 family of peptides are likely to populate off-pathway oligomers and show a delicate balance between on- and off-pathway processes which can be altered by changing the pH. 5 THE EFFECT OF LIPIDATION ON THE PHYSICAL STABILITY OF PEPTIDES From the detailed study of GLP-1 and Am-GLP-1, it is clear that C-terminal amidation and the consequent change of net charge has a significant influence on the aggregation characteristics of GLP-1. In this Chapter, the results of studies on the effect of lipidation on the physical stability of GLP-1 are described. Two peptides, called IPP4 and IPP5, were studied. They are lipidated at different positions, the modification involving attachment of a palmitic acid to the amino group of a glutamic acid, which is used as a spacer, the $\gamma$-carboxyl group of which is subsequently covalently linked to the $\varepsilon$-amino group of a lysine side chain in the peptide, Figure 5.1. In the case of IPP5, the lipid-spacer molecule was attached at the first naturally occurring lysine (at position 20) in the Am-GLP-1 sequence. Subsequently, the positive charge of the lysine is lost and an additional negatively charged carboxylate group of the glutamic acid is added. In addition, in IPP5, the lysine at position 28 is substituted by an arginine (K28R) to prevent lipidation at this position. Arginine is chosen as a substitute as it retains the positive charge and shows a similar hydropathicity to lysine. The lipidation and the loss of the positive charge on the lysine side chain on conjugation should increase the overall hydrophobicity of the peptide, however, the hydrophilicity may be partly replaced by the negative charge of the glutamic acid spacer. IPP5 has the same sequence and modification as Liraglutide but is amidated at the C-terminus. For IPP4, both naturally occurring lysines are substituted by arginines (K20R and K28R) to prevent covalent modification. In this case, the hydrophilic glutamine at position 17 is replaced with a lysine (Q17K) enabling lipidation at this site, Figure 5.1. Figure 5.1. Amino-acid sequence of GLP-1, Am-GLP-1, IPP4, IPP5 and Liraglutide. Possible de-/protonation sites are marked in green or red including the N- and C-terminus of the peptides if not amidated. Green sites are positively charged if the pH is lower than the p$K_a$ of the group (p$K_a$ values are shown in green next to the site for the parent peptide GLP-1). Red sites are negatively charged if the pH is higher than the p$K_a$ value (shown in red next to the site for the parent peptide GLP-1 and the linker group in IPP4). The fraction of de-/protonation and therefore the change of charge around the p$K_a$ can be determined using Equations 2.12 and 2.13. 5.1 Molecular Weight and Purity of IPP4 and IPP5 To measure the molecular weight of the lipidated peptides, as well as to compare the purity of the samples, LC-MS measurements were conducted. The UV absorbance at 210 nm shows a single narrow peak for both peptides, Figures 5.2A and 5.3A. The same peak was found in the total ion count (TIC) data, Figures 5.2B and 5.3B. This establishes that the peptides have high purity and no other molecules with a similar molecular weight which absorb in the UV are present. However, both peptides also show additional smaller peaks at longer elution times. The species corresponding to these peaks do not absorb in the UV and are probably more hydrophobic, causing the longer retention times. Between 5.30 and 6 min, both lipidated peptides also show a broad peak which was not observed for the non-lipidated peptides. These broad peaks are artefacts caused by the LC-MS method used for lipidated peptides and were similarly seen in a run with pure water injected (data not shown). Figure 5.2C shows the mass spectrum of IPP4 with IPP4 mainly present as a +3 molecular ion (1260.27 m/z). Smaller fractions are also observed as +5 molecular ion (756.85 m/z), +4 molecular ion (945.33 m/z), and +2 molecular ion (1890.12 m/z), Figure 5.4C. The determined molecular weight is 3778.2 ± 0.8 Da, Figure 5.3C. This value is in good agreement with the theoretical value of 3778.26 Da as well as the relative molecular mass of 3778.33 Da obtained by Bachem using matrix-assisted laser desorption/ionization-mass spectrometry (MALDI-MS). The mass spectrum of IPP5 shows that it is also mainly present as a +3 molecular ion (1250.85 m/z). Again, some smaller peaks are seen for the +4 molecular ion (938.56 m/z), and +2 molecular ion (1875.83 m/z) but not the +5 molecular ion as the maximum positive charge of IPP5 is +4. The determined molecular weight is 3749.8 ± 0.4 Da, Figure 5.3C. This value is in good agreement with the theoretical value of 3750.2 Da. Figure 5.2. LC-MS of IPP4. A) UV absorbance signal at 210 nm. The peak observed at 0.77 min is caused by the injection of the sample. It is due to the different percentage of acetonitrile in the sample in comparison to the LC gradient as well as the presence of salt in the sample. The x-axis is given in minutes. B) Total ion chromatogram (TIC). The x-axis is given in minutes. C) Mass spectrum of the peptide peak eluting at 2.71 min. Figure 5.3. LC-MS of IPP5. A) UV absorbance signal at 210 nm. The peak at 0.78 min is caused by the injection of the sample. It is due to the different percentage of acetonitrile in the sample in comparison to the LC gradient as well as the presence of salt in the sample. The x-axis is given in minutes. B) Total ion chromatogram (TIC). The x-axis is given in minutes. C) Mass spectrum of the peptide peak eluting at 2.82 min. 5.2 Solubility, Net Charge and pI are All Influenced by Lipidation Initial experiments were used to measure the effect of lipidation on the solubility of the peptide. The solubility of IPP4 and IPP5 was determined as in the earlier studies on Am-GLP-1 and the results are shown in Figure 5.4A. The results establish that lipidation greatly reduces the solubility of the peptide, such that IPP4 and IPP5 are only soluble at pH values higher than their pIs, i.e., towards the basic pH range, Figure 5.4A. IPP5 is soluble from pH 6.5 upwards and IPP4 from pH 7.5. upwards. The net charge was calculated for both peptides in a similar way as for Am-GLP-1 and GLP-1 and as described in Section 2.15 and results are shown in Figure 5.4B. In addition, the net charge of Liraglutide was also calculated and is shown. Theoretically, under basic conditions, the net charge on IPP4 parallels the net charge on IPP5 with a net charge difference of plus one. The net charge of IPP4 is also similar to the net charge on GLP-1 and only shows differences at highly acidic or basic conditions. The theoretical pI values for IPP4 and IPP5 were calculated using standard methods as described in Section 2.15 and are 5.5 for IPP4 and 4.7 for IPP5. The values were also determined experimentally and are 6.1 and 5.5 for IPP4 and IPP5, respectively, Figure 5.4C. The measured values are similar to, but not the same as, the theoretical values, suggesting that there is some structure or local charge effects in the lipidated peptides in solution which results in perturbed $pK_a$ values for some side chains. The peak of IPP5 is broader and less focused than for IPP4, which could be caused by the formation of stable oligomers or the need for a longer focusing time. The latter was, however, restricted because of the pI markers running out of the detectable range of the capillary, Section 1.16. Figure 5.4. Solubility, net charge and experimentally determined pI of lipidated GLP-1 peptides. A) Measured peptide concentration after dissolving approx. 0.25 mg of the peptide into 0.5 mL buffer at different pHs and after filtration of the sample with a 0.2 µm PVDF filter. IPP4 (red closed circles) and IPP5 (blue closed diamonds). B) Calculated net charge versus pH based on the peptide amino-acid sequence and standard pKₐ values. The data for IPP4 (blue solid line) and IPP5 (red solid line) are shown in comparison to the calculated net charge of GLP-1 (black dashed line), Am-GLP-1 (grey dashed line) and Liraglutide (green dotted line). C) Experimental determination of the pI values for IPP4 (blue line) and IPP5 (red line). The pI was measured using capillary isoelectric focusing (iCIEF). The method used included urea to prevent precipitation. 5.3 A pH Induced Switch of Aggregation Propensity For all pH values at which the peptides showed sufficient solubility, ThT aggregation assays were performed to learn more about the aggregation propensity of the two lipidated peptides at different pHs. IPP4 shows two regions which have different aggregation propensities, Figure 5.5A. At pH 7.5 and 7.7, the ThT signal shows a strong sigmoidal increase in fluorescence, whilst at pH 8.2 and 8.7, there is rather little increase in ThT fluorescence over the timeframe studied. Thus, if one assumes that the ThT fluorescence is linearly related to the formation of fibrils, IPP4 appears to have a much higher propensity to form fibrils at near neutral pH. IPP5 also shows a change in aggregation propensity with pH, Figure 5.5B. ![Figure 5.5. ThT aggregation assay data for lipidated peptides at different pH values.](image) Measurements of IPP4 and IPP5 conducted in 25 mM phosphate buffer at pH 6.5, (red open circles), pH 7.0 (orange open circles) and pH 7.5 (light green open circles) and 25 mM Tris buffer at pH 7.7 (dark green open circles), pH 8.2 (light blue open circles) and pH 8.7 (dark blue open circles). A) ThT assays of peptide aggregation for ~150 µM IPP4 from pH 7.5 to 8.7 at 37 °C. For each pH, the average of triplicate runs is shown. B) ThT fluorescence for ~150 µM IPP5 from pH 6.5 to 8.7 at 37 °C. For each pH, the average of triplicate runs is shown. Figure 5.6. Three-dimensional aggregation landscapes illustrating the ThT assay data for peptide aggregation for lipidated peptides at different pH values. A) ThT assays of peptide aggregation for 150 µM IPP4 from pH 7.5 to 8.7 at 37 °C. For each pH, the results of triplicate runs are shown. The x-axis shows the pH value, z-axis time (h) and the y-axis ThT fluorescence (arbitrary units) with 0-1000 (blue), 1000-2000 (red), 2000-3000 (green) and 3000-4000 (purple). B) ThT fluorescence for 150 µM IPP5 at pH 6.5 to 8.7 at 37 °C. For each pH, the results of triplicate runs are shown. The x-axis shows the pH value, z-axis time (h) and the y-axis ThT fluorescence (a.u.) with 0-500 (blue), 500-1000. At pH values between 6.5 and 7.5, the samples show no lag phase and nearly no growth phase, but rapidly reach a moderately high ThT fluorescence plateau which may indicate fibril formation. However, on increasing the pH to 7.7, aggregation is significantly slower and by pH 8.2 and 8.7, there is relatively little fibril formation over the time course of the experiment as indicated by increased ThT fluorescence. Indeed, under these conditions, the ThT signal decreases not increases with time. It is worth mentioning that all samples of IPP5 from pH 7.5 to 8.7 show an initial ThT signal that does not start at zero, in contrast to the data for IPP4. Similarly, at pH 7.0 and 7.5, once the moderately high fluorescence signal has been reached, it then decreases slowly over time. 3D plots of the ThT data are shown in Figure 5.6A & B, illustrating the two different regions of aggregation behaviour for each peptide. 5.4 Aggregation Kinetics of Lipidated Peptides at Different Peptide Concentrations The peptide concentration dependence of the aggregation of IPP4 and IPP5 at different pH values probed by ThT fluorescence measurements are shown in Figure 5.7. The ThT signal for IPP4 in phosphate buffer at pH 7.5 at higher peptide concentrations are sigmoidal in shape and data were fitted to Equation 2.4 and 2.5, to obtain values of $t_{1/2}$ and lag time. At lower peptide concentrations, 25 and 50 $\mu$M, the fits did not converge and therefore values for $t_{1/2}$ and lag time were not determined for these concentrations. Both kinetic parameters, $t_{1/2}$ and lag time, decrease with increasing peptide concentration, Figure 5.8A & C. IPP4 in Tris buffer at pH 8.2 also showed a sigmoidal increase in ThT signal; however, the amplitude of the change in signal was approximately four times lower than at pH 7.5, Figure 5.7B. These data were also fit to Equation 2.4 and 2.5, and values for $t_{1/2}$ and lag time shown in Figure 5.8B & D vary rather little with peptide concentration. It is interesting to note that there is a higher variance of the data at pH 8.2 compared with pH 7.5, Figure 5.7B. In contrast to IPP4, the ThT kinetics of IPP5 aggregation at pH 6.5 starts at relatively high ThT fluorescence values but the signal does not change significantly with time, Figure 5.7C. At pH 7.5, there is no lag phase, but a short sharp increase in ThT signal to some maximum is observed which is followed by a slow decrease in signal over longer times, Figure 5.7D. In both cases the maximum ThT signal for each peptide concentration is approximately linearly proportional to the peptide concentration, Figure 5.7C & D. Figure 5.7. ThT aggregation assays of lipidated peptides at different peptide concentrations and pH values. All samples were measured at the following peptide concentrations: 25 µM (pink), 50 µM (orange), 75 µM (blue), 100 µM (dark blue), 125 µM (green), and 150 µM (dark green). All experiments performed at 37 °C. A) IPP4 in 25 mM phosphate buffer at pH 7.5. The solid lines show the best fit of the data to Equation 2.4. B) IPP4 in 25 mM Tris buffer at pH 8.2. The solid lines show the best fit of the data to Equation 2.4. C) IPP5 in 25 mM phosphate buffer at pH 6.5. Data not fitted. D) IPP5 in 25 mM phosphate buffer at pH 7.5. Data not fitted. Figure 5.8. Kinetic parameters from the aggregation kinetics of IPP4. ThT kinetic data for six different peptide concentrations between 25 – 150 µM were fitted to Equation 2.4. Fits at lower peptide concentrations did not converge and therefore values for $t_{1/2}$, lag time and apparent growth rate are not shown for 25 and 50 µM at pH 7.5 or 25 µM at pH 8.2. The error bars show the standard deviation between triplicate measurements. A) $t_{1/2}$ at pH 7.5. B) $t_{1/2}$ at pH 8.2. C) $t_{lag}$ at pH 7.5. D) $t_{lag}$ at pH 8.2. E) Apparent growth rate at pH 7.5. F) Apparent growth rate at pH 8.2. 5.5 Imaging of Higher-Order Structure in Aggregated Samples of Lipidated Peptides The higher-order structures formed during the aggregation of the lipidated peptides, and proof of whether amyloid-like fibrils are forming or not, was assessed by SEM imaging. SEM imaging does not allow the highest resolution, but it gives a valuable overview of the higher-order structures of aggregates formed. Differences in the higher-order structure can point towards differences in the microstructure of the aggregates. Images of IPP4 aggregated in phosphate buffer at pH 7.5 recorded at different levels of magnification are shown in Figure 5.9. No fibrillar structures are observed at all at any level of magnification. Instead, roundish white dots on the barely covered region of the slide are seen, along with a sharp transition from the densely packed surface to the barely covered region, Figure 5.9C. The roundish white dots were analysed in detail: they were counted and the length of the major and minor axis of the dots were determined, Figure 5.10. It showed that the length of the major axis is Gaussian distributed with a mean of 14 nm, Figure 5.10C. Similarly, the length of the minor axis is distributed around 12 nm. Both values are linearly related to each other, Figure 5.10D. IPP4 aggregated in Tris at pH 8.2 shows different higher-order structures in comparison to samples aggregated at pH 7.5, Figure 5.11. The images at low magnification show long (>100 μm) thin species, Figure 5.11A, however, these are unlikely to be fibrils as there are many breaks in them. In some cases, thicker species can divide into two species with a sharp and well-defined angle between them Figure 5.11A. At higher magnifications, the aggregates appear curved and even smaller diameter, ~20 nm, strands are observed, Figure 5.11B & C. In the right upper corner of Figure 5.11C a strand splits into two and the widths are approximately 20 nm or 10 nm for the thicker and the thinner strands, respectively. These structures show numerous cracks, probably caused by the drying process. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample was dried on to a glass microscopy sheet. The images show the most typical of those obtained. A) Low magnification. Overview of regions with high and low peptide density. B) Higher magnification. Shows the image of a region where there is a high local concentration of aggregated peptide (Region 1). C) Highest magnification. High local density on the left and less densely populated regions of the surface on the right (Region 2). The border is marked with a red arrow. The less densely populated region shows white roundish species (orange arrow). In regions with a high density of the aggregated sample, the surface is highly porous and no clear fibrillar structure can be observed, Figure 5.11D. SEM images of samples of IPP5 before and after the aggregation process at pH 7.5 were taken, Figures 5.12 and 5.13. The sample imaged before the aggregation assay shows two different regions. One region is covered with more dense crystal-like aggregates, Figure 5.12A & C. Figure 5.10. Size of oligomer-like IPP4 species formed in 25 mM phosphate buffer at pH 7.5 A) SEM image of less densely populated region with the white roundish species. B) Binary and inverted version of Image A. C) Histogram of the number of aggregates distributed by the length of the major axis of the aggregates. The data follows a Gaussian distribution. D) Relation between the length of the major and minor axis of the aggregates. The average length of the major axis value is approximately 14 nm and for the minor axis it is 12 nm. From imaging of pure buffer these aggregates are most likely due to salt in the buffer, possibly mixed with sample but it is not possible to differentiate between them, Figures 4.14D and 4.15D. The second region shows a typical surface without dense peptide coverage, Figure 5.12B & D. The darker marks are most likely thin scratches on the glass surface. In general, the resolution of SEM is not high enough to say anything about the possible oligomeric structure of peptides before the aggregation assay. Figure 5.11. SEM images of aggregated forms of IPP4 in Tris buffer at pH 8.2. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample was dried on a glass microscopy sheet. The images show the most typical of those obtained. A-C) Show images of regions where there is a low density of aggregates, but flow marks are visible. A) Sharp and well-defined angle between two splitting flow marks (orange arrow) C) A strand splitting into two (red arrow) D) Shows a densely populated region of the surface. The same sample after the aggregation assay is shown in Figure 5.13. Two different regions were observed. A densely covered region shows a porous surface with some little holes in it, Figure 5.13A. The less densely covered region shows structures approximately 100 – 200 µm in diameter, seemingly consisting of shorter fibrils, as well as several thin short fibrils, Figure 5.13B & C. Characterisation of the fibrils showed a width of approximately 15 nm, Figure 5.13D. It is in the same range as the major axis of the roundish white dots or oligomer-like aggregates seen for IPP4 at pH 7.5, Figure 5.10. Figure 5.12. SEM images of freshly dissolved lipidated peptides of IPP5 in phosphate buffer at pH 7.5. Before the samples were incubated in the plate reader, 5 µL of freshly prepared 150 µM IPP5 was dried on a glass microscopy sheet. The images show the most typical of those obtained. A & C) Show images of regions where there is a high density of aggregates. B & D) Shows a less densely populated region of the surface. C & D are at slightly higher magnifications than A & B. Figure 5.13. SEM images of aggregated forms of IPP5 in 25 mM phosphate buffer at pH 7.5 and measurement of width of fibrils. After 144 h of incubation time in the plate reader at 37 °C, 5 µL of 150 µM sample was dried on a glass microscopy sheet. The images show the most typical of those obtained. A) Image of region where there is a high density of aggregates (Region 1). B) Less densely populated region of the surface (Region 2). C) Detail of Figure 5.13B. Arrows point towards measured fibrils. D) Normalised grey scale value plotted vs the distance orthogonal to the measured fibrils highlighted in Figure 5.13C. Each fibril was measured twice. The average width of the fibril is 15 ± 1 nm. 5.6 Secondary Structure of Lipidated Peptides To learn more about the aggregates imaged with SEM a detailed study of the secondary structure was conducted. In Chapter 4, it was shown that even a small modification to GLP-1 (C-terminal amidation) influences the secondary structure of the peptide. It is, therefore, likely that a larger modification such as lipidation may also have an effect on secondary structure. The far-UV CD spectra of IPP4 and IPP5 were measured over a range of pH values in the same way as for GLP-1 and Am-GLP-1. However, the measurements on IPP4 and IPP5 were restricted to neutral and basic pH values due to the lack of solubility at lower pHs, Figure 5.4A. The far-UV CD spectra of IPP4 were measured at pH 7.5 (phosphate buffer) and 8.0, 8.5 and 9.0 (pH of the Tris buffer at room temperature). At 37 °C, under aggregation conditions, the pH of the Tris buffers was 7.7, 8.2 and 8.7, respectively. Freshly prepared samples of IPP4 show only minimal differences in secondary structure between pH 7.5 and pH 9.0, Figure 5.14A. After the aggregation assay, the secondary structure of the samples aggregated at pH 8.2 and 8.7 show only minor changes in comparison to the freshly prepared samples, however, a clear change in the far-UV CD spectra occurs after aggregation at pH 7.5 and 7.7, Figure 5.14A. The CDPro analysis shows that this change in the far-UV CD spectra at pH 7.5 and pH 7.7 is due to the decrease of α-helical and increase of β-sheet structure. The data also show a small increase in turns, Figure 5.15A & B. Before the aggregation assay, the far-UV CD spectra of IPP5 were measured from pH 6.5 to 9.0 at six different pHs, Figure 5.14B. The secondary structure directly after the peptide was dissolved in aqueous buffer shows that, under basic conditions, a similar α-helical content to IPP4 but decreasing pH from 8.0 to 6.5 results in a loss of helicity, Figure 5.15B. After the aggregation assay, the secondary structure, of samples aggregated between pH 7.7 and 8.7, changes only slightly in comparison to the secondary structure before the aggregation assay. However, between pH 6.5 and 7.5 there is a complete change in the secondary structure after aggregation. The sample at pH 7.7 shows intermediate behaviour, Figure 5.14B & D. Figure 5.14. Far-UV CD spectra of lipidated peptides at different pH values before and after aggregation. A) Far-UV CD spectra for IPP4 in 25 mM phosphate buffer at pH 7.5 (bright green) and 25 mM Tris buffer at pH 7.7 (dark green), 8.2 (bright blue) and 8.7 (dark blue) before (dashed lines) and after aggregation (solid lines). B) Far-UV CD spectra for IPP5 in 25 mM phosphate buffer at pH 6.5 (red), 7.0 (orange) and 7.5 (bright green) and Tris buffer at pH 7.7 (dark green), 8.2 (bright blue) and 8.7 (dark blue) before (dashed lines) and after the aggregation (solid lines). C) Comparison of the far-UV CD spectra of the same samples as shown in (A) and (B) before the aggregation assay. IPP4 data shown as dashed lines and IPP5 as solid lines. D) Far-UV CD spectra of the same samples as shown in (A) and (B) after 144 h aggregation in the plate reader under the same conditions as the ThT assay. IPP4 data shown as dashed lines and IPP5 as solid lines. The far-UV CD spectra were recorded at 25 °C, while the aggregation assays were performed at 37 °C. Thus, the pH values in the Tris buffers were 0.3 pH units higher when the far-UV CD spectra were acquired compared to the pH at which aggregation took place in the plate reader. Figure 5.15. Secondary structure of the lipidated peptides at different pH values before and after the aggregation assay. The fractions are calculated from the far-UV CD spectra shown in Figure 5.14 using CDPro. A) Fractions of $\alpha$-helical, $\beta$-structure, turn and disordered structure of IPP4 and IPP5 after the peptides were dissolved, filtered and measured within 15 min. B) Fractions of $\alpha$-helical, $\beta$-structure, turn and disordered structure of IPP4 and IPP5 after aggregation. The error is given as the standard deviation of the three algorithms used to calculate the secondary structure, Section 2.10. D/O stands for disordered structure. If one compares the far-UV CD spectra before the aggregation assay of IPP4 and IPP5 directly, it can be seen that IPP5 has a less pronounced minimum at 208 and 220 nm and its maximum at 190 nm is lower compared to IPP4, Figure 5.14C. Plotting the far-UV CD spectra of the samples after the aggregation assay shows again the similarity in the behaviour of both peptides at basic pH values, Figure 5.14D. It is worth mentioning that the sample of IPP4 at pH 7.5 shows certain similarities with the spectra of IPP5 at pH 7.7. The far-UV CD data were further analysed using CDPro. It shows that IPP4 immediately after it is dissolved has more $\alpha$-helical structure at pH 7.5, 8.0 and 8.5 in comparison to IPP5. At pH 9.0, the amounts of $\alpha$- versus $\beta$-structure are similar for both peptides. For freshly prepared IPP5, the fraction of $\alpha$-helical structure is higher with increasing pH. After aggregation, the CDPro analysis shows only minor changes of their $\alpha$-helical content for both peptides incubated at pH 8.2 and pH 8.7. In contrast, from pH 7.7 towards more acidic pH values the fraction of $\alpha$-helix decreases and $\beta$-structure increases for both peptides after 144 h of incubation in the plate reader. After the aggregation assay and at pH 7.5, IPP5 has a higher fraction of $\beta$-structure in comparison to IPP4, despite showing a lower ThT signal, Figures 5.5A & B and 5.15B. ### 5.6.1 Influence of Lipidation and Amidation on the Secondary Structure A direct comparison of the secondary structure of all four peptides investigated is shown in Figure 5.16. Immediately after the peptides are dissolved Am-GLP-1, IPP4 and IPP5 show, under all conditions, more $\alpha$-helical structure than $\beta$-structure. The fractional range of $\alpha$-helicity spans from 0.3 to 0.5, whereas, the fraction of $\beta$-structure is always below 0.2, except for IPP5 at pH 6.5. GLP-1, the only non-amidated peptide of the four, shows a different behaviour of its secondary structure. At pH 6.5, the fractions of $\alpha$-helical and $\beta$-structure for GLP-1 are still similar to the values of Am-GLP-1, IPP4 and IPP5. However, as the pH increases, the fraction of $\alpha$-helices for GLP-1 becomes smaller and the fraction of $\beta$-structure higher, compared with the trend for the other three peptides where generally $\alpha$-helicity increases with pH with a concomitant decrease in $\beta$. For GLP-1, from pH 8.0 upwards, the fraction of $\beta$-structure even exceeds the fraction of $\alpha$-helical structure, Figure 5.16A. The main observation after aggregation is that the $\alpha$-helical fraction for both lipidated peptides stays at a high level at basic pH values, consistent with the SEM data which indicate that neither lipidated peptide form large amounts of fibrils under these conditions. This suggests that the lipidation stabilises the $\alpha$-helical structure, especially at basic pH values. The non-lipidated peptides GLP-1 and Am-GLP-1 show $\alpha$-helical fractions approaching zero and increased amounts of $\beta$-structure, consistent with the fact that these have formed amyloid-like fibrils over the 144 h incubation period. Figure 5.16. Secondary structure of GLP-1, Am-GLP-1 and the lipidated peptides at different pH values before and after the aggregation assay. The fractions are calculated from the far-UV CD spectra shown in Figures 4.29, 4.30, 4.31 and 5.14 using CDPro. A) Fractions of $\alpha$-helical and $\beta$-structure of GLP-1, Am-GLP-1, IPP4 and IPP5 after the peptides were dissolved, filtered and measured within 15 min. B) Fractions of $\alpha$-helical, $\beta$-structure, turn and disordered structure of GLP-1, Am-GLP-1, IPP4 and IPP5 after aggregation. The error bars show the standard deviation of the three algorithms used to calculate the secondary structure, Section 2.10. 5.7 Size of Lipidated Peptide Oligomers Size-exclusion chromatography (SEC) measurements were conducted by Eva Brichtová to analyse the oligomer distribution of the lipidated peptides.\textsuperscript{341} SEC is a chromatographic method in which molecules are separated by their hydrodynamic radii with larger species eluting earlier from the column than smaller ones. IPP4 and IPP5 have been measured at a concentration of 135 µM in 25 mM phosphate, pH 7.5. Before each run, the samples were filtered to remove any larger insoluble aggregates. At the first time point, IPP4 and IPP5 show two different size distributions, Figure 5.17. IPP4 shows one broad peak eluting at 13.1 mL (A) (Figure 5.17), whereas IPP5 shows three different peaks eluting at 13.2 mL (A), 14.4 mL (B) and a minor peak at 17.6 mL (C), Figure 5.17. Figure 5.17. IPP4 and IPP5 oligomer distribution analysed by SEC and estimated sizes of oligomers. The SEC experiments were conducted by Eva Brichtová and are also described in her First Year Report. IPP4 and IPP5 samples at a concentration of 135 µM and in 25 mM phosphate buffer at pH 7.5 were analysed on a Superdex® 200 Increase 10/300 GL column. The samples were filtered prior to the SEC analysis. The molecular weight and Stoke’s radius of oligomers were estimated using calibration curves. The molecular weight and Stoke’s radii were determined to get a better insight into the species present. However, the values obtained are rough estimates only because the commercially-available SEC calibration kits are purely based on globular proteins, Section 2.18. The estimated number of peptide subunits in the different oligomeric species are 24/25 for peak A, 14 for peak B and 3 for peak C. A comparison of these results with the literature shows that Liraglutide populates a similar-sized oligomer as IPP5. The studies of Wang et al. and Bothe et al. on Liraglutide, a non-amidated analogue of IPP5, identify oligomers consisting of 12/13 peptide molecules at pH values below pH 7 which is similar in size to those found for IPP5 in peak B, however, under different pH conditions.\textsuperscript{91,227} For Liraglutide, smaller oligomers comprising of approx. 7 monomers were found at more basic pH values.\textsuperscript{91,227} \begin{figure}[h] \centering \includegraphics[width=\textwidth]{figure5_18.png} \caption{IPP4 and IPP5 oligomers distribution at two different time points analysed by SEC.} \end{figure} The SEC experiments were conducted by Eva Brichtová and are also described in her First Year Report. IPP4 and IPP5 samples at a concentration of 135 µM and in 25 mM phosphate buffer at pH 7.5 were analysed on a Superdex® 200 Increase 10/300 GL column. The samples were filtered prior to the SEC analysis. A) IPP4 measured at t = 0 h and after 24 h of incubation. B) IPP5 measured at t = 0 h and after 24 h of incubation. Additional measurements were conducted on IPP4 and IPP5, to learn more about the influence of incubation on oligomer size and stability. After 24 h incubation in 25 mM phosphate buffer (pH 7.5) at 37 °C and agitation with 180 rpm, the oligomer distribution of IPP4 changed only marginally and only a minor shift of the maximum of the main peak was observed and a small new peak appeared, Figure 5.18A. This small peak elutes at around 8 mL and most likely results from the formation of higher molecular weight oligomers which elute in the void of the column, Figure 5.18A. IPP5 analysed after 24 h of incubation shows an increase in a high molecular weight peak eluting at around 7.5 mL. Similar to IPP4 this peak is attributed to large $M_w$ oligomers which elute in the void volume of the column. The results for IPP5 also showed a decrease in the oligomeric peaks eluting at 13.2 mL (A) and 14.4 mL (B), Figure 5.18B. The reduction of peak B is more pronounced than that of peak A, Figure 5.18B. It is possible that this oligomer (peak B) is on-pathway and crucial for the further self-assembly of IPP5 into larger species. The faster self-assembly of larger soluble oligomeric species for IPP5 in comparison to IPP4 is in agreement with the ThT assay data which shows a steep increase in ThT fluorescence within the first 24 h only for IPP5 and not for IPP4 at pH 7.5, Figure 5.5A & B. Dynamic light scattering (DLS) data were collected for 150 µM IPP5 in 25 mM phosphate buffer at pH 7.0 and 7.5 and in 25 mM Tris buffer at pH 8.5 and 9.0, Figure 5.19A-D. Note that the Tris buffer samples change their pH at 37 °C, under aggregation conditions, to pH 8.2 and 8.7. In all four samples, 60-80% of the intensity of the monomeric peptide is represented by the first peak (Peak I), Figure 5.20A. The actual percentage of the species represented by Peak I is expected to be even higher than the given percentage of the intensity as smaller particles scatter light less and have therefore a lower intensity in comparison to larger species. The apparent hydrodynamic diameters of these peaks are approximately 7 nm at pH 7.5, 8.5 and 9.0 (pH values at 25 °C) and 14 nm at pH 7, Figure 5.20B. The smaller hydrodynamic diameter suggests that the peptide at pH 7.5, 8.5 and 9.0 stays in the solution as monomers or assembles into small oligomers like dimers. The larger oligomers with a diameter of approx. 14 nm formed at pH 7 likely contain more monomeric units than those species formed under more basic conditions. Figure 5.19. Results of DLS measurements to determine the size of IPP5 species in solution at time zero and at four different pH values.* DLS measurements of 150 µM IPP5 at 25 °C shown as intensity vs. hydrodynamic diameter. The darker pink areas show the overlap of three repeated measurements. A) 25 mM phosphate buffer at pH 7.0, B) 25 mM phosphate buffer at pH 7.5, C) 25 mM Tris buffer at pH 8.5 and D) 25 mM Tris buffer at pH 9.0. At 37 °C, under aggregation conditions, the Tris buffer pH values change to pH 8.2 and 8.7. At all pH values studied, a smaller fraction of the total amount of peptide also forms oligomeric species with approx. hydrodynamic radii between 200 and 300 nm (Peak II). Here, a difference can again be seen between pH 7 and the IPP5 at more basic pH values, where the former shows a higher size variance of the larger aggregates. Figure 5.20. Analysis of DLS results: size and amount of smaller species of IPP5 formed at four different pH values. Percentage of intensity and diameter of aggregates of peak I observed by DLS measurements of samples of 150 µM IPP5 at 25 °C. IPP5 was measured in 25 mM phosphate buffer at pH 7.0, 25 mM phosphate buffer at pH 7.5, 25 mM Tris buffer at pH 8.2 (37 °C) and 25 mM Tris buffer at pH 8.7 (37 °C). A) Percentage of IPP5 found in peak I at different pH values. B) Apparent hydrodynamic diameter of species in peak I vs pH. After 144 h of incubation of IPP5 in a ThT plate reader at pH 7.0 and 7.5, the main peak observed in the DLS moves and indicates an increased amount of species with hydrodynamic diameters of around 200 nm, Figure 5.21A & B. These aggregates are likely either short fibrils or oligomers which have β-structure because at pH 7.0 and 7.5 no distinct lag time was observed in the ThT kinetics, Figure 5.5B, and similarly sized aggregates are already present at the first time point. Under these conditions, the signal corresponding to the smaller species with hydrodynamic diameters of approximately 7 or 14 nm, respectively, has nearly entirely vanished. At pH 8.2 and 8.7, the DLS measurements were not reproducible and, for unknown reasons, showed single spikes with high variance, Figure 5.21C & D. This may be because of the concentration of peptide used in these experiments, which was chosen to be consistent with other biophysical measurements, but which is rather low for DLS. Figure 5.21. Results of DLS measurements to determine the size of IPP5 species in solution after 144 h incubation at 37 °C and at four different pH values. DLS measurements performed at 25 °C of samples of 150 µM IPP5 which have been incubated with shaking at 37 °C. Data shown as intensity vs. hydrodynamic diameter. The darker pink areas show the overlap of three repeated measurements. A) 25 mM phosphate buffer at pH 7.0, B) 25 mM phosphate buffer at pH 7.5, C) IPP5 incubated in 25 mM Tris buffer at pH 8.2 and D) IPP5 incubated in 25 mM Tris buffer at pH 8.7. 5.8 Discussion 5.8.1 Solubility of Lipidated Peptides is Restricted to Neutral and Basic Conditions The solubility of IPP4 and IPP5 is dominated by the influence of the lipid, which causes very low solubility at acidic pHs. Towards neutral and more basic pH values, the solubility increases for both peptides. For IPP4 this starts around pH 7.5, in comparison to pH 6.5 for IPP5. This difference is probably due to the differences in net charge at these pH values, where IPP4 has a smaller net charge than IPP5. The measured pI values of pH 6.1 and 5.6 for IPP4 and IPP5, respectively, are in good agreement with the solubility data, a significant increase in solubility being observed 1 to 1.5 pH units above the pI. The slightly higher difference of 1.4 pH units for IPP4 can be explained by the different slope of the net charge versus pH. The relative net charge of IPP5 increases faster than for IPP4 with increasing pH in this range. 5.8.2 Is There Evidence that Lipidated GLP-1 Peptides Form Amyloid-Like Fibrils? IPP4 For IPP4, the fact that there is a sigmoidal increase in ThT fluorescence over time when it is incubated at 37 °C at pH 7.0 and 7.5 and the fact that the final ThT fluorescence is higher than that of GLP-1 and Am-GLP-1 under similar conditions, indicate that IPP4 might form fibrils under these conditions. In support of this, the far-UV CD spectra show clear increases in β-structure at pH 7.0 and 7.5. However, the SEM images recorded at the end of the incubation at pH 7.5 do not show any evidence of fibril formation. Nevertheless, there are regions which show dense peptide coverage possibly due to amorphous aggregation, indicating that some aggregation phenomenon has taken place. The density of coverage and the amorphous aggregation may well obscure any fibrils present in the sample. In contrast, IPP4 at pH 8.2 after incubation at 37 °C for 144 h, shows a considerably lower ThT fluorescence either indicative of the formation of a smaller quantity of amyloid-like fibrils or a different species of aggregate that cannot bind ThT, or can bind only weakly. These results are consistent with the observed lack of change in the far-UV CD spectra of IPP4 before and after aggregation suggesting that amyloid-like fibrils are not formed at this pH. The SEM results are consistent with this: no amyloid-like fibrils are seen, however, there is some evidence of aggregated species of unknown type. IPP5 For IPP5, an increase in ThT fluorescence was observed after incubation at 37 °C for 144 h at pH 6.5 and 7.5, albeit to a much smaller degree than IPP4 under similar conditions. The lower ThT fluorescence is despite the fact that IPP5 has a higher negative net charge in comparison to IPP4 under basic conditions which should attract the positively charged ThT to a greater extent. It has been shown that the $\zeta$-potential of fibrils, which is strongly correlated to the net charge, influences the binding affinity of the positively charged Thioflavin T.\textsuperscript{291} Despite the smaller change in ThT fluorescence, there was a noticeable change in the far-UV CD spectra of IPP5 under these conditions, the CDPro analysis indicating a pronounced increase of $\beta$-structure and a decrease in $\alpha$-helical structure. At pH 7.5, the aggregated form of IPP5 showed some evidence of fibrils in the SEM imaging, however, the observed fibril-like structures differ from the typical rigid fibrils observed for GLP-1 and Am-GLP-1, Figure 5.13C. In this case, the IPP5 aggregates resemble more closely the thin curly fibrils observed in the early stages of aggregation of GLP-1, Figure 3.15B. At pH 7.7 and above, there is little change in ThT fluorescence from start to end of aggregation, and the difference in the far-UV CD spectra before and after aggregation is not as pronounced as for the more acidic pH values. Thus, there is little evidence that amyloid-like fibrils have formed under these conditions. 5.8.3 ThT Fluorescence Caused by Non-Fibrillar Structures Although an increase in ThT fluorescence is frequently used as an indicator of amyloid-fibril formation, it cannot be excluded that other aggregates, such as oligomers, can also interact with and increase the fluorescence of ThT. This is because ThT does not recognize fibrils per se, but it is assumed to bind to the molecular grooves which are typically found on the surface of amyloid fibrils.$^{362}$ This raises the question of whether the increase in ThT fluorescence observed for both IPP4 and IPP5 at near neutral pH values is due to fibril formation or the formation of some other aggregated species. The question arises, therefore, what is causing the high fluorescence signal if not amyloid-like fibrils? From the SEM imaging, it appears that IPP4 at pH 7.5 shows two different kinds of aggregated morphologies. The glass sheet was mostly covered by a dense rather amorphous cover of peptides, which constituted most of the peptide molecules. However, small oligomers could be observed in the less densely covered regions, Figures 5.9C and 5.10. It is possible that the densely covered region consists out of tightly packed oligomers and it is, therefore, not clear if there are two different species present or not. At pH 8.2 the SEM images again show an extended region with thick peptide cover and in a less densely covered region, some extended structures can be seen, however, they do not show typical rigid fibril-like structures either. In both cases, ThT may bind to the non-amyloid like aggregates observed (amorphous or with more regular structure) and increase in fluorescence giving rise to the typical sigmoidal ThT kinetics observed. The same may also be the case for IPP5, however, here some short thin fibrils were also observed. The hypothesis that ThT also binds to non-fibrillar species, also explains why the maximum ThT fluorescence of IPP5 is lower than for IPP4 despite it forming more β-structure during the aggregation process. Collectively, the results for both lipidated peptides suggest that during aggregation the peptides increase their β-structure but that this structure forms inside oligomers or other types of amorphous structures instead of amyloid fibrils. 5.8.4 Kinetics of the Formation of Aggregates The ThT data for IPP4 and IPP5 at different pH values establishes that there are three types of behaviour observed. The first, in which the ThT fluorescence increases to a high value showing standard sigmoidal kinetics, is observed for IPP4 at pH 7.5 and 7.7. In the second class, the ThT shows an immediate or rapid increase in fluorescence reaching a final value that is significantly lower than in the first case. IPP5 shows such kinetics at pH 6.5 to 7.5. In the third case, there is either little or no increase in ThT fluorescence over the time course of the experiment, and in some cases, the low starting ThT fluorescence decreases even further. This is found for IPP4 and IPP5 at pH 8.2 and 8.7. The first behaviour observed suggests an aggregation reaction that follows a classic nucleation-propagation mechanism, the second behaviour is also consistent with this, but the initial primary nucleation must be rapid. However, in the second case, the kinetics are also compatible with a mechanism in which oligomerisation does not involve a nucleation step. The third case suggests that no aggregation occurs or that the aggregated species is not capable of binding to ThT. 5.8.5 Unusual Decrease of ThT Fluorescence At pH 7.5 and higher peptide concentrations, the ThT fluorescence of IPP5 decreases linearly after reaching a maximum early in the assay, Figure 5.7D. It is interesting to note that pH 7.5 is close to the pH value where a change in aggregation behaviour is observed (pH 7.7 and higher). It is possible to speculate that if two different aggregated species with either different ThT affinities or which affect the ThT fluorescence differentially are populated under these conditions, that this slow decrease in the ThT signal, could be due to the transition from one aggregated species to another, Figure 5.22. Alternatively, the decrease could be explained by a structural change of the aggregate and therefore, a different ThT affinity or effect on fluorescence, Figure 5.22. From the amorphous structures observed with SEM for IPP5 at pH 7.5, it is likely that these are all non-fibrillar aggregates, Figure 5.13A. It may also be possible that hydroxylation of ThT causes the decrease of ThT fluorescence observed at the higher pH values.\textsuperscript{301} Figure 5.22. ThT fluorescence caused by non-fibrillar structures. The formation of oligomers X and Y is described by the primary nucleation rate constants $k_{nX}$ and $k_{nY}$ as well as the dissociation rate constants $k_{dX}$ and $k_{dY}$. The transition between oligomers X and Y and the structure change between oligomer X and X* is defined by the rate constants $k_{XY}$, $k_{YX}$, $k_{XX^}$ and $k_{X^X}$, respectively. If smaller non-fibrillar aggregates bind ThT, as suggested by the IPP4 and IPP5 data, a change from one species X to another species Y can cause a change in ThT fluorescence $f$. Similarly, a conformational change illustrated by the change in structure from X to X* can have the same effect. 5.8.6 Peptide Concentration Dependence of the Aggregation Kinetics IPP4 The aggregation kinetics at different peptide concentrations of IPP4 showed two distinct characteristics. At pH 7.5, the peptide aggregated faster with increasing peptide concentration, consistent with a classic nucleation-propagation mechanism. Under more basic conditions (pH 8.2), the kinetics change and slightly shorter but constant lag times show that the aggregation process must be influenced by an additional factor next to the nucleation-propagation mechanism, for example, off-pathway species. The observed decrease of the ThT intensity under basic conditions is most likely influenced by a change of the populated species, a structural change of the aggregate or the hydroxylation of ThT$^{301}$ as discussed in Section 5.8.5. IPP5 The concentration dependence of IPP5 aggregation was measured at pH 6.5 and 7.5. In both cases, no lag time is visible in the aggregation kinetics which may be due to the lag phase being shorter than the time needed to prepare the samples before the aggregation assay is started or may be due to seeds in the freshly prepared samples. There is an approximately linear relationship between the final ThT signal and the peptide concentration, suggesting some type of aggregation process has occurred. It is most likely not caused by fibrils but ThT binding to oligomers, assuming that oligomers form rapidly after the peptide is dissolved in aqueous buffer and can bind to and restrict the rotation of the ThT leading to an increase in fluorescence. 5.8.7 Different Oligomer Sizes Influenced by Sequence and pH The SEC measurements of IPP4 and IPP5 at pH 7.5 established that the two peptides can form oligomeric species, A, B and C. IPP4 forms only oligomers of type A which contain approx. 24 monomers. Oligomers of the same size were also found in smaller amounts for IPP5, the majority of which forms smaller oligomers containing approx. either 14 or 3 monomers. The different-sized oligomers of IPP5 can be compared to oligomers found for Liraglutide, a non-amidated analogue of IPP5. Frederiksen et al. showed by small-angle X-ray scattering (SAXS) that at pH 8.1, Liraglutide assembles into oligomers with a global shape of hollow elliptical cylinders which are either hexa-, hepta- or octamers depending upon peptide concentration.\textsuperscript{363} Asymmetric flow field flow fractionation-UV-multi-angle light scattering (AF4-UV-MALS) measurements confirmed the size of the oligomers as hexamers – the solutions being at lower concentrations in this case.\textsuperscript{363} Additional simulations predicted heptamers as the most likely size of the oligomers.\textsuperscript{363} These findings were reproduced by Wang et al., who also described one additional larger oligomer using static-light scattering (SLS).\textsuperscript{227} They described a pH-dependent assembly of octamers below pH 7.0 and dodecamers under more basic conditions. Measurements were performed in a range between pH 6.4 and 8.7 at a concentration well over that used in the previous study (over 1 Bothe et al. found similar results and reported heptamers below pH 7 and oligomers consisting out of 13 monomeric units above pH 7. The size of the oligomers was measured using SEC and online DLS and MALS.$^{91}$ IPP5 forms a similar-sized oligomer to Liraglutide with approx. 14 monomer subunits. However, it forms these oligomers at pH 7.5, a pH at which Liraglutide assembles into smaller heptamers. IPP5 oligomers appear to be similar in size to the larger oligomers of Liraglutide detected at high concentrations using static light scattering$^{227}$, suggesting that IPP5 and Liraglutide may populate similar species, albeit under different conditions. Importantly, IPP5, despite having a higher propensity than Liraglutide to form larger oligomers, still assembles further into even bigger aggregates at lower pH values close to and below pH 7. The differences observed between IPP5 and Liraglutide are most likely caused by the difference in net charge or different concentrations at which the measurements were conducted. Figure 5.23. Influence of different on-pathway oligomers on the aggregation kinetics. Different sized on-pathway oligomers at two different pH values associated with different lag times in the aggregation kinetics. F and F* may be fibrils but they may also be some other form of aggregate, for example amorphous aggregate. The process is described by the primary nucleation rate constants $k_{nA}$ and $k_{nB}$, the dissociation rate constants $k_{nA^{-}}$ and $k_{nB^{-}}$, the rate constants $k_{AB}, k_{BA}, k_{AF}$ and $k_{nF^{+}}$, the concentrations of the oligomers $c_A$ and $c_B$ and the oligomer size $n_B$ and $n_A$. A comparison of the aggregation propensity of IPP4 and IPP5 using the ThT assay data, Figure 5.7, shows that IPP5, which is initially self-assembled into smaller oligomers, than IPP4, aggregates faster, in agreement with results on Liraglutide. Bothe et al. showed that samples with smaller oligomers (pH 8.1) also aggregate faster.\textsuperscript{91} Therefore, it seems that the size and concentration of oligomers may have a direct effect on the aggregation kinetics, independent of lipidation site, C-terminal amidation or pH, Figure 5.23. ### 5.8.8 Two Different Aggregation Behaviours That Depend on pH The data for both lipidated peptides, IPP4 and IPP5, show an apparent change in their aggregation kinetics depending on pH, Figure 5.5. A possible explanation for this is that the peptides follow different aggregation pathways to each other, and pathways can vary with pH, Fig. 5.23. For example, IPP4 and IPP5 may populate different-sized oligomers to each other and the size of the oligomers may vary with pH. In support of this hypothesis, a difference in the size of smaller oligomers was measured by DLS for IPP5 between pH 7.0 and 7.5. A similar pH-induced switch between two different oligomeric species was found for Liraglutide by Wang et al. and Bothe et al. (N.B. Liraglutide is the same as IPP5 but lacks the C-terminal amidation, see Section 5.8.7).\textsuperscript{91,227} The fact that IPP4 and IPP5 both change their aggregation behaviour at a slightly more basic pH value than that observed with Liraglutide can be explained by the lower pI of Liraglutide and subsequent higher negative net charge under these conditions in comparison to IPP4 or IPP5. ### 5.8.9 Influence of the Amidation and Lipidation on the Secondary Structure The attachment of a spacer and fatty acid group to Am-GLP-1 affects the secondary structure of the peptide and leads to an increase in $\alpha$-helical structure in freshly dissolved peptide samples. However, amidation at the C-terminus has a similar significant effect on secondary structure than the lipidation itself even though this is a much larger modification, Figure 5.16A. This finding underlines the potent influence of the C-terminus amidation on the secondary structure of GLP-1-like peptides and potentially the role of net and local charge on secondary structure. 5.8.10 Conclusions One of the most significant influences of lipidation is on peptide solubility. The lipidation restricts the solubility to neutral and basic conditions. This may be due to the change in the net charge of the molecule but is more likely associated with the addition of a large hydrophobic fatty acid moiety. The lipidation also influences the secondary structure. Most notable is the higher fraction of $\alpha$-helical structure in freshly dissolved samples, however, C-terminal amidation has also been shown to have a similar effect. The fact that IPP4 shows no formation of fibrils despite having a sigmoidal shaped increase of its ThT fluorescence and an increase of $\beta$-structure with time indicates that the ThT signal and change in secondary structure is not always correlated to the formation of amyloid-like fibrils. The ThT signal is, in this case, most likely caused by ThT binding to oligomeric structures or amorphous aggregates or both\textsuperscript{362} which still form partial $\beta$-sheet structure. Lipidated peptides often form micelles or micelle-like structures due to their amphiphilic nature. For example, for the lipidated analogue of the gut-derived peptide hormone PYY$_{3-36}$, was shown to forms micelles containing lipopeptides with an $\alpha$-helical conformation.\textsuperscript{34} The amount of $\beta$-structure, as measured by far-UV CD and indirectly by ThT binding, leads to the conclusion that if IPP4 forms micelles under these conditions, they must have some $\beta$-sheet structure. It can also be concluded that the observed amount of $\beta$-structure is not correlated with the intensity of the ThT fluorescence. For example, IPP5 shows a lower ThT fluorescence than IPP4, despite the formation of thin fibrils and the most substantial observed increase of $\beta$-structure. This is even more striking due to the fact that IPP5 has a higher negative net charge under basic conditions which should lead to a better binding of positively charged ThT.\textsuperscript{291} It would be worth studying the aggregates in more detail by cryo-TEM and SAXS as undertaken for PYY by Hutchinson \textit{et al.} to learn more about these self-assembly structures. Similar to Liraglutide, a pH-dependent change in aggregation behaviour has been described here for IPP4 and IPP5. In this study, different types of aggregation kinetics were observed dependent upon peptide and pH. A switch between behaviours occurred at pH values approx. 2 units above their pI value. The different aggregation behaviour is associated with the formation of different sized oligomers or micelle-like structures, these being influenced by the sequence of the peptide as well as the pH conditions. 6 CONCLUSIONS AND FUTURE WORK 6.1 Summary and Conclusions 6.1.1 Background The work presented in this Thesis is focused on the physical stability and aggregation kinetics of peptides belonging to the GLP-1 family, which is influenced by parameters such as pH, peptide concentration, net charge and chemical modifications (lipidation). Protein/peptide aggregation is a very widely studied topic and draws its importance on one hand from its connection to several human diseases, for example, Alzheimer’s, Parkinson’s or Huntington Diseases,\textsuperscript{37} and on the other hand from issues faced by the pharmaceutical industries who use peptides as biopharmaceuticals.\textsuperscript{364–366} GLP-1 receptor agonists are under development and used to slow digestion and help lower blood sugar levels.\textsuperscript{226,256,262,367} However, the use of therapeutic peptides can be challenging because of problems with their physical stability during long-term storage because of fibrillation and precipitation or their short half-life \textit{in vivo} after injection.\textsuperscript{368} Understanding the formation and proliferation of peptide aggregates under a wide range of conditions is, therefore, of great interest scientifically as well as commercially.\textsuperscript{369} The results of this study have led to a better understanding of the mechanism of aggregation and amyloid formation of GLP-1 and three GLP-1 analogues. GLP-1 is a naturally occurring incretin hormone, and even though it is in extensive use for medicinal purposes, our knowledge about its aggregation kinetics and understanding of this self-assembly process is limited. A specific focus of these studies was to gain further information on, and understanding of, the unusual behaviour of the aggregation kinetics with respect to its peptide concentration dependence as had been shown previously by the Jackson group.\textsuperscript{5} In particular, the aim of the studies presented in this Thesis, was to extend the preliminary studies conducted at pH 7.5-8.2 to acidic pH values and to use time-course experiments to gain further insight into the different species populated during aggregation under different conditions. In addition, it was crucial to compare the results on the lipidated GLP-1 analogues investigated here with those published for a different lipidated GLP-1 variant, Liraglutide. It had already been shown by Wang and co-workers that changes in pH have significant influence on the aggregation kinetics of Liraglutide.\textsuperscript{227} In this case, two different sized oligomers were shown to be populated at different pH values.\textsuperscript{227} For the same modified peptide, it was later shown by Bothe \textit{et al.} that an increase in the peptide concentration, lead to longer lag times in aggregation experiments.\textsuperscript{91} \subsection{6.1.2 Summary of Experimental Chapters} In this Thesis, the first approach was to undertake a more detailed study of GLP-1, Chapter 3, extending the pH range over which the aggregation was monitored. Not only was the aggregation of GLP-1 measured over a wide range of conditions but also at different timepoints to learn more about the mechanism underpinning its aggregation kinetics. In the second study, Chapter 4, the aggregation kinetics of a C-terminal amidated analogue Am-GLP-1 were established and compared to those obtained for GLP-1. The amidation, a rather small perturbation with a predictable influence on the net charge of the peptide, was shown to perturb the aggregation kinetics in a pH-dependent manner. The results enabled the influence of net charge on the aggregation kinetics of GLP-1 and Am-GLP-1 to be quantified. In the final study, the aggregation kinetic of two lipidated analogues of Am-GLP-1 were investigated and compared with those already obtained for Am-GLP-1 as well as GLP-1, Chapter 5. In all three Chapters, a wide variety of experimental methods were employed. To study the secondary structure of the peptides far-UV circular dichroism (CD), and Fourier-transform infrared spectroscopy (FT-IR) were used. Both datasets were analysed using a singular value decomposition (SVD) method. ANS, tryptophan and ex-situ* ThT fluorescence were all measured to gain information about the changes in tertiary structure during aggregation. ThT-assays were used to follow the aggregation kinetics and to determine the lag and $t_{1/2}$ of the aggregation process, using a sigmoidal fit of the data. In addition, the ThT-assay data was also fitted with a nucleation-elongation model (NEF) to learn more about the aggregation kinetics and its rate constants. To probe the structure and size of species in solution, dynamic light scattering, atomic force microscopy and scanning electron microscopy were all employed. All experiments were performed over a wide range of conditions. ### 6.1.3 Symmetrical Aggregation Propensity Around the pI Results of measurements of the aggregation of GLP-1 under acidic conditions, Chapter 3, showed that a relatively small change in pH altered the aggregation behaviour, illustrating that the self-assembly of GLP-1 is very sensitive to pH not only in basic conditions but also in the acidic pH regime. Results showed that at pH 3.5 but not pH 3.0, off-pathway oligomers become populated leading to a change in the dependence of the aggregation kinetics on peptide concentration. The results demonstrate that the aggregation propensity and the population of off-pathway species is strongly related to the pH and the pI of the peptides. This was also shown to be true for the C-terminally amidated variant of GLP-1, Am-GLP-1. The population of off-pathway oligomers for GLP-1 and AM-GLP-1 surprisingly results in relatively long lag times close to their pIs and therefore also under conditions of relatively low net charge on the peptides. This is stark contrast to previous studies on other peptides where they were shown to aggregate faster if they carried a lower net charge.\textsuperscript{131–136} However, the findings for GLP-1 and its analogues can be explained by the fact that they have a significant propensity to form off-pathway species near their pI values, whilst other peptides, such as Aβ, do not.\textsuperscript{85,370} 6.1.4 The Net Charge Influences the Aggregation Propensity more than the Secondary Structure of the Monomer The motivation to study the aggregation of Am-GLP-1 and to compare it to that of GLP-1 came from two ideas: First, it enables the influence of the net charge of the peptide on its aggregation propensity to be determined without a significant change in the sequence and, secondly, it provides a starting point for further studies to assess the impact of chemical modification (lipidation) on physical stability. This is because the two lipidated forms of GLP-1 available are both amidated at the C-terminus. The results clearly show, for all four peptides, several properties of the peptide are correlated with net charge. Starting with the protonation sites (and state) of the peptides, these directly affect the net charge but were also shown to influence the secondary structure of the monomeric peptide as well as the pI and similarly the solubility of the peptide at different pH values. Net charge and/or secondary structure both affect the aggregation properties. Results described in Chapters 3 and 4, strongly suggest that the net charge has a more significant influence on the aggregation kinetics compared with secondary structure, Section 4.13.2. 6.1.5 Changes of Secondary Structure at pH Values near the p$K_a$ Values of Specific Side Chains Influence Aggregation Propensity The results of the studies described in Chapters 3 and 4 also suggest that the secondary structure also influences the aggregation propensity. However, the relationship between the secondary structure and the aggregation propensity is more specific to certain conditions. The far-UV CD data suggests that, especially in the acidic regime between pH 3.0 and 4.5, the de-/protonation of the side chains of aspartic acid and glutamic acid cause a significant increase of the α-helical structure of both non-lipidated peptides, Figure 4.32A. The observed change in secondary structure most likely affects the aggregation propensity of both peptides similarly. While at pH 3.0, both peptides follow nucleation-elongation kinetics with decreasing lag times with increasing peptide concentration, leads the increase in alpha-helical structure to a change of the aggregation kinetics at less acidic pH values. For example, Am-GLP-1 shows constant lag time with increasing peptide concentration at pH 4.0 and GLP-1 shows even increasing lag time with increasing peptide concentration already at pH 3.5. Both behaviours are typical for the formation of off-pathway species. The influence of the secondary structure on the aggregation propensity under these conditions may also explain why, for example, GLP-1 has similar aggregation propensities in the acidic and basic pH regimes despite having very different net charges. Notable, and against our expectations, a substantial effect of the amidation on the secondary structure of the peptide was observed under neutral and basic condition: Am-GLP-1 having more $\alpha$-helical structure than GLP-1, over wide range of conditions. It is also of note that, under all the conditions at which the aggregation kinetics follow simple nucleation-elongation kinetics where only on-pathway oligomers are significantly populated, the peptides show a higher fraction of $\beta$-sheet in comparison to $\alpha$-helical structure in the monomeric state. In summary, the data suggests the net charge is the main factor influencing the aggregation kinetics, however, under specific conditions, there is an additional effect and the secondary structure in the monomer also plays a role. ### 6.1.6 Lipidation and Amidation Increase $\alpha$-Helicity of Freshly Dissolved Peptides The lipidation of peptides is a widely used modification in peptide therapeutics which improve half-lives in vivo as well as increasing the physical stability of a peptide in vitro. The latter is significant in the improvement of drug formulations.\textsuperscript{3,371} The study of IPP4 and IPP5 described in Chapter 5 shows that the solubility of GLP-1 is greatly affected by lipidation resulting in them only being soluble at neutral/basic pH values above their pIs. It was previously reported that lipidation increases the $\alpha$-helical content of freshly dissolved samples in a study of Liraglutide, a lipidated GLP-1 analogue.\textsuperscript{224} The data presented in Chapter 5 confirms this finding and extends the conclusion to other lipidated GLP-1 analogues. However, by comparison of the data on IPP4 and IPP5 with GLP-1 and Am-GLP-1, it becomes clear that C-terminal amidation itself is responsible for the increase in $\alpha$-helicity observed. 6.1.7 Lipidated Peptides Self-Assemble to form $\beta$-Sheet Structures Independent of the Formation of Rigid Fibrils SEM imaging of the lipidated peptides which had been incubated under the same conditions as those that induced amyloid fibrils in GLP-1 and Am-GLP-1, showed that they have a much lower tendency to form rigid fibrils. At the same time, the ThT fluorescence and the far-UV CD data showed the formation of $\beta$-sheet during their aggregation. It can therefore be concluded that these two lipidated variants of GLP-1 form a $\beta$-sheet rich oligomeric structure, which does not appear to be able to convert into amyloid-like fibrils over the timescales used in this study. 6.1.8 GLP-1 Forms $\beta$-Sheet Rich Intermediate Species The time-course measurements of the secondary structure of GLP-1 under basic conditions showed that GLP-1 forms intermediate oligomers/aggregates that contain considerable $\beta$-sheet content during the lag phase. Surprisingly, these aggregates cannot bind to ThT. There is some evidence of short fibril-like aggregates already present during the lag phase, as shown by AFM in Figures 3.17D and 3.18D, however, it is likely that these species, which are likely to bind to ThT, are not present in significant amounts. This suggests that fibrillar the oligomers/aggregates formed which contribute to the increase in $\beta$-sheet signal are globular in nature. 6.1.9 pH Switch Observed for Four Different GLP-1 Analogues The lipidated variants IPP4 and IPP5 also show pH-dependent self-assembly behaviour similar to GLP-1 and Am-GLP-1. GLP-1 changes its aggregation behaviour twice, between pH 3.0 and pH 3.5 as well as between pH 7.5 and pH 8.2. Similarly, Am-GLP-1 changes its aggregation kinetics between pH 3.0 and 4.0. Also, in the basic regime, a pH switch can be observed for Am-GLP-1, however, the pH value at which this occurs is not as well defined as in the case of GLP-1. Measurements on the two lipidated peptides were restricted to the basic regime where they are soluble, but they also showed a pH-dependent aggregation behaviour. IPP4 changes its aggregation behaviour between pH 7.7 and 8.2 and IPP5 between pH 7.5 and pH 7.7. These results indicate that the pH dependence is a common feature of the aggregation of all GLP-1 analogues. The data strongly suggests that the pH value at which the self-assembly behaviour changes is related to the pI of the peptides. 6.1.10 Physical Evidence for Different Aggregates Formed Under Different pH Conditions for Individual Peptides Even though GLP-1 and Am-GLP-1 form similar fibrillar species over a wide range of pH values, there is evidence that the structure and aggregation pathways can vary. For example, GLP-1 showed different sized curly fibrils during the lag phase under acidic and basic conditions. For Am-GLP-1, variations in high-order structures were observed under neutral and basic conditions, indicating indirectly that the fibrillar structures formed might be different. Finally, both peptides also show changes in their ANS binding affinity between acidic and basic conditions. Similarly, the Trp side chain in the fibrils are more buried and has less contact with the aqueous solvent under acidic conditions. 6.1.11 Rate Constants are not Globally Valid Under Different Sample Concentrations In the last decade, much work has gone into developing methods for the fitting of kinetic data from aggregation reactions, simulation of aggregation and prediction of peptide aggregation propensity. From the fitting of experimental aggregation data for some peptides to different mathematical models, it has been possible, in some cases, to identify some of the critical processes underpinning the self-assembly reactions on the molecular level. These mathematical models have helped to generate information on the relative importance of primary nucleation, elongation, fragmentation and surfacecatalysed secondary nucleation.\textsuperscript{83,353,354} Recently, the active suppression of fibril elongation by off-pathway oligomers was shown for human and salmon calcitonin (hCT/sCT).\textsuperscript{90} In this study, attempts to fit the experimental data for the aggregation of GLP-1 and Am-GLP-1 at different peptide concentrations to a NEF model (nucleation, elongation and fragmentation) were undertaken. However, it was not possible to fit the data for different peptide concentrations globally using this model and these methods, which shows that, in this case, the rate constants of the NEF model are not independent of the peptide concentration. This is almost certainly because there are off-pathways species populated during the aggregation of GLP-1 and Am-GLP-1 requiring a more complex model and fitting algorithm to be developed. \subsection{Further Work} \subsubsection{Further Characterisation of the Structure of Oligomeric Species} To increase our understanding of the pH dependence of GLP-1/Am-GLP-1 aggregation, more detailed measurements on the size and structure of the oligomeric species populated at different pH values is essential. For some of the peptides/conditions studied, DLS and SEC were used to measure the size of the oligomers. Additional measurements using both techniques, for all four peptides over a wider range of conditions, especially close to and around the pH conditions at which all four peptides change their aggregation behaviour, would be beneficial. In addition, DLS experiments which were undertaken at different time points for GLP-1, showed a high variability, Figure 3.25A-D, likely because the concentration of peptide was insufficient. The DLS experiments should be repeated at higher peptide concentrations, and ThT aggregation assays should be performed under the same conditions to allow a true comparison of the different datasets. For a more detailed analysis of the molecular weight of the oligomers formed during aggregation, alternative techniques such as SAXS\textsuperscript{363} and SEC-MALS\textsuperscript{91,372} could be employed. Another promising approach to investigate the aggregation kinetics of peptides and small proteins is the combination of mass spectrometry (MS) and its allied technique of ion mobility mass spectrometry (IM-MS). IMS provides information on the cross-sectional area of ions in the gas phase as measured by their mobility through a buffer gas, as well as providing information on the mass of the corresponding species.\textsuperscript{373} IM-MS can therefore separate complex mixtures and ions which are indistinguishable by mass spectrometry alone. For excellent reviews on how IM-MS is used to study aggregation and amyloid formation, reporting recommendations for IM-MS data and the different IM-MS techniques used in drift-time ion mobility spectrometry (DTIMS), traveling-wave ion mobility spectrometry (TWIMS) and field-asymmetry ion mobility spectrometry (FAIMS) see Ashcroft (2010)\textsuperscript{374}, Gabelica \textit{et al.} (2019)\textsuperscript{375} and Lanucara \textit{et al.} (2014)\textsuperscript{376} To analyse the aggregation pathway of peptides and proteins using MS, and specifically ESI-MS (electrospray ionisation-MS) or nano-ES-MS (nanoflow electrospray-MS), it is crucial that non-covalently bound peptide complexes retain, at least to a certain extent, their tertiary and quaternary structure during ionisation and in the gas-phase. This has been shown to be possible in a number of cases, for example, in measurements of insulin aggregation conducted by Nettleton \textit{et al.}\textsuperscript{377} Their nano-ES-MS data showed that insulin in the presence of Zn\textsuperscript{2+} is present in a mix of dimers, tetramers and hexamers.\textsuperscript{377} The latter with two to four Zn\textsuperscript{2+} ions bound. The absence of small odd-numbered oligomers in the gas phase was in good agreement with previous measurements in solution by Lord \textit{et al.}\textsuperscript{378} which together with the findings of Nettleton \textit{et al.} provided evidence that no additional oligomers form as an artefact of the electrospray ionisation or the fact that the experiment is conducted in the gas phase.\textsuperscript{377} Bernstein and co-workers used MS techniques to compare the oligomers formed by Aβ\textsubscript{1-42} with oligomers formed by Aβ\textsubscript{1-40}.\textsuperscript{379,380} Such a comparison is of interest because their propensity to aggregate into amyloid fibrils is very different. Aβ\textsubscript{1-42} showed evidence for the formation of dimeric, tetrameric, hexameric and dodecameric oligomers, whereas Aβ\textsubscript{1-40} showed only evidence of dimer and tetramer.\textsuperscript{379,380} IM-MS was also successfully used in a study of Aβ\textsubscript{10-30}. This fragment, containing the Aβ amyloid core region, showed the presence of monomers, dimers, trimers, tetramers, pentamers and hexamers.\textsuperscript{381} To gain more information about the structure, Jablonowska \textit{et al.} also combined their IM-MS experiments with HDX.\textsuperscript{381} The results indicated no difference in the rate of exchange for different oligomers suggesting that the oligomers lack a defined or stable structure or that the exchange of monomeric subunits is fast. A comparison with $^{15}$N-labeled peptides confirmed the latter and showed evidence of an exchange of monomers with subunits in the oligomers on a sub-second time scale.\textsuperscript{381} Together, these results show that IM-MS can be a powerful method to study the aggregation kinetics and the formation of oligomers arising from monomers. However, IM-MS results have to be considered carefully. It is, for example, not immediately given that every detected species in the gas phase is also naturally occurring in solution and not merely an artefact of the ionisation technique. It is also possible that different species are suppressed. This question is closely related to the general challenge of proving that fibril formation \textit{in vivo} can be reproduced \textit{in vitro}. Both can only be solved by carefully comparing the results of many different biophysical techniques. 6.2.2 Further Characterisation of the Atomic Structure of Fibrils under Different pH Conditions The studies presented in this Thesis showed some evidence that GLP-1 and Am-GLP-1 form different aggregates under different pH conditions, Section 6.1.10. Additional, solid-state NMR measurements could resolve if the differences observed in the aggregates are caused by altered atomic structures and conformations of the β-strands forming the β-sheets. This would also enable a comparison to published results on the fibrils of glucagon formed under acidic conditions, in which the entire peptide length is involved in cross-β bonding.\textsuperscript{65} 6.2.3 Is the Aggregation of GLP-1 and GLP-1 Analogues Influenced by Liquid-Liquid Phase Transition or Gelation? IM-MS methods discussed in Section 6.2.1 can be described as bottom-up approaches measuring the initial steps in aggregation, which consequently influence the aggregation behaviour. Alternatively, a detailed study of the bulk behaviour of dissolved peptides and therefore, a top-down approach could also lead to valuable insights. A broader comparison between the ThT fluorescence and the change of the turbidity or viscosity of the samples could provide information on whether the system undergoes a liquid-liquid phase transition or gelation is happening. A change of these parameters would raise the question of whether they influence the aggregation kinetics or not. Wang et al. described a liquid-liquid phase transition (LLPS) for six palmitoylated as well as one unconjugated incretin peptides.\textsuperscript{382} For the lipopeptide, IP5 which has a pI of 4.0 and molecular weight of 4500 Da, quasi-elastic light-scattering was measured at several pH values between pH 5.5 and 7.42. The peptide solution appeared either in a clear or cloudy phase depending on the temperature, which could be changed reversibly by lowering or increasing the temperature. The data showed that the temperature at which phase separation occurred decreased with increasing pH and therefore increasing net charge on the peptide. The peptide concentrations used were very high, starting at 2250 µM, and were at least a magnitude higher in comparison to the concentrations used in the studies undertaken and reported in this Thesis. Gelation caused by peptides and especially peptide amphiphiles has been previously reported.\textsuperscript{34,72,383–386} The preferred secondary structure of peptides forming hydrogels is the β-sheet structure,\textsuperscript{386} however, hydrogels can also form from peptides rich in α-helical structure.\textsuperscript{387} A detailed study of the potential gelation of GLP-1 and GLP-1 analogues samples could clarify if gelation occurs under the conditions used in these studies. 6.2.4 Complementary Experiments for a Deeper Understanding of the Effect of Lipidation One primary aim of this study was to learn more about the influence of lipidation on the physical stability of GLP-1. Am-GLP-1 was studied in detail to be able to compare its aggregation kinetics with the kinetics of the lipidated peptides which are both analogues of Am-GLP-1. However, both lipidated peptides had additional modifications of their sequence to remove lysine side chains to avoid additional covalent attachment of the spacer and fatty acid. In these cases, a lysine was mutated to arginine which retains the positive charge. It is assumed that these mutations have a rather small effect on the aggregation behaviour. However, it was shown in a separate study that substitution of lysine with arginine can influence a peptide’s aggregation kinetics.\textsuperscript{388} Therefore, it would be valuable to also measure the sequences of Am-GLP-1 which correspond directly to the non-lipidated form of both IPP4 and IPP5. This would exclude any misinterpretation of characteristics observed for the lipidated peptides that were due to the lysing-arginine substitution. In addition, a detailed study of the effect of different linker types as well as different fatty acids, could lead to valuable information regarding how the exact nature of the lipidation modifications affect physical stability. This would enable an assessment of the contribution of different parts of the lipidated GLP-1 variants to physical stability and whether the properties of the different regions of the lipidated peptides acted in an additive fashion or if the product of peptide, linker and fatty acid show independent characteristics. 6.2.5 Role of Zeta Potential in the Aggregation of GLP-1 and GLP-1 Analogues The results in Chapter 4 show the influence of the net charge on the aggregate kinetics. A detailed study of the zeta potential, especially at the pH values summarised in Section 6.1.9 could help to understand the influence of the net charge on off-pathway oligomers or aggregates. It might also help to understand why under certain conditions samples with lower net charge are more likely to form off-pathway species and show longer aggregation lag times. Learning more about the zeta potential is also valuable for the understanding of the binding affinity of fluorescent molecules such as ANS or ThT. It was recently shown that the zeta potential is related to the binding and fluorescence of thioflavin T.\textsuperscript{291} In this study, it was shown that the zeta potential rather than pH-dependent assembly of the fibrils is the primary factor affecting ThT binding and fluorescence. Interestingly, the ThT fluorescence measurements of GLP-1 and GLP-1 analogues under acidic and basic condition show similar maximum fluorescence intensities. 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Biochemistry 58, 3413–3421. 8 APPENDICES ANALYTICAL DATA SHEETS ................................................................. 279 ## Analytical Data Sheet Lot number 1061673 not for drug use \| Catalog number \| H-9560 \| \|----------------\|--------\| \| Product number \| 4043014 \| Product GLP-1 (7-37) (human, bovine, guinea pig, mouse, rat) acetate salt H- His- Ala- Glu- Gly- Thr- Phe- Thr- Ser- Asp- Val- Ser-Ser- Tyr- Leu- Glu- Gly- Gln- Ala- Ala- Lys- Glu- Phe-Ile- Ala- Trp- Leu- Val- Lys- Gly- Arg- Gly- OH acetate salt Molecular formula $C_{151}H_{238}N_{42}O_{47}$ Relative molecular mass 3355.71 \| Tests \| Results \| \|------------------------\|-------------------------------------------------------------------------\| \| Appearance \| white lyophilisate \| \| Appearance of solution \| clear, colorless solution (1 mg/mL in 50% acetic acid) \| \| Identification (ESI-MS)\| $m = 3355.7$ u (average mass) \| \| Purity (HPLC) \| 99.2% (TFA) \| \| \| 96.6% (TEAP) \| \| Assay (elemental analysis) \| 91.4% (Nth 16.70%, Nld 15.27%) \| Latest update: October 19, 2015 ## Am-GLP-1 ### Analytical Data Sheet Lot number 3014701 not for drug use \| Product number \| 4094597 \| \|--------------------\|---------\| \| Product \| H-His-Ala-Glu-Gly-Thr-Phe-Thr-Ser-Asp-Val-Ser-Ser-Tyr-Leu-Glu-Gly-Gln-Ala-Ala-Lys-Glu-Phenyl-Ala-Trp-Leu-Val-Lys-Gly-Arg-Gly-NH$_2$ acetate salt \| \| Molecular formula \| C$_{16}$H$_{23}$N$_{11}$O$_{6}$ \| \| Relative molecular mass \| 3354.73 \| \| Tests \| Results \| \|-----------\|-------------\| \| Appearance \| white powder \| \| Identification (MALDI-MS) \| 3354.83 \| \| Amino acid analysis \| Asp 1.04(1) Ala 3.89(4) Phe 1.87(2) Thr 1.89(2) Val 1.81(2) His 1.03(1) Ser 2.84(3) Ile 0.97(1) Lys 2.04(2) Glx 4.16(4) Leu 1.81(2) Trp 0.68(1) Gly 4.07(4) Tyr 0.99(1) Arg 1.02(1) \| \| Solubility \| soluble in water at 1mg/mL \| \| Purity (HPLC) \| 96.7% \| \| Assay (AAA) \| 97.3% \| \| Date of manufacture \| February 19, 2016 \| Latest update: February 25, 2016 This Analytical Data Sheet is automatically generated based on reviewed analytical data and is therefore unsigned. ## Analytical Data Sheet Lot number 3014726 not for drug use \| Product number \| 4094484 \| \|--------------------\|---------\| \| Product \| H- His- Ala- Glu- Gly- Thr- Phe- Thr- Ser- Asp- Val- Ser- Ser- Tyr- Leu- Glu- Gly- Lys(ε- Glu-palmitoyl)- Ala- Ala- Arg- Glu- Phe- Ile- Ala- Trp- Leu- Val- Arg- Gly- Arg- Gly- NH$_2$ acetate salt \| \| Molecular formula \| C$_{173}$H$_{375}$N$_{48}$O$_{48}$ \| \| Relative molecular mass \| 3778.33 \| \| Tests \| Results \| \|-----------\|-------------\| \| Appearance \| white powder \| \| Identification (MALDI-MS) \| 3778.35 \| \| Solubility \| insoluble in water at 1mg/mL insoluble in DMF at 1mg/mL soluble in 50% Acetic acid at 1mg/mL \| \| Purity (HPLC) \| 96.3% \| \| Date of manufacture \| March 04, 2016 \| Latest update: March 04, 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JSW Energy Limited Q4 and FY 2018 Results Presentation May 3, 2018 Key highlights for Q4FY18 [x] Long term PPA (LTPPA) proportion at 75.0% in Q4FY18, up from 69.3% in Q3FY18, after securing 200MW LTPPA with Punjab discom and 50MW group captive contract [x] Net debt reduced by ~ ` 3,106 crore in FY18 after adjusting for JPVL liability; cost of debt dipped by 114bps from Q4FY17 level [x] EV business – (i) Appointed auto industry expert, Mr. Sergei Rocha as COO of EV – Passenger Vehicles and (ii) Capex increased to ~ ` 6,500 crore led by enhanced scope and product strategy [x] RE business – FY19 plans entail total capex of ~ ` 1,200 crore involving (i) installation of 200MW of solar power systems and (ii) setting up facility for 1,000 MW solar PV module manufacturing capacity; exploring opportunities in PV cell/ wafer manufacturing [x] Proactive working capital management: Consolidated debtors and debtor days reduce by ~ ` 1,032 crore and 35 days respectively over Q4FY17 levels [x] Adjusted carrying value of investments/advances related to Toshiba JSW, South African operations and JPVL by making gross provisions aggregating ~ ` 815 cr. Along with RWPL related provisions made throughout FY18, all major financial risks are adequately provided. 2 Business Environment Operational and Financial Performance 3 Demand growth rate further picks up to 7.1% in Q4FY18 Region North-East Trend in Growth Rates 4 Thermal PLF increases to 63.6% in Q4FY18 Gross Generation Thermal Hydro RE Others Total PLF (%) Thermal 5 Merchant tariff higher in CY18 on YoY basis Merchant tariff staged a recovery in CY17 and continue to rise in CY18 on YoY basis Source: IEX, PXIL 6 RE Capacity addition falls short of target Sector-wise Installed Capacity : 344.0 GW (as on Mar 31, 2018) Mode-wise Installed Capacity (as on Mar 31, 2018) QoQ increase in total capacity of 10.45 GW in Q4FY18 led by RE (6.2 GW) and thermal (3.9 GW) segments FY18 saw net capacity addition of ~17.2 GW led by private sector (12.9 GW); 2.5GW capacity was retired RE capacity addition of ~11.8 GW in FY18 falls short of target of 20.2 GW # Refers to total installed capacity of respective segments * YoY change during the financial year 7 Indian economy and thermal coal prices [x] Maintaining healthy growth, Industrial Production grew at 7.1%YoY in February 2018 Thermal coal prices remain at elevated levels, while INR depreciated marginally in Q4 FY18 [x] Growth recovery signs are also seen with GVA growth picking up from 5.6%YoY in Q1FY18 to 6.7%YoY in Q3FY18 [x] Going forward, growth is expected to pick up led by govt infrastructure focus and receding head-winds of GST & demonetisation with risks of rising crude and interest rates Industrial production growth (% YoY) Source: API4 Coal Index, Bloomberg Indexed to Dec-2017 levels 8 Business Environment Operational and Financial Performance 9 Q4 plant-wise net generation Annual plant-wise net generation Long term PPAs [x] Secured 200 MW LT PPA with Punjab discom for Karcham Wangtoo HEP in Q4 FY18 enabling the offtake of this plant to be 100% tied-up in terms of LTPPA [x] Added 50MW contract to group captive portfolio at Ratnagiri plant Consolidated financial results ` Crore Proactive & Prudent Provisioning in Q4FY18 [x] Provisioning of ` 241 crore related to investments in Toshiba JSW JV and South African operations [x] Commissioned valuation of both the businesses [x] Adopting a conservative approach, total provisioning hit of ` 241 crore taken in Q4FY18 [x] No impact on consolidated financials as accumulated losses equal to the impairment amounts have already been provided for in earlier periods [x] Gross Provisioning of ` 574 crore in outstanding advance to Jaiprakash Power Ventures Ltd (JPVL) [x] Post recovery of ~ ` 248 crore, outstanding JPVL advance had reduced to ~ ` 752 crore [x] Net impact in consolidated P&L of ` 418 crore in Q4FY18 against outstanding JPVL advance [x] Provisioning taken considering JPVL's continued financial challenges [x] JSWEL evaluating all options, including legal recourse under IBC, to recover its dues from JPVL Above one-time provisions, along with those related to RWPL of ~ ` 248 crore in FY18, imply that all major financial risks are adequately provided Consolidated financial highlights Debt gearing declines to ~ 1x Reduction in cost of debt to 9.03% by end of Q4FY18 Sustained reduction in net debt Entity wise summary financial performance ` Crore Key updates during Q4FY18 [x] EV & associated business: Business development phase gathering pace [x] Appointed Mr. Sergio Rocha, an auto industry expert, as COO – EV, Passenger Vehicles. Dedicated team continues to be built. [x] Scope widened to include select electric CV models including electric bus & light pick-up trucks [x] Discussions progressing for partnerships wrt EV platform and storage battery technology [x] Capex increased to ~ ` 6,500 crore over period of next 3-4 years considering enhanced scope and product strategy, of which ~ ` 1,000 crore expected to be incurred in FY19 [x] RE/Solar business: Enhancing our presence [x] 17MW solar power capacity under implementation on track for Sep 2018 completion [x] FY19 plans entail total capex of ~ ` 1,200 crore involving (i) installation of 200MW of solar power systems and (ii) setting up facility for 1,000 MW solar PV module manufacturing capacity; exploring opportunities in PV cell/ wafer manufacturing [x] Commissioned 2 captive solar power systems already. New contract won from Delhi Golf Club. [x] JSW PTC demerger process stands completed Forward looking and cautionary statement This presentation has been prepared by JSW Energy Limited (the "Company") based upon information available in the public domain solely for information purposes without regard to any specific objectives, financial situations or informational needs of any particular person. This presentation should not be construed as legal, tax, investment or other advice. This presentation is confidential, being given solely for your information and for your use, and may not be copied, distributed or disseminated, directly or indirectly, in any manner. Furthermore, no person is authorized to give any information or make any representation which is not contained in, or is inconsistent with, this presentation. Any such extraneous or inconsistent information or representation, if given or made, should not be relied upon as having been authorized by or on behalf of the Company. The distribution of this presentation in certain jurisdictions may be restricted by law. Accordingly, any persons in possession of this presentation should inform themselves about and observe any such restrictions. Furthermore, by reviewing this presentation, you agree to be bound by the trailing restrictions regarding the information disclosed in these materials. This presentation contains statements that constitute forward-looking statements. These statements include descriptions regarding the intent, belief or current expectations of the Company or its directors and officers with respect to the results of operations and financial condition of the Company. These statements can be recognized by the use of words such as "expects," "plans," "will," "estimates," "projects," or other words of similar meaning. Such forward-looking statements are not guarantees of future performance and involve risks and uncertainties, and actual results may differ from those specified in such forward-looking statements as a result of various factors and assumptions. The risks and uncertainties relating to these statements include, but are not limited to, (i) fluctuations in earnings, (ii) the Company's ability to manage growth, (iii) competition, (iv) (v) government policies and regulations, and (vi) political, economic, legal and social conditions in India. The Company does not undertake any obligation to revise or update any forward-looking statement that may be made from time to time by or on behalf of the Company. Given these risks, uncertainties and other factors, viewers of this presentation are cautioned not to place undue reliance on these forward-looking statements. The information contained in this presentation is only current as of its date and has not been independently verified. 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Thank you	<urn:uuid:00e43aa7-8443-4079-9339-822cf19179a5>	CC-MAIN-2024-10	https://www.jsw.in/sites/default/files/assets/industry/energy/IR/Financial%20Performance/Financials/FY_17_18/Q4/Results%20Presentation.pdf	2024-02-28T17:03:05+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-10/subset=warc/part-00254-d9675c6d-5c8d-45bb-9c98-c56e42022a4d.c000.gz.parquet	843,166,465	2,420	eng_Latn	eng_Latn	0.845504	eng_Latn	0.987966	[ "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "unknown", "eng_Latn", "eng_Latn", "unknown", "unknown", "eng_Latn", "eng_Latn", "unknown" ]	false	rolmOCR	[ 68, 1265, 1329, 1430, 1547, 1699, 2245, 2858, 2922, 2986, 3225, 3266, 4307, 4425, 4458, 4510, 5631, 11162, 11173 ]
HPSS RAIT Network Overhead Analysis July 1, 2009 Benny Wilbanks, Kent Dehart & Jason Alt In this discussion we assume that the HPSS Client/Mover stripe width is represented by c. The data stripe width for tape is represented by d and the number of redundancy tapes is represented by p. The total tape stripe width is d+p. In the examples we take d = 4 and p = 2. Approach #1 – Rotating Redundancy Generation This is one of the original proposals, where d helpers (each running on a tape Mover) collects (over the network) 1/d of the data and sends it to the local tape Mover, by utilizing share memory. It also transmits, over the network, this data to p helpers. These helpers will generate redundancy information and send it to the local tape Mover via shared memory. This configuration is depicted in the figure below. Notice that the network overhead required for this approach is the transfer of 1/d of the data by each d helper for each p redundancy blocks. Totaling the overhead gives us: (d * p * 1 /d) + (d * (1/d)) or simply p +1. For each redundancy tape all the data much be transferred to the node targeted to generate redundancy information. Approach #2– Rotation Redundancy Pipeline This is also one of the original proposals, where d helpers (each running on a tape Mover) collects (over the network) 1/d of the data and sends it to the local tape Mover, by utilizing share memory. It also transmits, over the network, a partial redundancy block. These helpers continue receiving data, computing partial redundancy information and passing it on until the block is complete and it is passed to another helper. These p helpers will send the redundancy block to the local tape Mover via shared memory. This configuration is depicted in the figure below. The network overhead required for this approach is the transfer of 1/d of the data by each d-1 helper for each p redundancy blocks. Totaling the overhead gives us: (p * 1 /d * (d + p – 1)) + (d * 1/d),or simply (p/d * (d+p-1))+1. This approach is more expensive than that the first. It was included for completeness. Approach #3– Per Stripe Redundancy This is based on the proposal from NCSA, where redundancy information is calculated closer to the source, using the available data. Each Helper (which should be started on the Client/Mover machine) gets data for an entire stripe length extent, generates the redundancy data and transmits all to tape Movers. One or more of these Helpers can be run in parallel. In our example, we use h to represent the number of Helpers running. This configuration is depicted in the figure below. The network overhead required for this approach is party depended on how wide the data is distributed at the Client/Mover. Because each Helper is started on the Client/Mover machine only c-1/c network overhead is required. The remaining 1/c is handled via shared memory. Additionally, since the transfer is split between the h helpers, each helper will handle 1/h of the data. This includes writing p of the 1/h redundancy information to the Movers. Totaling the overhead gives us: h (p/hd) + (c-1)/c + hd(1/hd), or p/d + (c1)/c + 1. Conclusion If we concentrate on approach #1 and #3 (#2 is not even in the running), approach #3 appears to be the most efficient (see the solution of the following inequality): So Approach #3 is better than #1 when p > 1. If p is equal to 1, then they both produced the same network overhead. The included table demonstrates this. There must be care taken with the approach because it is possible in a single Client/Mover situation to run more helpers per Client/Mover node than can be handled by the network interface. If you consider 250MB/sec tape drives, d=8 and p=2, you'd need to push 3125MB/sec across your network and 2500MB/sec to the drives to keep them streaming. Also, to reach an adequate level of parallelism the Client/Mover will be required to buffer multiple HPSS stripe length of data. For example, to fully drive an 8 way tape stripe, you might have a 16 way disk virtual volume. If your stripe block size is 4MB, then each disk Mover would need to buffer 32MB of data. This is something that we need to continue to investigate for feasibility. It may be difficult to run the RAIT helper on the same machine as the Client/Mover. The next best case may to run it on one of the Tape Mover machines. The network overhead in this case would be: 1 + p/d + (d-1)/d	<urn:uuid:d5195251-e77a-4d19-84b3-7876807b82b9>	CC-MAIN-2017-13	http://hpss-collaboration.org/documents/RAIT_NO_Analysis.pdf	2017-03-25T09:42:44Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-13/segments/1490218188914.50/warc/CC-MAIN-20170322212948-00535-ip-10-233-31-227.ec2.internal.warc.gz	167,055,247	1,043	eng_Latn	eng_Latn	0.996915	eng_Latn	0.997472	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1161, 2092, 3147, 4431 ]
Kathryn Volk Associate StaﬀScientist Department of Planetary Sciences/ Lunar and Planetary Laboratory The University of Arizona 1629 E University Blvd, Tucson, AZ 85721 [email protected] Education Ph.D. Planetary Sciences, The University of Arizona, 2013 B.S. Physics, Russian Area Studies, Wittenberg University, 2006 Summa Cum Laude. Positions Grants and Fellowships PI, "Constraining Neptunes migration using the surface properties of resonant trans-Neptunian objects", NASA Emerging Worlds (2021-2024) PI, "Dynamics of sticky resonances and detached Kuiper belt objects", NASA Solar System Workings (2019-2022) Co-I, "Distribution of planet masses, planet-planet separations and dynamical lifetimes of planetary systems", NASA Exoplanet Research Program (2018-2021, PI: R. Malhotra) Co-I, "Kuiper Belt Dynamics with a Distant Unseen Planet", NSF (2018-2021, PI: R. Malhotra) Co-I/Science PI, "Current dynamics of Neptune's distant mean motion resonances", NASA Solar System Workings (2015-2019, PI: R. Murray-Clay) Canadian Institute for Theoretical Astrophysics National Fellow (2013-2015) Professional Leadership Chair of the American Astronomical Society (AAS) Division on Dynamical Astronomy (DDA) (2020-2021) DDA Meeting Scientiﬁc/Virtual Organizing Committee Chair (2020) Member of the AAS Strategic Assembly (2020) Vice-Chair of the DDA (2019-2020) DDA committee member (2017-2019) AAS Division for Planetary Sciences Meeting Scientiﬁc Organizing Committee member (2017) Spacecraft Mission Proposal Involvement Co-I, "Chimera: Orbital Exploration of 29P/Schwassmann-Wachmann as a Gateway to the Centaurs and the Secrets of Small Body Formation" (proposed in resposnse to the 2019 NASA Discovery Mission Announcement of Opportunity, PI Walt Harris, University of Arizona – not selected) Publications Abedin et al. (2020), "Collision Probabilities in the Edgeworth-Kuiper belt", in prep Kareta et al. (2020), "Contemporaneous Multi-Wavelength and Precovery Observations of Active Centaur P/2019 LD2 (ATLAS)", submitted to PSJ Fink, Harris, Doose, Volk, Woodney, Farnham, & Womack (2020), "Dust outburst dynamics and hazard assessment for close spacecraft-comet encounters", submitted to PSJ Lin, Chen, Volk, et al. (2020), "OSSOS: The Bimodal Eccentricity and Inclination Distributions of the Stable Neptunian Trojans", submitted to Icarus. Steckloﬀ, Sarid, Volk, et al. (2020), "P/2019 LD2 (ATLAS): An Active Centaur in Imminent Transition to the Jupiter Family", ApJ Letters, in press. Volk & Malhotra (2020), "Dynamical instabilities in systems of multiple short-period planets are likely driven by secular chaos: a case study of Kepler-102", AJ. Harris, Fernandez, Sarid, Steckloﬀ, Volk, Womack, & Woodney (2020), "Active Primordial Bodies: Exploration of the primordial composition of ice-rich planetesimals and early-stage evolution in the outer solar system", White Paper submitted for the Planetary Science and Astrobiology Decadal Survey 2023-2032 Woodney, Rivkin, Harris, et al. (2020), "Strength In Diversity: Small Bodies as the Most Important Objects in Planetary Sciences", White Paper submitted for the Planetary Science and Astrobiology Decadal Survey 2023-2032 Smullen & Volk (2020), "Machine Learning Classiﬁcation of Kuiper Belt Populations", MNRAS. Kareta, Volk, et al. (2020). "An Extremely Temporary Co-orbital: The Dynamical State of Active Centaur 2019 LD2", RNAAS. Nesvorny et al. (2020). "OSSOS XX: The Meaning of Kuiper Belt Colors", AJ. Ashton et al. (2020), "OSSOS: XI. An upper limit on the number of distant planetary objects in the Solar System", Icarus. Marsset et al. (2020), "COL-OSSOS: Compositional homogeneity of three binaries found in the Outer Solar System Origins Survey", PSJ. Kareta et al. (2020), "Carbon Chain Depletion of 2I/Borisov", ApJ Letters. Pike et al. (2020), "OSSOS XVI: The missing small members of the Haumea family", Nature Astronomy. Kareta et al. (2019), "Physical Characterization of the December 2017 Outburst of the Centaur 174P/Echeclus", AJ. Chen, Gladman, Volk, et al. (2019), "OSSOS: constraining migration models with the 2:1 resonance using the outer solar system origin survey", AJ. Sarid, Volk, Steckloﬀ, Harris, Womack, & Woodney (2019), "29P/Schwassmann-Wachmann 1, A Centaur in the Gateway to the Jupiter-Family Comets", ApJ Letters. Alexandersen et al. (2019), "OSSOS: XII. Variability studies of trans-Neptunian objects using the Hyper-Suprime Camera", ApJS. Nesvorny et al. (2019), "OSSOS XIX: Testing Early Solar System Dynamical Models using OSSOS Centaur Detections", AJ. Volk & Malhotra (2019), "Not a simple relationship between Neptune's migration speed and Kuiper belt inclination excitation", AJ. Van Laerhoven, Gladman, Volk, et al. (2019), "OSSOS XIV : The Plane of the Kuiper Belt", AJ. Schwamb et al. (2019), "Col-OSSOS: the colours of the Outer Solar System Origin Survey", ApJS. Lawler et al. (2019), "OSSOS: XIII. Fossilized resonant dropouts tentatively conﬁrm Neptune's migration was grainy and slow", AJ. Marsset et al. (2019), "Col-OSSOS: a distinct inclination distribution for each color seen in the dynamically excited trans-neptunian populations", AJ. Cabral et al. (2019), "OSSOS: XV. No active Centaurs in the Outer Solar System Origins Survey", A&A. Schwamb et al. on behalf of the LSST Solar System Science Collaboration (2019), "A Software Roadmap for Solar System Science with the Large Synoptic Survey Telescope", RNAAS. Schwamb, Volk, Lin, et al. (2018), "A Northern Ecliptic Survey for Solar System Science", LSST Cadence Optimization White Paper (arXiv:1812.01149). Volk et al. (2018), "The Eﬀects of Filter Choice on Outer Solar System Science with LSST", LSST Cadence Optimization White Paper (arXiv:1812.01149). Malhotra, Lan, Volk, & Wang (2018), "Neptune's 5:2 Resonance in the Kuiper Belt", AJ. Yu, Murray-Clay, & Volk (2018), "Trans-Neptunian Objects Transiently Stuck in Neptune's Mean Motion Resonances: Numerical simulations of the current population", AJ. Volk et al. (2018), "OSSOS IX : two objects in Neptune's 9:1 resonance – implications for resonance sticking in the scattering population", AJ. Lawler et al. (2018), "OSSOS VIII – two size distribution slopes in the scattering disk", AJ. Bannister, Gladman, Kavelaars, Petit, Volk, Chen, Alexandersen, Gwyn, & the OSSOS collaboration (2018), "OSSOS: 800+ tans-Neptunian objects – the complete data release", ApJS. Volk & Malhotra (2017), "The curiously warped mean plane of the Kuiper belt", AJ. Pike et al. (2017), "Col-OSSOS: z band photometry reveals three distinct TNO surface types", AJ. Shankman et al. (2017), "OSSOS VI. Striking biases in the detection of large semimajor axis trans-Neptunian objects", AJ. Bannister, Shankman, Volk, et al. (2017), "OSSOS: V. Diﬀusion in the orbit of a high-perihelion distant Solar System object". AJ. Fraser et al. (2017), "All planetesimals born near the Kuiper belt formed as binaries", Nature Astronomy. Bannister et al. (2016), "OSSOS: IV. Discovery of a dwarf planet candidate in the 9:2 resonance with Neptune", AJ. Volk et al. (2016), "OSSOS III - Resonant Trans-Neptunian Populations: Constraints from the ﬁrst quarter of the Outer Solar System Origins Survey", AJ. Malhotra, Volk, & Wang (2016), "Corralling a distant planet with extreme resonant Kuiper belt objects", ApJ Letters. Bannister et al. (2016), "The Outer Solar System Origins Survey I: design and ﬁrst-quarter discoveries", AJ. Shankman et al. (2015), "OSSOS II: A sharp transition in the absolute magnitude distribution of the Kuiper belt's scattering population", AJ. Volk & Gladman (2015), "Consolidating and Crushing Exoplanets: Did it Happen Here?", ApJ Letters. Pike, Kavelaars, Petit, Volk, & Shankman (2015), "The 5:1 Neptune Resonance as Probed by CFEPS: Dynamics and Population", AJ. Volk & Malhotra (2013), "Do Centaurs preserve their source inclinations?", Icarus. Volk & Malhotra (2012), "Long-term dynamical stability of the Haumea (2003 EL61) collisional family", Icarus. Volk & Malhotra (2011), "Inclination mixing in the classical Kuiper belt", ApJ. Volk & Malhotra (2008), "The scattered disk as the source of the Jupiter family comets", ApJ. Cui, Yelle, & Volk (2008), "Distribution and escape of molecular hydrogen in Titan's thermosphere and exosphere", JGR. Recent Seminars and Invited Talks "Active Centaurs in context: understanding future members of the Jupiter family comets", Invited Plenary Talk, DPS Virtual Meeting, October 2020. "Combining theory and observations of trans-Neptunian objects to pin down Neptune's migration history", Theoretical Astrophysics Program Colloquium, October 2019, Tucson, AZ. "Solar System Shake-up: how planet migration rearranged our system", invited talk, Breakthrough Discuss Conference, April 2019, Berkeley, CA. "Combining theory and observations of trans-Neptunian objects to pin down Neptune's migration history", Academica Sinica Institute of Astronomy and Astrophysics Colloquium, March 2019, Taipei, Taiwan. "Our evolving picture of the Kuiper belt: unexpectedly warped mean planes and new observations of resonant populations", Southwest Research Institute Colloquium, December 2017, Boulder, CO. "The curiously warped mean plane of the Kuiper belt", Lunar and Planetary Institute Seminar, September 2017, Houston, TX. Selected Recent Conference Proceedings 2020: K. Volk & R. Malhotra. "Characterizing and predicting dynamical instabilities in multiplanet systems". DPS, Virtual meeting. 2020: K. Volk & R. Malhotra. "Dynamical instabilities in systems of multiple short-period planets are likely driven by secular chaos: a case study of Kepler-102". DDA, Virtual meeting. 2020: K. Volk & R. Malhotra. "Kepler-102: a case study for using dynamical constraints to characterize exoplanet systems". AAS, Honolulu, HI. 2019: K. Volk & R. Malhotra. "Not a simple relationship between Neptune's migration speed and Kuiper belt inclination excitation". DDA, Boulder, CO. 2018: K. Volk & R. Malhotra. "A statistical exploration of dynamical stability in Kepler and K2 multi-planet systems". DPS, Knoxville, TN. 2018: K. Volk et al. "Two objects in Neptune's 9:1 resonance – implications for resonance sticking in the scattering population". DDA, San Jose, CA. Telescope Time Awarded PI, Large Binocular Telescope (MODS), 0.5 nights in 2019B, 'Searching for Cold Classical Interlopers in the 3:2 Neptune Resonance" Co-I, Large Binocular Telescope (MODS, LBC), 7 nights in 2018A-2019B, "Constraining Neptune's Migration: Surfaces of Resonant TNOs" (PI: R. Murray-Clay) PI, Large Binocular Telescope (LBC), 1.5 nights in 2018A, "Constraining Neptune's Migration: Surfaces of Resonant TNOs" Teaching Instructor, University of Arizona, Fall 2015 – PTYS/ASTR 170B2 The Universe and Humanity: Origins and Destiny (general education introductory astronomy course; ∼ 120 students) Graduate Teaching Assistant Instructor/Co-Instructor, University of Arizona, Fall 2009, Spring 2010, Fall 2012 – LASC 297a: Letters, Arts, and Science Specialty Training Workshop (9-week course to improve scientiﬁc literacy and help students become peer mentors in their science classes; ∼ 20 students per class) Graduate Teaching Assistant, University of Arizona, Fall 2006, Spring 2008, Spring 2009 – various general education astronomy/planetary science undergraduate courses Professional Service Referee for Icarus, Science, A&A, MNRAS, Nature Astronomy, AAS journals, CelMech&DA External grant reviewer for NASA Research Programs Panelist for NASA Research Program grant reviews Panelist for NSF Astronomy grant review Reviewer for telescope proposal calls (Gemini, K2) 2019-2020 StaﬀRepresentative, Dept. of Planetary Sciences, University of Arizona 2018-2019 LPL representative on the Steward Observatory Telescope Allocation Committee Recent Outreach Activities 2019, 2017, 2015 speaker for Astronomy on Tap, Tucson 2018 speaker for Astronomy on Tap, Seattle 2015-2018 invited speaker at several local amateur astronomy associations 2018 Phoenix Comic Fest panelist 2015-2017 volunteer for various Lunar & Planetary Lab outreach events 2016-2017 guest lecturer for the University of Arizona's Osher Lifelong Learning Institute 2017, 2016 Judged the Southern Arizona Research, Science & Engineering Foundation Science Fair Selected Honors & Awards 2013 College of Science Outstanding Scholarship Award, University of Arizona 2013 Gerard P. Kuiper Memorial Award, University of Arizona 2011, 2009 Galileo Circle Scholar, University of Arizona 2010 Department of Planetary Sciences Service Award, University of Arizona 2007 College of Science Graduate Teaching Assistant Award, University of Arizona 2006 Department of Planetary Sciences Graduate Teaching Award, University of Arizona 2006 Departmental Honors in Physics, Wittenberg University 2006 Award for Excellence in the Russian Studies Program, Wittenberg University	<urn:uuid:664e5107-fa19-4e9f-8a0f-6a956f34a07a>	CC-MAIN-2020-50	http://katvolk.com/wp/wp-content/uploads/2020/11/Volk_CV_Nov_2020.pdf	2020-11-27T08:39:15+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-50/subset=warc/part-00038-8431e8c9-c763-4c27-b286-ba1dd7e2631e.c000.gz.parquet	58,176,187	3,475	eng_Latn	eng_Latn	0.679141	eng_Latn	0.739591	[ "dag_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1505, 3944, 6544, 8718, 10936, 12992 ]
## CPT ANTISLAVERY CAMPAIGN in BRAZIL ### NATIONAL DATA, updated 31 Dec 2008 \| DATA \| 2003 \| 2004 \| 2005 \| 2006 \| 2007 \| 2008 \| \|-----------------------------\|--------\|--------\|--------\|--------\|--------\|--------\| \| Nb of claims \| \| \| \| \| \| \| \| Slavery \| 237 \| 230 \| 278 \| 265 \| 265 \| 280 \| \| Superexploitation \| 38 \| 63 \| 104 \| 95 \| 112 \| 68 \| \| Total \| 275 \| 293 \| 382 \| 360 \| 377 \| 348 \| \| Workers involved \| \| \| \| \| \| \| \| Enslavement \| 8,315 \| 5,812 \| 7,628 \| 6,899 \| 8,674 \| 7,022 \| \| Superexploitation \| 1,166 \| 1,448 \| 2,007 \| 6,601 \| 1,599 \| 1,533 \| \| Total \| 9,481 \| 7,260 \| 9,635 \| 13,500 \| 10,273 \| 8,555 \| \| Claims investigated \| \| \| \| \| \| \| \| Nb of claims inspected \| 146 \| 126 \| 164 \| 136 \| 152 \| 214 \| \| % Claims inspected./ tot. slavery claims \| 62% \| 55% \| 59% \| 51% \| 57% \| 76% \| \| Nb of workers freed \| 4,999 \| 3,212 \| 4,586 \| 3,666 \| 5,973 \| 5,244 \| Freed between 2003 & 2008 = 27,893 (82.6% of total freed since 1995 – [1] The official number published by Ministry of Labor is 5,016. CPT figures include more 228 workers rescued from Usina Central/PR: a judiciary sentence against labor inspection blocked their effective liberation. ### SLAVERY RANKING \| 'the champion' states \| 2003 \| 2004 \| 2005 \| 2006 \| 2007 \| 2008 \| \|-----------------------------\|--------\|--------\|--------\|--------\|--------\|--------\| \| Number of claims \| 237 \| 230 \| 278 \| 265 \| 265 \| 280 \| \| Number of workers involved \| 8,315 \| 5,812 \| 7,628 \| 6,899 \| 8,674 \| 6,674 \| \| 'the champions' \| \| \| \| \| \| \| \| Number of workers freed \| 4,999 \| 3,212 \| 4,586 \| 3,666 \| 5,973 \| 5,244 \| \| Farmers on the dirty list \| 53 \| 163 \| 133 \| 172 \| 184 \| 203 \| \| 'the champions' \| \| \| \| \| \| \| ### CLAIMS & INSPECTIONS \| CLAIMS & INSPECTIONS \| 2003 \| 2004 \| 2005 \| 2006 \| 2007 \| 2008 \| TOTAL \| \|-----------------------------\|--------\|--------\|--------\|--------\|--------\|--------\|-------\| \| ClaimsTOT \| 237 \| 220 \| 278 \| 265 \| 265 \| 280 \| 1,545 \| \| Claims investigated TOT \| 150 \| 126 \| 161 \| 136 \| 152 \| 214 \| 939 \| \| Claims through CPT Campaign \| 167 \| 145 \| 159 \| 151 \| 132 \| 95 \| 849 \| \| % claims CPT / Claims TOT \| 70% \| 66% \| 57% \| 57% \| 50% \| 34% \| 55% \| \| Claims CPT investigated \| 95 \| 48 \| 48 \| 47 \| 33 \| 33 \| 304 \| \| Workers involved TOT \| 8,306 \| 5,812 \| 7,612 \| 6,941 \| 8,674 \| 7,022 \| 44,367\| \| Workers freed TOT \| 5,228 \| 3,212 \| 4,570 \| 3,666 \| 5,973 \| 5,244 \| 27,893\| \| Workers involved / Claims CPT\| 4,867 \| 3,822 \| 4,823 \| 3,204 \| 2,401 \| 1,812 \| 20,929\| \| Workers freed / Claims CPT \| 2,091 \| 1,487 \| 1,947 \| 998 \| 543 \| 245 \| 7,311 \| \| % of investigation / claims TOT \| 63% \| 57% \| 58% \| 51% \| 57% \| 76% \| 61% \| \| % of investigation / claims CPT \| 57% \| 33% \| 30% \| 31% \| 25% \| 35% \| 36% \| \| % of investigation / Workers involved TOT \| 63% \| 55% \| 60% \| 53% \| 69% \| 75% \| 63% \| \| % of investigation / Workers involved CPT \| 43% \| 39% \| 40% \| 31% \| 23% \| 14% \| 35% \| \| Claims CPT without investigation \| 72 \| 97 \| 111 \| 104 \| 99 \| 62 \| 545 \| \| Workers invol. In Claims CPT without investigation \| 2,776 \| 2,335 \| 2,876 \| 2,206 \| 1,858 \| 1,567 \| 13,618\| ### RURAL SLAVERY – Claims & Inspections – last 2 years \| STATES \| Claims registered \| Claims registered \| Workers involved \| Workers involved \| Claims investigated \| Claims investigated \| Workers freed \| Workers freed \| \|-------------------------\|-------------------\|-------------------\|------------------\|------------------\|---------------------\|---------------------\|--------------\|--------------\| \| PArá \| 133 \| 109 \| 3,317 \| 1,581 \| 59 \| 67 \| 1,933 \| 811 \| \| MATo grosso \| 17 \| 32 \| 310 \| 605 \| 8 \| 30 \| 117 \| 578 \| \| MAranhão \| 33 \| 27 \| 714 \| 885 \| 15 \| 8 \| 378 \| 99 \| \| TOcantins \| 21 \| 16 \| 570 \| 238 \| 14 \| 13 \| 91 \| 78 \| \| Mato grosso do Sul \| 13 \| 14 \| 1,634 \| 245 \| 13 \| 14 \| 1,634 \| 236 \| \| PaRaná \| 4 \| 14 \| 129 \| 398 \| 4 \| 14 \| 129 \| 398 \| \| Minas Gerais \| 6 \| 13 \| 532 \| 229 \| 5 \| 13 \| 425 \| 229 \| \| PIauí \| 4 \| 8 \| 241 \| 154 \| 3 \| 8 \| 171 \| 129 \| \| AMazonas \| 1 \| 7 \| 10 \| 85 \| 1 \| 7 \| 10 \| 85 \| \| Santa Catarina \| 3 \| 7 \| 52 \| 125 \| 3 \| 7 \| 52 \| 125 \| \| BAHia \| 5 \| 6 \| 175 \| 106 \| 5 \| 6 \| 175 \| 106 \| \| GOiás \| 11 \| 6 \| 704 \| 867 \| 11 \| 6 \| 658 \| 867 \| \| São Paulo \| 3 \| 6 \| 102 \| 172 \| 2 \| 6 \| 61 \| 172 \| \| ALagoas \| - \| 3 \| - \| 656 \| - \| 3 \| - \| 656 \| \| ParaíBa \| 1 \| 3 \| 22 \| 309 \| - \| 3 \| 309 \| - \| \| CEará \| 2 \| 2 \| 19 \| 193 \| 2 \| 2 \| 19 \| 192 \| \| Espírito Santo \| 1 \| 2 \| 22 \| 89 \| 1 \| 2 \| 22 \| 89 \| \| ROndônia \| - \| 2 \| - \| 28 \| - \| 2 \| - \| 28 \| \| Rio de Janeiro \| 4 \| 1 \| 49 \| 46 \| 4 \| 1 \| 49 \| 46 \| \| Rio grande do Norte \| - \| 1 \| - \| 7 \| - \| 1 \| - \| 7 \| \| Rio grande do Sul \| 1 \| 1 \| 47 \| 4 \| 1 \| 1 \| 47 \| 4 \| \| ACre \| 1 \| 0 \| 2 \| 0 \| 1 \| 0 \| 2 \| 0 \| \| Total \| 265 \| 280 \| 8,674 \| 7,022 \| 152 \| 214 \| 5,973 \| 5,244 \| ### RURAL SLAVERY – Claims & Inspections – last 2 years \| REGION \| Claims registered \| Claims registered \| Workers involved \| Workers involved \| Claims investigated \| Claims investigated \| Workers freed \| Workers freed \| \|-------------------------\|-------------------\|-------------------\|------------------\|------------------\|---------------------\|---------------------\|--------------\|--------------\| \| CO = Midwest \| 43 \| 52 \| 2,653 \| 1,717 \| 32 \| 50 \| 2,409 \| 1,681 \| \| N = North \| 156 \| 134 \| 3,899 \| 1,932 \| 75 \| 89 \| 2,036 \| 1,002 \| \| NE = Northeast \| 44 \| 50 \| 1,189 \| 2,310 \| 25 \| 31 \| 743 \| 1,498 \| \| S = South \| 8 \| 22 \| 228 \| 527 \| 8 \| 22 \| 228 \| 527 \| \| SE = Southeast \| 14 \| 22 \| 705 \| 536 \| 12 \| 22 \| 557 \| 536 \| \| TOTAL \| 265 \| 280 \| 8,674 \| 7,022 \| 152 \| 214 \| 5,973 \| 5,244 \| \| Sub-total AMAZON Region \| 207 \| 193 \| 4,928 \| 3,422 \| 98 \| 127 \| 2,531 \| 1,679 \| \| \| 2007 \| 2008 \| 2007 \| 2008 \| 2007 \| 2008 \| 2007 \| 2008 \| \|----------------------\|--------\|--------\|--------\|--------\|--------\|--------\|--------\|--------\| \| CO = Midwest \| 16.2% \| 18.6% \| 30.7% \| 24.5% \| 21.1% \| 23.4% \| 40.3% \| 32.1% \| \| N = North \| 58.9% \| 47.9% \| 45.1% \| 27.5% \| 49.3% \| 41.6% \| 34.1% \| 19.1% \| \| NE = Northeast \| 16.6% \| 17.9% \| 13.7% \| 32.9% \| 16.4% \| 14.5% \| 12.4% \| 28.6% \| \| S = South \| 3.0% \| 7.9% \| 2.6% \| 7.5% \| 5.3% \| 10.3% \| 3.8% \| 10.0% \| \| SE = Southeast \| 5.3% \| 7.9% \| 8.1% \| 7.6% \| 7.9% \| 10.3% \| 9.3% \| 10.2% \| \| TOTAL \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| \| Sub-total AMAZON Region \| 78.1% \| 68.9% \| 56.9% \| 48.7% \| 64.5% \| 59.3% \| 42.4% \| 32.0% \| \| WORKERS FREED \| 1995-98 \| 1999 \| 2000 \| 2001 \| 2002 \| 2003 \| 2004 \| 2005 \| 2006 \| 2007 \| 2008 \| TOTAL \| EM % \| \|--------------\|--------\|------\|------\|------\|------\|------\|------\|------\|------\|------\|------\|-------\|------\| \| AC \| \| \| \| \| \| \| \| \| \| \| \| \| 0.1% \| \| RN \| \| \| \| \| \| \| \| \| \| \| \| \| 0.1% \| \| RS \| \| \| \| \| \| \| \| \| \| \| \| \| 0.3% \| \| AM \| \| \| \| \| \| \| \| \| \| \| \| \| 0.3% \| \| SC \| \| \| \| \| \| \| \| \| \| \| \| \| 0.7% \| \| CE \| \| \| \| \| \| \| \| \| \| \| \| \| 0.9% \| \| PE \| \| \| \| \| \| \| \| \| \| \| \| \| 0.9% \| \| ES \| \| \| \| \| \| \| \| \| \| \| \| \| 1.3% \| \| SP \| \| \| \| \| \| \| \| \| \| \| \| \| 1.3% \| \| RO \| \| \| \| \| \| \| \| \| \| \| \| \| 1.4% \| \| PI \| 83 \| \| \| \| \| \| \| \| \| \| \| \| 1.5% \| \| PR \| \| \| \| \| \| \| \| \| \| \| \| \| 2.0% \| \| AL \| 50 \| \| \| \| \| \| \| \| \| \| \| \| 2.2% \| \| RJ \| \| \| \| \| \| \| \| \| \| \| \| \| 2.3% \| \| MG \| 46 \| \| \| \| \| \| \| \| \| \| \| \| 2.9% \| \| MS \| \| \| \| \| \| \| \| \| \| \| \| \| 5.8% \| \| TO \| 32 \| \| \| \| \| \| \| \| \| \| \| \| 5.9% \| \| GO \| \| \| \| \| \| \| \| \| \| \| \| \| 7.1% \| \| BA \| \| \| \| \| \| \| \| \| \| \| \| \| 7.2% \| \| MA \| 8 \| 27 \| 0 \| 457 \| 184 \| 276 \| 347 \| 484 \| 284 \| 378 \| 99 \| 2,544 \| 7.5% \| \| MT \| 455 \| 283 \| 157 \| 245 \| 567 \| 683 \| 326 \| 1,412 \| 444 \| 117 \| 578 \| 5,267 \| 15.6% \| \| PA \| 386 \| 383 \| 280 \| 527 \| 1,392 \| 1,888 \| 928 \| 1,345 \| 1,180 \| 1,933 \| 811 \| 11,053\| 32.8% \| \| TOTAL \| 1,028 \| 725 \| 516 \| 1,305 \| 2,285 \| 5,228 \| 3,212 \| 4,570 \| 3,666 \| 5,973 \| 5,244 \| 33,752\| 100.0%\| \| WORKERS INVOLVED IN CLAIMS \| 1996-98 \| 1999 \| 2000 \| 2001 \| 2002 \| 2003 \| 2004 \| 2005 \| 2006 \| 2007 \| 2008 \| 96-08 \| % \| \|---------------------------\|---------\|------\|------\|------\|------\|------\|------\|------\|------\|------\|------\|-------\|------\| \| Paraíba \| \| \| \| \| \| \| \| \| \| \| \| \| 0.0% \| \| Rio G, do Norte \| \| \| \| \| \| \| \| \| \| \| \| \| 0.1% \| \| Acre \| \| \| \| \| \| \| \| \| \| \| \| \| 0.1% \| \| Rio G, do Sul \| \| \| \| \| \| \| \| \| \| \| \| \| 0.1% \| \| Amazonas \| \| \| \| \| \| \| \| \| \| \| \| \| 0.2% \| \| Amapá \| 199 \| \| \| \| \| \| \| \| \| \| \| \| 0.3% \| \| Santa Catarina \| \| \| \| \| \| \| \| \| \| \| \| \| 0.4% \| \| Ceará \| \| \| \| \| \| \| \| \| \| \| \| \| 0.5% \| \| Pernambuco \| \| \| \| \| \| \| \| \| \| \| \| \| 0.5% \| \| Rondônia \| 9 \| 28 \| 516 \| 245 \| 567 \| 683 \| 326 \| 1,412 \| 444 \| 117 \| 578 \| 611 \| 1.1% \| \| Alagoas \| 70 \| \| \| \| \| \| \| \| \| \| \| \| 1.3% \| \| Rio de Janeiro \| 36 \| \| \| \| \| \| \| \| \| \| \| \| 1.3% \| \| Espírito Santo \| 172 \| 38 \| 96 \| 184 \| 276 \| 347 \| 484 \| 284 \| 378 \| 99 \| 2,544 \| 786 \| 1.4% \| \| Piauí \| 199 \| \| \| \| \| \| \| \| \| \| \| \| 1.4% \| \| São Paulo \| 320 \| 47 \| 50 \| 16 \| 142 \| 261 \| 404 \| 277 \| 704 \| 867 \| 2,602 \| 857 \| 1.5% \| \| Paraná \| 280 \| \| \| \| \| \| \| \| \| \| \| \| 1.6% \| \| Minas Gerais \| 836 \| 43 \| 180 \| 29 \| 23 \| 26 \| 39 \| 1634 \| 245 \| 2,153 \| 1,896 \| 593 \| 3.2% \| \| Mato G, Sul \| \| \| \| \| \| \| \| \| \| \| \| \| 3.7% \| \| Goiás \| 47 \| 19 \| 23 \| 1,094 \| 150 \| 314 \| 1045 \| 175 \| 106 \| 2,884 \| 2,602 \| 857 \| 4.5% \| \| BAHIA \| \| \| \| \| \| \| \| \| \| \| \| \| 5.0% \| \| TOCANTINS \| 13 \| 77 \| 17 \| 707 \| 847 \| 848 \| 657 \| 570 \| 238 \| 3,974 \| 2,602 \| 857 \| 6.9% \| \| MARANHÃO \| 155 \| \| \| \| \| \| \| \| \| \| \| \| 8.1% \| \| MATO GROSSO \| 656 \| 136 \| 106 \| 723 \| 1,268 \| 1,003 \| 1,873 \| 953 \| 315 \| 605 \| 7,633 \| 2,602 \| 857 \| 13.1% \| \| PARÁ \| 1,417 \| 462 \| 334 \| 989 \| 4,534 \| 3,793 \| 2,464 \| 3,198 \| 2,899 \| 3,317 \| 1,581 \| 24,988\| 43.3% \| \| TOTAL \| 3,881 \| 966 \| 799 \| 1,823 \| 5,840 \| 8,306 \| 5,812 \| 7,612 \| 6,941 \| 8,674 \| 7,022 \| 57,653\| 100.0%\| \| % \| 7% \| 2% \| 1% \| 3% \| 10% \| 14% \| 10% \| 13% \| 12% \| 15% \| 13% \| 100.0%\| ### RURAL SLAVERY – Claims & Inspections – previous 2 years \| STATE \| Claims registered \| Claims investigated \| Workers involved \| Workers freed \| \|-------\|-------------------\|---------------------\|------------------\|--------------\| \| \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| \| PA \| 134 \| 133 \| 2,899 \| 3,317 \| 50 \| 59 \| 1,180 \| 1,933 \| \| MA \| 25 \| 32 \| 450 \| 732 \| 15 \| 14 \| 284 \| 378 \| \| TO \| 36 \| 21 \| 657 \| 570 \| 20 \| 14 \| 455 \| 91 \| \| MT \| 22 \| 19 \| 953 \| 315 \| 11 \| 9 \| 444 \| 117 \| \| MS \| 3 \| 13 \| 39 \| 1,634 \| 3 \| 13 \| 29 \| 1,634 \| \| GO \| 4 \| 11 \| 277 \| 704 \| 2 \| 11 \| 154 \| 658 \| \| MG \| 6 \| 6 \| 233 \| 532 \| 6 \| 5 \| 221 \| 425 \| \| BA \| 16 \| 5 \| 1,045 \| 175 \| 12 \| 5 \| 589 \| 175 \| \| PI \| 1 \| 4 \| 54 \| 241 \| 1 \| 3 \| 54 \| 171 \| \| PR \| 5 \| 4 \| 64 \| 129 \| 5 \| 4 \| 64 \| 129 \| \| RJ \| 3 \| 4 \| 44 \| 49 \| 3 \| 4 \| 44 \| 49 \| \| SP \| 3 \| \| 102 \| \| 2 \| \| 61 \| \| \| SC \| 3 \| \| 52 \| \| 3 \| \| 52 \| \| \| CE \| 2 \| 2 \| 88 \| 19 \| 2 \| 2 \| 88 \| 19 \| \| RS \| 4 \| 1 \| 44 \| 47 \| 4 \| 1 \| 44 \| 47 \| \| ES \| 1 \| 1 \| 45 \| 22 \| 1 \| \| 22 \| \| \| AM \| 1 \| 1 \| 8 \| 10 \| 1 \| 1 \| 8 \| 10 \| \| AC \| 1 \| 1 \| 8 \| 2 \| 1 \| 1 \| 8 \| 2 \| \| PB \| 1 \| \| 22 \| \| \| \| \| \| \| RO \| 1 \| \| 25 \| \| \| \| \| \| \| Total \| 265 \| 265 \| 6,933 \| 8,674 \| 136 \| 152 \| 3,666 \| 5,973 \| ### RURAL SLAVERY – Claims & Inspections – previous 2 years \| REGION \| Claims registered \| Claims investigated \| Workers involved \| Workers freed \| \|--------\|-------------------\|---------------------\|------------------\|--------------\| \| \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| \| CO \| 29 \| 43 \| 1,269 \| 2,653 \| 16 \| 33 \| 627 \| 2,409 \| \| N \| 173 \| 156 \| 3,597 \| 3,899 \| 72 \| 75 \| 1,651 \| 2,036 \| \| NE \| 44 \| 44 \| 1,637 \| 1,189 \| 30 \| 24 \| 1,015 \| 743 \| \| S \| 9 \| 8 \| 108 \| 228 \| 9 \| 8 \| 108 \| 228 \| \| SE \| 10 \| 14 \| 322 \| 705 \| 9 \| 12 \| 265 \| 557 \| \| TOTAL \| 265 \| 265 \| 6,933 \| 8,674 \| 136 \| 152 \| 3,666 \| 5,973 \| \| Sub-total AMAZON REGION \| 203 \| 207 \| 5,302 \| 4,928 \| 101 \| 98 \| 2,379 \| 2,531 \| \| % REGION \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| 2006 \| 2007 \| \|----------\|------\|------\|------\|------\|------\|------\|------\|------\| \| CO \| 10.9% \| 16.2% \| 18.3% \| 30.7% \| 11.8% \| 21.1% \| 17.1% \| 40.3% \| \| N \| 65.3% \| 58.9% \| 51.9% \| 45.1% \| 52.9% \| 49.3% \| 45.0% \| 34.1% \| \| NE \| 16.6% \| 16.6% \| 23.6% \| 13.7% \| 22.1% \| 16.4% \| 27.7% \| 12.4% \| \| S \| 3.4% \| 3.0% \| 1.6% \| 2.6% \| 6.6% \| 5.3% \| 2.9% \| 3.8% \| \| SE \| 3.8% \| 5.3% \| 4.6% \| 8.1% \| 6.6% \| 7.9% \| 7.2% \| 9.3% \| \| TOTAL \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| 100.0% \| \| Sub-total AMAZON REGION \| 83.0% \| 78.1% \| 72.1% \| 56.9% \| 72.1% \| 64.5% \| 64.9% \| 42.4% \| ## BY BRANCH OF ACTIVITY – data: SIT & CPT; process.: CPT \| ACTIVITY – 2008 \| CLAIMS REGISTERED \| % \| CLAIMS INSPECTED \| % \| WORKERS INVOLVED \| % \| WORKERS FREED \| % \| \|-----------------\|-------------------\|---\|------------------\|---\|------------------\|---\|--------------\|---\| \| DEFORESTATION \| 6 \| 2%\| 6 \| 3%\| 99 \| 1%\| 83 \| 2%\| \| RANCHING \| 135 \| 48%\| 86 \| 40%\| 1,726 \| 25%\| 1,026 \| 20%\| \| REFORESTATION \| 19 \| 7%\| 19 \| 9%\| 264 \| 4%\| 248 \| 5%\| \| SUGAR CANE \| 20 \| 7%\| 20 \| 9%\| 2,553 \| 36%\| 2,553 \| 49%\| \| OTHERS PLANTATIONS\| 35 \| 13%\| 29 \| 14%\| 876 \| 12%\| 720 \| 14%\| \| CHARCOAL \| 46 \| 16%\| 38 \| 18%\| 1,235 \| 18%\| 410 \| 8%\| \| OTHER or n.i \| 14 \| 5%\| 11 \| 5%\| 201 \| 3%\| 155 \| 3%\| \| TOTAL \| 280 \| 100%\| 214 \| 100%\| 7,022 \| 100%\| 5,244 \| 100%\| \| ACTIVITY – 2007 \| CLAIMS REGISTERED \| % \| CLAIMS INSPECTED \| % \| WORKERS INVOLVED \| % \| WORKERS FREED \| % \| \|-----------------\|-------------------\|---\|------------------\|---\|------------------\|---\|--------------\|---\| \| DEFORESTATION \| 12 \| 5%\| 5 \| 3%\| 128 \| 1%\| 55 \| 1%\| \| RANCHING \| 157 \| 59%\| 81 \| 53%\| 2,888 \| 33%\| 1,430 \| 24%\| \| REFORESTATION \| 5 \| 2%\| 5 \| 3%\| 165 \| 2%\| 165 \| 3%\| \| SUGAR CANE \| 9 \| 3%\| 7 \| 5%\| 3,543 \| 41%\| 3,060 \| 51%\| \| OTHERS PLANTATIONS\| 18 \| 7%\| 11 \| 7%\| 730 \| 8%\| 476 \| 8%\| \| CHARCOAL \| 24 \| 9%\| 8 \| 5%\| 504 \| 6%\| 249 \| 4%\| \| OTHER or n.i \| 40 \| 15%\| 35 \| 23%\| 716 \| 8%\| 538 \| 9%\| \| TOTAL \| 265 \| 100%\| 152 \| 100%\| 8,674 \| 100%\| 5,973 \| 100%\| \| ACTIVITY – 2003-2006 \| CLAIMS REGISTERED \| % \| CLAIMS INSPECTED \| % \| WORKERS INVOLVED \| % \| WORKERS FREED \| % \| \|----------------------\|-------------------\|---\|------------------\|---\|------------------\|---\|--------------\|---\| \| DEFORESTATION \| 66 \| 7%\| 44 \| 8%\| 2,517 \| 9%\| 1,446 \| 9%\| \| RANCHING \| 642 \| 64%\| 320 \| 56%\| 14,050 \| 50%\| 6,510 \| 40%\| \| REFORESTATION \| 5 \| 1%\| 5 \| 1%\| 216 \| 1%\| 173 \| 1%\| \| SUGAR CANE \| 10 \| 1%\| 8 \| 1%\| 1,896 \| 7%\| 1,605 \| 10%\| \| OTHERS PLANTATIONS \| 108 \| 11%\| 77 \| 13%\| 5,066 \| 18%\| 3,415 \| 21%\| \| CHARCOAL \| 88 \| 9%\| 58 \| 10%\| 2,074 \| 7%\| 1,302 \| 8%\| \| OTHER or n.i \| 77 \| 8%\| 58 \| 11%\| 2,134 \| 7%\| 1,798 \| 11%\| \| TOTAL \| 996 \| 100%\| 571 \| 100%\| 27,951 \| 100%\| 16,249 \| 100%\| \| ACTIVITY – 2003-2008 \| CLAIMS REGISTERED \| % \| CLAIMS INSPECTED \| % \| WORKERS INVOLVED \| % \| WORKERS FREED \| % \| \|----------------------\|-------------------\|---\|------------------\|---\|------------------\|---\|--------------\|---\| \| DEFORESTATION \| 85 \| 6%\| 56 \| 6%\| 2,744 \| 6%\| 1,584 \| 6%\| \| RANCHING \| 934 \| 61%\| 485 \| 52%\| 18,664 \| 43%\| 8,966 \| 33%\| \| REFORESTATION \| 29 \| 2%\| 29 \| 3%\| 645 \| 1%\| 586 \| 2%\| \| SUGAR CANE \| 39 \| 3%\| 35 \| 4%\| 7,992 \| 18%\| 7,218 \| 26%\| \| OTHERS PLANTATIONS \| 125 \| 8%\| 101 \| 11%\| 5,642 \| 13%\| 4,290 \| 16%\| \| CHARCOAL \| 158 \| 10%\| 103 \| 11%\| 3,813 \| 9%\| 1,961 \| 7%\| \| OTHER or n.i \| 157 \| 10%\| 119 \| 13%\| 3,727 \| 9%\| 2,490 \| 9%\| \| TOTAL \| 1,540 \| 100%\| 937 \| 100%\| 43,624 \| 100%\| 27,461* \| 100%\| (*) out of total 27,888 workers freed during this period \| DIRTY LIST 15/07/2008 \| STATE \| Nb of EMPLOYERS \| Nb FREED WORKERS \| Rk \| \|----------------------\|-------\|-----------------\|------------------\|----\| \| 1 \| PA \| 50 \| 1,628 \| 1 \| \| 2 \| MA \| 38 \| 889 \| 4 \| \| 3 \| TO \| 27 \| 645 \| 6 \| \| 4 \| GO \| 26 \| 530 \| 7 \| \| 5 \| MS \| 16 \| 658 \| 5 \| \| 6 \| MT \| 13 \| 1,089 \| 3 \| \| 7 \| BA \| 10 \| 1,267 \| 2 \| \| 8 \| SC \| 4 \| 46 \| 11 \| \| 9 \| RO \| 4 \| 438 \| 8 \| \| 10 \| MG \| 3 \| 39 \| 12 \| \| 11 \| PR \| 3 \| 106 \| 9 \| \| 12 \| CE \| 2 \| 44 \| 12 \| \| 13 \| PI \| 2 \| 104 \| 10 \| \| 14 \| AM \| 1 \| 2 \| 16 \| \| 15 \| RN \| 1 \| 29 \| 13 \| \| 16 \| AC \| 1 \| 12 \| 15 \| \| 17 \| ES \| 1 \| 22 \| 14 \|	<urn:uuid:472b122c-0573-47e7-9505-f41f5f9eb895>	CC-MAIN-2017-22	http://reporterbrasil.org.br/documentos/stats_cpt_31_12_2008.PDF	2017-05-27T02:41:19Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-22/segments/1495463608765.79/warc/CC-MAIN-20170527021224-20170527041224-00145.warc.gz	387,009,310	9,278	eng_Latn	eng_Latn	0.811946	eng_Latn	0.881787	[ "eng_Latn", "eng_Latn", "unknown", "eng_Latn", "eng_Latn", "unknown" ]	false	docling	[ 3980, 11097, 17532, 20984, 25640, 27067 ]
International Peat 14TH Congress Abstract no: 154 Peatland strategies and programs in Finland Anne Tolvanen 1 1) Finnish Forest Research Institute, Finland Finland has about 10 million hectares of mires and peatlands, which is a third of the land area. 52% of the area of mires has been drained for forestry, 13% is protected, and 60,000 hectares/yr are used for peat production. Multiple needs and values therefore relate to the use of peatlands. Finnish National Strategy for Mires and Peatlands was submitted by the Ministry of Agriculture and Forestry in February 2011. The aim was to create common understanding of the sustainable and diverse use of mires and peatlands. Practical questions were: 1) what to do with drained unproductive peatlands, 2) where to direct peat production, and 3) what are further peatland protection needs. At the same time when the National Strategy was completing, planning of local peatland programs with similar sustainability aims and target questions were launched. In Northern Ostrobothnia, the peatland-richest region in Finland, a large interdisciplinary research project was launched as a part of the local peatland program to give information on the biodiversity state, economical impacts, and social values of peatlands. Local stakeholders were involved in the project through interviews and questionnaires. Based on existing data, tens of new high biodiversity areas outside protected areas were found. Peatlands were found to be an essential source of living for people, but depending on their occupation, either pristine or managed peatlands were preferred. Conflicting opinions revealed by the questionnaires indicate that the peatland programs will face strong arguments regardless the suggestions. Further results will be discussed in the congress.	<urn:uuid:64eddebf-4729-4008-9af1-d3cec63d2e99>	CC-MAIN-2024-33	https://peatlands.org/assets/uploads/2019/06/Tolvanen154.pdf	2024-08-11T06:43:07+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-33/subset=warc/part-00173-4f628544-3cdf-4526-86aa-bdfa0b33cdc9.c000.gz.parquet	354,767,871	379	eng_Latn	eng_Latn	0.997888	eng_Latn	0.997888	[ "eng_Latn" ]	false	rolmOCR	[ 1806 ]
THE CALL BEYOND VOLUME 44 NO.12 15 DECEMber 2019 Heaven's call is rare, rarer the heart that heeds; The doors of light are sealed to common mind, And earth's needs nail to earth the human mass, Only in an uplifting hour of stress Men answer to the touch of greater things: Or, raised by some strong hand to breathe heaven-air… -Sri Aurobindo (Savitri, Book 11, Canto 1, p. 689) An Online Publication of SRI AUROBINDO ASHRAM - DELHI BRANCH www.sriaurobindoashram.net Highlights Contents From Christmas to New Year is Just One Week From Delhi to Agra is 200 km, and so is the distance from Agra to Delhi. Why then Christmas to New Year is just one week, but New Year to Christmas is almost a year? This question may be answered in at least two ways. The calendar gives us the mechanistic reason for the discrepancy. On the other hand, the teleological reason for the discrepancy is that the long gap between New Year and Christmas is to give us time for work between the celebrations. Leaving this frivolous question aside, from birth to death is just three score and ten years, how about the interval between death and being born again? Some would have it, the question is absurd because this is the only life we have. But even those who believe in rebirth may not know for sure. The interval between death and rebirth is said to be highly variable, and may range from a few days in some cases to several centuries in others. Having several lives available for completing the journey of the soul may be a good thought to relax the mind, but if we waste each life because there are many more available, the journey will never be over! Hence, no matter what we believe in, what we do with this life is itself important. The unique purpose of human life is spiritual growth, or growth of consciousness. We do not have to accept this idea just because religious and spiritual traditions say so. We are tempted to accept it because happy and fulfilled people in the world are only those who are living a life that leads to spiritual growth. The life that leads to spiritual growth is filled with choices driven by love, compassion, giving, caring and sharing. Those who are making these choices are not making them because they want to grow spiritually. They are making these choices because they respond positively to the voice of the soul, which is higher than the voice of reason. Responding positively brings with it the clarity and courage required to do what is right. Making the right choices in life gives a sense of joy and lasting mental peace. Spiritual growth is also a by-product of making the right choices. The more we grow spiritually, the easier it becomes to make the right choices. Making the right choices leads to further spiritual growth. Thus the process of spiritual growth is selfperpetuating. It is spiritual growth that the Mother referred to when She said that the aim of life should be high and wide, generous and disinterested. That gives us plenty to do during the long gap between the New Year and Christmas. A mutual debt binds man to the Supreme: His nature we must put on as he put ours; We are sons of God and must be even as he: His human portion we must grow divine. Our life is a paradox with God for key. Sri Aurobindo, In: 'Savitri', Book 1, Canto 4, p.67 First posted as a blog on the Speaking Tree website on 25 December 2011. Link: https://www.speakingtree.in/blog/from-christmas-to-new-year-is-just-one-week Mental Fasting Tarun Baveja Apart from a very few exceptions, it is absolute silence that is put against unbridled talkativeness. Yet it is a much greater and more fruitful austerity to control one's speech than to abolish it altogether. The Mother, on mental austerity, in 'Four Austerities and Four Liberations' 'All excess is bad,' says an age-old dictum. Being overfed is as bad as starvation. We try to compensate for feasting by fasting. For food, that is common knowledge. But it applies just as much also to the mind. Why mental fasting? The mind is fed by the five senses. The eyes are these days fed an overdose of screens ranging from smartphones to not so smart TVs (remember, once the TV was called the idiot box). If we move the eyes away from the screen, there is no shortage of pulp fed to us by the newspapers which are more ads than news. The ears are plugged not to keep the sound out, but to be fed on a continuous cacophony doled out by earphones. If a 'friend' makes us unplug the ears, it is not to wish us 'Hari Om ' or 'Ram Ram' but to gossip about things that do no good to either of us. The nose is exposed to the smell of polluted air. The tongue has forgotten the taste of water because we get to drink anything from polluted gangajal to water that has gone through half a dozen treatments before it was trapped in a plastic bottle a few months ago. The skin is touched by synthetic clothing pressed against the body by an ergonomically designed chair. Sitting in that chair has become today's sukhasana. And children, before they are ten, are taught to fear the bad touch. In short, our minds are being overfed with a continuous supply of sensory inputs. Further, the quality of the mental food is toxic. It is food that is difficult for the mind to digest. Hence, there is a need for periodic mental fasting. What is mental fasting? One way to escape the barrage of stimuli and information that poison the mind would be to go and settle in a forest or a cave. But that does not suit most of us. Further, those of us who have chosen the spiritual path shown by Sri Aurobindo and The Mother would much rather engage with the real world to transform ourselves as well as seek to raise the consciousness of the human race. Therefore, what one can do without renouncing the world and worldly life, is to observe a periodic mental fast during which there is a voluntary and conscious ruthless effort to curb sensory inputs. Some of the articles that may be turned off during the mental fast are the TV, phone and computer. One can skip the newspaper and avoid meeting people. Fasting may be made more integral by combining mental fasting with keeping away also from food. While observing a fast is good, the spirit being fasting is even more important. The spirit behind the fast is to develop selfcontrol, to overcome the attachment to what has been given up during the fast. If during the fast, one is not eating but is thinking of the food all the time, the purpose of the fast is defeated. Similarly, during mental fasting, if one keeps thinking of the phone, the computer and the newspaper, it is of no use. But the mind cannot tolerate a vacuum. Therefore, one may not think of food or the phone, but one needs a substitute. The substitute should be higher, wider and deeper than what has been given up. Giving up the lower for the sake of something higher does not feel like giving up. Instead, it gives a feeling of relief and joy. That is what leads to true detachment from the lower. It is such detachment that Sri Aurobindo calls inner renunciation. What is the higher, wider and deeper substitute? The highest, widest and deepest is the Everlasting, the Eternal, the Divine. Moving towards the Divine, or Brahman, is what Brahmcharya actually and literally means. How about thoughts unrelated to sensory inputs? One may stop thinking about the phone and food, but the mind is not dependent on raw material from outside for manufacturing thoughts. It has an amazing capacity to produce thoughts out of nothing; amazing at least in quantity if not in quality, and often in quantity at the expense of quality. That being so, how effective can mental fasting really be? That is why the power of concentration is necessary. We need will power to stop the chaotic activity of the mind, to streamline it for focused and desirable activity. This will power can be developed by good company, or satsang. We tend to have the type of thoughts that dominate our environment. We can do it by inner work, which has may be of three types. First, suppression of negative thoughts and feelings. This does not generally work. It may seem to work for a while, but the suppressed tendencies return, sooner or later, with renewed vigour. Secondly, substitution of negative thoughts by their opposites. This works better than suppression. Finally, sublimation of negative tendencies to a spiritual aspiration so that the negativities lose their relevance for the person; they just fade away. This works best. The inner work can be done during meditation. Meditation need not be a formal and rigid practice. It can be with the eyes closed or open. It can be silent repetition of a mantra. It can be a 'writing meditation,' in which a person simply copies from a scripture while also meditating on what he is writing. In conclusion… That we need a break is widely recognized today as something indispensable in the fast-paced, unhealthy and non-elevating environment in which we live. But the break is often a vacation from which the person returns broke and broken rather than healed and restored. Giving a thought to the type of break we really need can help in making deviation from routine a meaningful, rejuvenating and uplifting experience. Based on a talk by Dr. Tarun Baveja in the Ashram's Meditation Hall in the Sunday Satsang series on 1 December 2019. Dr. Baveja is the medical officer incharge of The Mother's Integral Health Centre. Religion and True Spiritual Life Religion exists almost exclusively in its forms, its cults, in a certain set of ideas, and it becomes great only through the spirituality of a few exceptional individuals, whereas true spiritual life, and above all what the supramental realization will be, is independent of every precise, intellectual form, every limited form of life. It embraces all possibilities and manifestations and makes them the expression, the vehicle of a higher and more A new religion would not only be useless but very harmful. It is a new life which must be created; it is a new consciousness which must be expressed. This is something beyond intellectual limits and mental formulae. It is a living truth which must manifest. Everything in its essence and its truth should be included in this realization. This realization must be an expression as total, as complete, as universal as possible of the divine reality. Only that can save humanity and the world. The Mother ('The Great Adventure', p. 23) A Defence of Indian Culture India has lived and lived greatly, whatever judgment one may pass on her ideas and institutions. What is meant after all by life and when is it that we most fully and greatly live? Life is surely nothing but the creation and active self-expression of man's spirit, powers, capacities, his will to be and think and create and love and do and achieve. When that is wanting or, since it cannot be absolutely wanting, depressed, held under, discouraged or inert, whether by internal or external causes, then we may say that there is a lack of life. Life in its largest sense is the great web of our internal and external action, the play of Shakti, the play of Karma; it is religion and philosophy and thought and science and poetry and art, drama and song and dance and play, politics and society, industry, commerce and trade, adventure and travel, war and peace, conflict and unity, victory and defeat and aspirations and vicissitudes, the thoughts, emotions, words, deeds, joys and sorrows which make up the existence of man. … … In what field indeed has not India attempted, achieved, created, and in all on a large scale and yet with much attention to completeness of detail? … … Not to be as the common man, that is to say, as the crude natural, or half-baked human being, was indeed the sense of this ancient endeavour and in that sense it may be called an aristocratic culture. But it was not a vulgar outward but a spiritual nobility which was the aim of its self-discipline. Indian life, personality, art, literature must be judged in this light and appreciated or depreciated after being seen in the real sense and with the right understanding of Indian culture. Sri Aurobindo (In the Arya, Vol. 6, No. 5, 15 December 1919, pp. 279-293) A sophisticated hi-tech journalist raises a key question Do You Speak Computerese? Dave Barry For many of us, the first experience with computers occurs in the workplace. This was certainly true in the newspaper business. One day we reporters came to the office and discovered that our old, slow typewriters had been replaced by sleek, efficient computers with keys that said mysterious, scary things like "BREAK" and "NUM LOCK." Fortunately, we were trained by highly skilled professional personnel. "Before you macro your ASCII, you have to format your RAM," they advised us. We reporters were wary at first, but after just 175 weeks of training, we discovered that, instead of writing on old fashioned paper, we could create lengthy articles entirely on the screen, and then, simply by pushing a button, send them to ... the Planet Zembar! "Where the hell is my story!?" we would shout. But the lost texts always turned out to be our own fault. We had invariably committed some bonehead data-processing error such as failing to modem our ROM BIOS VGA megahertz cache. But gradually we got the hang of it, and today we routinely use highly sophisticated, multimillion- dollar systems to perform a function that is vital to the survival of a free society – namely, sending personal messages to each other. Walk into a newspaper office, and you'll see serious looking journalists clattering away on their keyboards. It seems as though they're writing important stories about the plight of the Kurds, but in fact they are sending each other the joke about what the male giraffe said to the female giraffe in the bar. In the old days, journalists had to transmit jokes manually. Of course, there are a few problems. You may have read about "viruses," which computers get when they're left uncovered in draughty rooms. This is bad, because if you're working on an infected machine it will periodically emit electronic sneezes – unfortunately not detectable by the naked eye. You are showered with billions of tiny electronic microbes, called "bytes," which penetrate your body and gradually make you stupid. This is definitely happening to me. I'll sit down at my home computer to write a thoughtful column about, say, foreign policy, and I'll type: "In view of the recent dramatic changes in the world geopolitical situation, it's time to play some Solitaire." My computer has a Solitaire-playing program on it, probably invented by the Japanese in an effort to sabotage other countries' economies. I used to think that was a boring game, but now that my brain is clogged with computer germs, I spend hours moving the electronic cards around, staring at the screen with the same facial expression as a mullet, while the computer sneezes on me. None of this was possible just 15 years ago. Undoubtedly, the computer is a most important invention in human history. So if you don't already have one in your home, I strongly recommend that you get one. Without it, you will never be able to know the answers to some pertinent questions, especially: what did the male giraffe say to the female giraffe in the bar? The answer is "The higpowoifj&kjfkyO." Hold it, there seems to be a keyboard problem here. Let me just try plugging this cable into.... ERROR ERROR ERROR ALL FILES HAVE BEEN DESTROYED. Sometimes I feel like pouring coffee into my computer and listening to its screams. But of course, I would never do that. Courtesy: Reader's Digest Reproduced from The Call Beyond, Vol. 19, No. 4, p. 46, 1994 Being Different My Life as an Apple Tree: a true story of courage, inspiration and lifechanging power by Colleen-Joy Page. Johannesburg: Red Nolan, 2002. The book is an autobiographical work of Colleen-Joy Page, who traces the journey of her life to give the readers a taste of what belief and will can conquer. will be fine. Then there is a flashback from the author's life as she reminisces about her own early life experiences as one blessed with psychic abilities. By the age of sixteen, she had started using her intuitive abilities to make significant predictions to a growing base of clientele and people around her were duly impressed. She also gives us a glimpse of how sometimes thoughts and visions can be misplaced and if not paid enough attention to or nurtured, can pass out The book opens quite dramatically, describing the intense pain and anguish of a mother (the author herself) forced to undergo the trauma of watching her little daughter, just 14-hours old, under the grip of unbearable suffering in a hospital. Lines like "freshly sprayed blood on the bed from her bleeding wrist" tells the reader how the child's mother would be feeling. Yet when the mother mentions her daughter to be a fighter the reader finds solace and starts believing all of our system like other unwanted material. The author, however, had learnt to engage with these intuitive flashes and make meaningful interpretations even as a teenager. Further on in the book, the author reveals her own difficult childhood because of a large tumor on her forehead, which had to be treated surgically. She describes how her own childhood memories comprised of scenes from the hospital and what inner agony she had to go through. During her stints at the hospital, at the very young age of five years, the author realizes what is the social definition of being good. Goodness, she feels is like wearing a mask to hide one's true feelings and pretend to be happy and not cause trouble to anyone. It has nothing to do with truly feeling happy or real. Sometimes, one needs masks of all kinds to cover up one's lacunae. The world is not kind to people differing starkly from the majority; a highly visible physical anomaly being the worst kind of difference. Born in a family that took special pride in being prim, proper and picture-perfect, it was difficult for the author as a child with her tumor, to be accepted as normal. The author picked up that masks, like acting extremely good, provides one with the security of being judged less. The world in its race for normalcy tends to reject what the abnormal have to offer. A self-certified normalcy leads to a feeling of superiority that discourages positive change and further evolution. The Mother warns us about how a puritan notion of virtue can stall our very progress by enhancing our ego. Complexes of inferiority in a child, created by a selfobsessed world can hamper her self-confidence as she grows up. We see this effect of childhood guilt and humiliation throughout the book upon the author's conscience until she is able to finally rise above it through her spiritual strength. book review 17 The author goes on to talk about her experiences inside the hospital room, at the age of four when the tumor was removed through an operation. She mentions how being and acting good had become a part of her existence because of which she would not flinch even as a sharp needle would be inserted into her back. A sense of guilt always engulfed her for having brought this tragedy upon her parents and being obedient and good was the only compensation. These difficult circumstances for the author at a very young age, combined with her fear of losing her sight or dying during her operations, were some of the initial impetus towards finding a truer meaning in life, but she was too young to express these feelings or define them then. She describes how post her successful operation at age five, she experienced a strong inner call for something she was unsure of, a strange longing and yet she was sure it wasn't any delusion. This sense was further strengthened when the author had to go through a second wave of the same problem which required a re-operation. It was during this time, at age ten, that she once again grappled with the ideas of life and death and everything in-between with a little more maturity than at age five. This was also the time when she increasingly started realizing her psychic abilities. The book further delves into the author's understanding of the concept of God, good, evil, recognition of various associated emotions and the seeking for her own truth. Amongst the stories of her growing up into a youth, we not only witness the various struggles of an adolescent but also the unusual ways that the author uses to deal with them and in the process understanding herself better. Her book can be a luminous guide for all adolescents who recognize their own struggles in the process of growing up and muster the courage to acknowledge and address them. The author also narrates her experiences with psychic practices like tarot and Ouija board but later realizes these were mere tools to help her further polish her psychic abilities. But more importantly, empathizing with the suffering of her clients, the author is able to realize the universal truth behind universal human suffering. She also realizes though that the predictions that she makes are never certain and do not warrant 'caging' the minds of her clients in predictions that could 'shape or destroy' their lives. Perhaps, the author here gets a hint of the universal free-will that has been bestowed upon humanity. However, the author eventually realized the futility of making predictions as it could make the clients over-dependent on her. Besides, as The Mother has also advised, trying to help humanity through bits and pieces with our own limited understandings is a difficult proposition since the only certain and true help that humanity can have is that from the Divine. The author slowly observed that her help was in no way improving the lives of her clients who would generally resign to fate rather than take action against it. Further, she also realized that her constant practice of the same for her clients drew away all her energy, leaving her tired and drenched and finally she decided to stop. Finally, it was her own psychic capabilities that through a dream helped her resolve this dilemma of whether to continue helping others or look for a greater purpose in life. Moving on with her other passion, she found a vocation in art which eventually led her to finding a job and the love of her life. The author's move from her most passionate pre-occupation to finding a job through her alternate passion, ending up marrying a colleague, also signifies how we sometimes need to let go of something good in our lives to reach a better destiny. The author's detailed romantic expeditions, I feel are an amazing insight into lessons on growing in love. The Mother has mentioned about how love grows in stages of wanting a return to wanting acceptance to simply loving for the joy of love. In the different relations that youngsters go through, it is precisely this life lesson that they are supposed to learn rather than getting caught up in the web of right versus wrong. The author's experiences in a mature relationship, handling the proposal of marriage very intelligently at a young age as well as being cheerful and wild at different stages with different men are helpful life lessons. Eventually, she is able to navigate her way through this maze into a successful and happy marriage and goes on to have a daughter. But, it is precisely when she settles down for a normal, regular life, that life hands her a new set of challenges, this time to take her beyond all her limits and excel with flying colors. After the birth of her first child Megan, when the author is excited for her second baby, she can get a feeling of something going wrong with the baby. Eventually, the baby is born with a congenital defect that requires several surgical operations and this is where the book had begun. The author then takes us through a trail of events that describe her intuitive openings further in a tumultuous time of fighting for the baby's health as well as a financial crisis that eventually starts affecting their married life. But instead of falling apart, the author chose to dig out the gold of spirituality from her experiences and eventually meets with an understanding of the body and the soul. Her insights become clearer and so do her realizations. She moves beyond tools like astrology and tarot into the soul-connect and realizes that significant life-changing answers did not come from outside, but from inside. When the focus of intuition is shifted inwards, it starts revealing deeper truths. Sometimes, trivial benefits of the intuitive consciousness need to be sacrificed for a true search of our psychic beings. Eventually, she could connect with her clients at the level of their souls and this unity helped her understand their stage of personal growth and development. However, the greatest challenge to her intuitive abilities comes in the form of a test when she is faced with taking decisions about her child's health, based purely on her intuitions, which meant going against the experts in medical science. Her decisions could even mean losing her baby's life. It is in this moment of crisis that she takes a leap of faith, connecting to her child's soul, going purely by her intuitive abilities, refusing to get her child operated, taking the risk. But out of her faith in her own psychic abilities, emerges her greatest strength that not only saves her baby but also eventually prepares her for a life of purpose. The author beautifully ends the book by revealing how every circumstance is a means to progress if you make it one. Echoing Sri Aurobindo's words in 'Savitri', "None can reach Heaven who has not passed through Hell", the author describes how her struggles to fight her own fears of facing people, communicating the hidden fears of a small four year old self, who was unable to see herself as beautiful, who felt burdened with the guilt of bringing in shame for her family rises out of the ashes to find her truth – that she is an apple tree, meant to blossom and bring forth fruits. She is finally able to recognize what the universe had so far been pushing her to become through all the difficulties in life – it was a spiritual communicator. She realizes her purpose of life was to find the unity of beings, to accept and love herself with all the bodily flaws as well as love others and to start believing in her soul, rising above any conditional form of love. She reveals how changing one's own self is the best example for demonstrating to others what the possibilities of the body, mind and soul are. The book has excellent lessons for spiritual seekers, replete as it is with the authentic personal experiences of an evolving soul that went from rejection to acceptance, from success to sorrow, and emerged stronger in spirit through each experience. The book would be specially educative for those who are highly enamoured of psychic abilities as well as those who reject such abilities as impossible. The book brings out that psychic intuitions are real, and yet have limitations in how far they can take a person on the spiritual path. For those who are specially gifted with such abilities, the key is to transcend them, and seek the Divine that manifests in such individuals through these gifts. Nilanjana Moitra Ph.D. student National University of Educational Planning and Administration There is a meaning in each curve and line. Sri Aurobindo ('Savitri', Book 6, Canto 2, p. 460) Windows to The Soul Jagdeep Singh Two windows to the soul, One of the heart, One of the mind, To unleash the divine power, That manifests everything, The good, the bad, The Angel, the devil, To create, to destroy, Here and beyond. The other opens to the inside, With the force of feelings, In love, Takes the plunge, In love, Risks everything, Restlessness at first, But lasting peace in the end. The window of the heart, Is hard to open. One opens to the outside, With the impulses of logic, Vents a rapid relief, With intellect, Takes away all the risks, But puts a burden on the soul. The window of the mind, Is hard to close. Feedback & Encouraging Words Feedback on Workshop on Integral Education Thirty-seven third year B.El.Ed. students from SPM College came to the Ashram for a one-day workshop on Integral Education on 16 November 2019 The session was very educative. We have learnt a number of learning theories yet, but to be able to derive some incisiveness is what happened with the help of today's session. The presentation was well-organised and it appeared to be based on the notion of proceeding from near to far, from familiar to unfamiliar, as it first permitted us to contemplate, how we as students who are on the verge of entering the job market can learn to incorporate our soul in our everyday decisions. It may mind us of our (as teachers) roles in the lives of children. Moreover, the session was interspersed with some activities to rejuvenate ourselves. Hence, it was one of my favourite educational visits so far. Saryu Sharma It helped me reflect upon my thoughts and actions. Hope I could go beyond memory and try to apply what I've learnt. The Yoga session was relaxing and soothing. I've never done Yoga so peacefully. Every time, I thought it is tough to practice Yoga but today was the first time. I felt relaxed and happy while doing the same. The Ashram is also very beautiful and soothing to the eye. It was really a heart-warming experience. Pooja Thakur The ashram was full of positive energy. In daily life hassles we forget to give something to our body and mind. But this session has made me realise how important it is to invest some time in the nourishment of our body, mind and soul. Also the yoga session has revived in me the asansas that we have performed in the second year of our course. The lunch we had was so tasty and had all nutrients and food components required for a good and healthy diet. As the saying "As we eat, so we think." The ashram food has 'Satvik value' which can have good impact on thought processes. The ashram's environment is very much spiritual and delightful. It encourages a person to believe in the oneness and togetherness of the world. I had a very great experience, enjoyed the session and that led me to mental peace and relaxation. Ritu Session were really interesting, I thoroughly enjoyed it. Most of the information shared by sir was new for me and I loved the way he talked about everything. Being from educational background. I got to know about lot of new teaching methodologies. I absolutely loved the environment of the ashram and the food which was served with much love. Shivani Gupta As I entered the Ashram, I felt like, I have come to a place of 'love and peace.' During the whole session I didn't feel bored at any time. To be very honest, I also want to be a part of this Ashram. Food given to us was best because in this running life there is no time for such healthy food, which I found here. After attending this session I feel motivated, energetic and I will try my best to be one of those teachers whose vision was developed by Shri Aurobindo and The Mother. The session was all on spirituality but it was communicated to us in such a way that I understood each and every argument, which was one of the best things about today. Harpriya The session was very useful for us as aspiring teachers. The food was very tasty. I liked the plants and trees here and also the peacocks around. Overall, it was great experience of my life. Kirti The session was planned well with different activities and appropriate duration of intervals. The food provided was very good and healthy. Meenakshi Yadav I found the session interactive and engaging. Overall, it was a development for us and our critical thinking. Yoga, short videos, stories, audios, songs were something which boosted energy level. Food system was quite impressive and new to me. It promotes self-discipline and the way it was offered to us was too in an order. Moreover, the maintenance of the whole place is in best way according to me. Ruchika It was my first visit to an ashram and I found it fascinating. The presentation was useful not only for me as an aspiring teacher but also as an individual. Nidhi Overall, the session was very good, interactive and different from what I expected. The yoga session, discussion about critical thinking, requirement of a primary class child, etc. was informative and enjoyable. The food was really healthy and tasty and I enjoyed it as the environment was really good with all the plants and birds. Everything is systematic and I liked it. Mehak Sethi Got a chance to know and learn about the integration of different aspects of learning and teaching. Some of the stories and examples would really help me in my life. I am happy for getting this opportunity. Yoga session was also good and the lunch was great. Got a chance to know and learn about the integration of different aspects of learning and teaching. Some of the stories and examples would really help me in my life. I am happy for getting this opportunity. Yoga session was also good and the lunch was great. Got a chance to know and learn about the integration of different aspects of learning and teaching. Some of the stories and examples would really help me in my life. I am happy for getting this opportunity. Yoga session was also good and the lunch was great. R.Padhmapriya I found it very useful for me as well as the information could be used in the classroom to help students. I personally liked the yoga session, because I love yoga. Activities made the session more interesting and it wasn't boring. Food was very good; I liked it. Intervals between the sessions gave us time to refresh ourselves. I found it very useful for me as well as the information could be used in the classroom to help students. I personally liked the yoga session, because I love yoga. Activities made the session more interesting and it wasn't boring. Food was very good; I liked it. Intervals between the sessions gave us time to refresh ourselves. I found it very useful for me as well as the information could be used in the classroom to help students. I personally liked the yoga session, because I love yoga. Activities made the session more interesting and it wasn't boring. Food was very good; I liked it. Intervals between the sessions gave us time to refresh ourselves. Thank you, for this great experience! Gauri Tiwari Sessions were nice and will help us in the future. The best parts were the stories and how we can help the child to reflect on their own. Sessions were nice and will help us in the future. The best parts were the stories and how we can help the child to reflect on their own. Sessions were nice and will help us in the future. The best parts were the stories and how we can help the child to reflect on their own. Aarzoo Mathur Today's class was highly useful and interactive. We learnt about Psychic education and it implications. Yoga was refreshing and peaceful. Today's class was highly useful and interactive. We learnt about Psychic education and it implications. Yoga was refreshing and peaceful. Today's class was highly useful and interactive. We learnt about Psychic education and it implications. Yoga was refreshing and peaceful. Kinnu Gola It enhanced my thinking towards becoming a teacher. Anshika Sahni Here I learnt some golden rules of life, which I couldn't learn from other places like my college or the society. Also, it gave me some idea about how to achieve one's goal and what is important or not in achieving the goal of life. About the food, the ashram maintains a proper diet. Towards the end, the session became tiring but sir facilitated some activity. So, it helped to regain some energy. The overall experience was good. Sakshi Yadav I feel internally highly motivated. Now I realise teaching is such a golden job. Babita To begin with, this was my first visit to an ashram. This was a very memorable one as it was totally different from the image of ashrams I had. The Ashram was very joyful and love giving and also the way they treated us the whole day was very welcoming. I learnt about what is Integral education. The concept of a vehicle and driver had a commendable impact on me. Also, the comparing of psychic education and value education was very good. Farheen Ahmed I felt that the session was very soulful. It's rare to have a complete experience which includes everything that is required by a person - Mind, Body and Soul. I could myself align all the three elements here today, and it gave me a sense of satisfaction. I can imagine the way little children that come here to study must be having life – long valuable learning experiences here. I would like to meet some of them on my own in the sessions scheduled for the next few days. The ambience over here is very peaceful. I personally feel connected to such environments and I am taking back a memorable experience with me. Shweta Bhardwaj Gratitude from the USA Dear Ramesh ji, Jeff Vander Clute, with the book Warm greetings from the USA after a sacred trip to Delhi, Varanasi, and Sarnath. As today is Thanksgiving in the United States, it feels especially appropriate to thank you for the signed copy of Understanding Spirituality and Living it 24x7. What a delight to see the printed edition! I'm lending it to my brother – a psychotherapist – as I sense it will help him and his clients. Jeff (Vander Clute) (in an e-mail dated 28 November 2019) Editor's note: Jeff Vander Clute was provided the manuscript of the book before it was printed. His endorsement, printed in the book, reads: "Understanding Spirituality is a transmission of profound insight, filled with crystal-clear explanations and illustrations of how we can all deepen in our humanity and discover our divinity. Reading this book, one has the sense that Dr. Bijlani's life is itself a demonstration of the synthesis of worldly endeavour and spiritual devotion. As such he is able to communicate the essence of the divine life using contemporary language and examples, with the elegant simplicity that comes from a lifetime of experience distilled into mastery. With every page, the clarity, wisdom, and loving, supportive presence of Sri Aurobindo and The Mother can be strongly felt, and by the end of the book, every aspect of life has been brought together – integrated – into a harmonious whole. In Understanding Spirituality, the path of our evolution is revealed, along with the means for always making wise decisions and staying true to the deepest longings of our soul. This book is a joy to read, and a precious gift to everyone on the spiritual journey. Jeff Vander Clute Co-founder, Sourcing The Way; Board Chair, Source of Synergy Foundation; Member, Evolutionary Leaders Circle, Seattle WA, USA" Feedback on the Ashram and The Mother's International School I am so grateful that I got the opportunity to read this wonderful book, 'Understanding Spirituality … and living it 24x7.' It has given me clarity on so many concepts . The way the author has explained is simple and drives the idea straight to the heart. I reside in Delhi and keep visiting the Ashram, mostly the SABDA store, and sometimes when the mind is disturbed sitting in the meditation hall in front of The Mother provides a lot of solace. My daughter studies in MIS. The school has truly contributed to her growth into becoming a sensible compassionate child... again a blessing of The Mother. Long back I worked as a financial consultant but then decided to travel from the mind to the heart... I got myself enrolled into a 4-year course on fine arts. Now I practice in my studio at South Delhi Polytechnic for women as a painter. Thank u once again for the book, 'Understanding Spirituality … and living it 24x7.' it has definitely contributed to my life. Regards always, Sanjukta (Sinha) (in an e-mail dated 20 November 2019) Contact us Our quarterly magazine in Hindi, Sri Aravind Karmadhara, is also available on-line now, and may be viewed on our website www.sriaurobindoashram.net. For a free subscription to Sri Aravind Karmadhara, please send an e-mail to [email protected] To get The Call Beyond online regularly, month after month, please send an e-mail to: [email protected] To learn about the recent and forthcoming activities through the Ashram's e-magazine, Realization, send an email to: [email protected] Please follow a simple two-step process: 1. Subject: Subscribe 2. Click on Send If you subscribe either to Realization, or to The Call Beyond, you will start receiving, month after month, both the magazines. For information about Auro-Mira Service Society and the Kechla project, please visit the website www.auromira.in Get in touch with Sri Aurobindo Ashram – Delhi Branch on: Our website: www.sriaurobindoashram.net YouTube: https://youtube.com/sriaurobindoashramdelhibranch Facebook: http://facebook.com/sriaurobindoashramdelhibranch Instagram: https://www.instagram.com/sriaurobindoashramdelhibranch Twitter: https://twitter.com/saadelhibranch Note In view of two major events coming: the Hundredth Anniversary of the Mother's Final Arrival in Pondicherry on 24 April 2020, and the Hundred and Fiftieth Birth Anniversary of Sri Aurobindo on 15 August 2022, the Ashram is expanding its mailing list to reach out to more and more who may benefit from the teachings of the Master and the Mother. To get included in the Mailing List, please go to http://erp.saaonline.net.in/addcontacts. cfm to fill in a form, which will take you only a few minutes. Please send your feedback to [email protected] The Call Beyond is a publication of Sri Aurobindo Ashram – Delhi Branch Sri Aurobindo Marg New Delhi 110 016 [email protected] 91-11-2656-7863	<urn:uuid:1b0c579e-4b33-4d5c-a13e-7b9afadc8cc3>	CC-MAIN-2020-16	http://sriaurobindoashram.net/ALL_PDF/CB_Dec2019.pdf	2020-04-02T20:50:29+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-16/subset=warc/part-00235-5e0433ee-fa15-4837-b2dc-d6f38301af97.c000.gz.parquet	174,282,753	8,901	eng_Latn	eng_Latn	0.97096	eng_Latn	0.998959	[ "eng_Latn", "eng_Latn", "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 382, 484, 494, 2327, 3465, 4913, 6718, 8497, 9443, 10464, 12242, 13925, 15397, 15757, 17029, 18889, 20794, 22668, 25569, 26390, 27572, 28207, 29578, 31431, 32752, 35511, 37141, 38844, 40098, 41283, 42003 ]
Florida Department of Education COURSE DESCRIPTION - GRADES 9-12, ADULT Subject Area: Language Arts Course Number: 1001370 Course Title: English III Credit: 1.0 Will meet graduation requirements for English Basic Assumptions for Language Arts Education: * Benchmarks for the Sunshine State Standards are repeated as needed in course sequences. As students progress from one course to the next, increases should occur in the complexity of materials and tasks and in the students' independence in the application of skills and strategies. * Reading, writing, speaking, listening and viewing competencies are integrated throughout students' learning experiences. * Learning tasks and materials accommodate the individual needs of students. * Technology is available for students to develop competencies in the language arts. A. Major Concepts/Content. The purpose of this course is to provide integrated educational experiences in the language arts strands of reading, writing, listening, viewing, speaking, language, and literature. The content should include, but not be limited to, the following: - using the reading process to construct meaning using technical, informative, and imaginative texts - using the research process and individual inquiry to locate, analyze, and evaluate information - using writing processes for various purposes with attention to style and format - using effective listening, speaking, and viewing strategies in informal and formal situations - understanding and analyzing literary texts - understanding the power of language as it impacts readers, writers, listeners, viewers, and speakers - responding critically and aesthetically to literature This course shall integrate the Goal 3 Student Performance Standards of the Florida System of School Improvement and Accountability as appropriate to the content and processes of the subject matter. B. Special Note. Students earning credit in English III may not earn credit in English Skills III, English Honors III, or English III Through ESOL. The emphasis should be on the works of American authors; however literature representative of other cultures may be used to support integrated studies and multicultural emphases. C. Course Requirements. These requirements include the benchmarks from the Sunshine State Standards that are most relevant to this course. After successfully completing this course, the student will: 1. Use and monitor own reading processes effectively to construct meaning from a range of technical, informative, and literary texts. LA.A.2.4.3 describe and evaluate personal preferences regarding fiction and nonfiction. LA.A.1.4.4 apply a variety of response strategies, including rereading, note taking, summarizing, outlining, writing a formal report, and relating what is read to his or her own experiences and feelings. LA.A.2.4.4 locate, gather, analyze, and evaluate written information for a variety of purposes, including research projects, real-world tasks, and self-improvement. 2. Use writing processes effectively to communicate ideas and process information for various purposes, reflecting appropriate styles, format, and conventions of standard English. LA.B.1.4.2 draft and revise writing that LA.B.1.4.1 select and use appropriate prewriting strategies, such as brainstorming, graphic organizers, and outlining. * is focused, purposeful, and reflects insight into the writing situation; * has effective use of transitional devices that contribute to a sense of completeness; * has an organizational pattern that provides for a logical progression of ideas; * has support that is substantial, specific, relevant, and concrete; * uses creative writing strategies as appropriate to the purpose of the paper; * demonstrates a commitment to and involvement with the subject; * demonstrates a mature command of language with precision of expression; * has varied sentence structure; and * has few, if any, convention errors in mechanics, usage, punctuation, and spelling. * correct spelling; LA.B.1.4.3 produce final documents that have been edited for * correct punctuation, including commas, colons, and common use of semicolons; * correct sentence formation; * correct capitalization; * correct instances of possessives, subject/verb agreement, instances of noun/pronoun agreement, and the intentional use of fragments for effect; and LA.B.2.4.2 organize information using appropriate systems. * correct formatting that appeals to readers, including appropriate use of a variety of graphics, tables, charts, and illustrations in both standard and innovative forms. LA.B.2.4.3 write fluently for a variety of occasions, audiences, and purposes, making appropriate choices regarding style, tone, level of detail, and organization. 3. Select and use appropriate speaking, listening, and viewing skills to clarify and interpret meaning in both formal and informal situations. LA.C.3.4.1 use volume, stress, pacing, enunciation, eye contact, and gestures that meet the needs of the audience and topic. LA.C.1.4.3 use effective strategies for informal and formal discussions, including listening actively and reflectively, connecting to and building on the ideas of a previous speaker, and respecting the viewpoints of others. LA.C.3.4.2 select and use a variety of speaking strategies to clarify meaning and to reflect understanding, interpretation, application, and evaluation of content, processes, or experiences (including asking relevant questions when necessary, making appropriate and meaningful comments, and making insightful observations). LA.C.3.4.4 apply oral communication skills to interviews, group presentations, formal presentations, and impromptu situations. LA.C.3.4.3 use details, illustrations, analogies, and visual aids to make oral presentations that inform, persuade, or entertain. LA.C.3.4.5 develop and sustain a line of argument and provide appropriate support. 4. Select and use appropriate language for effective visual, oral, and written communication. LA.D.2.4.2 understand the subtleties of literary devices and techniques in the comprehension and creation of communication. LA.D.1.4.2 make appropriate adjustments in language use for social, academic, and life situations, demonstrating sensitivity to gender and cultural bias. LA.D.2.4.3 recognize production elements that contribute to the effectiveness of a specific medium. 5. Demonstrate understanding of the ways that history, culture, and setting influence language. LA.D.1.4.3 understand that there are differences among various dialects of English. LA.D.1.4.1 apply an understanding that language and literature are primary means by which culture is transmitted. LA.D.2.4.1 understand specific ways in which language has shaped the reactions, perceptions, and beliefs of the local, national, and global communities. 6. Demonstrate understanding and respond aesthetically and critically to literature, including fiction, nonfiction, poetry, and drama. LA.E.1.4.5 understand the different stylistic, thematic, and technical qualities present in the literature of different cultures and historical periods. LA.E.1.4.2 understand why certain literary works are considered classics. LA.E.2.4.1 analyze the effectiveness of complex elements of plot, such as setting, major events, problems, conflicts, and resolutions. LA.E.2.4.3 analyze poetry for the ways in which poets inspire the reader to share emotions, such as the use of imagery, personification, and figures of speech, including simile and metaphor; and the use of sound, such as rhyme, rhythm, repetition, and alliteration. LA.E.2.4.2 understand the relationships between and among elements of literature, including characters, plot, setting, tone, point of view, and theme. Course Number: 1001370 - English III LA.E.2.4.4 understand the use of images and sounds to elicit the reader's emotions in both fiction and nonfiction. LA.E.2.4.6 recognize and explain those elements in texts that prompt a personal response, such as connections between one's own life and the characters, events, motives, and causes of conflict in texts. LA.E.2.4.5 analyze the relationships among author's style, literary form, and intended impact on the reader. LA.E.2.4.7 examine a literary selection from several critical perspectives. LA.E.2.4.8 know that people respond differently to texts based on their background knowledge, purpose, and point of view. 7. Use the research and critical inquiry processes to prepare documents and oral presentations. LA.A.2.4.7 analyze the validity and reliability of primary source information and uses the information appropriately. LA.A.2.4.6 select and use appropriate study and research skills and tools according to the type of information being gathered or organized, including almanacs, government publications, microfiche, news sources, and information services. LA.A.2.4.8 synthesize information from multiple sources to draw conclusions. LA.B.2.4.4 select and use a variety of electronic media, such as the Internet, information services, and desktop-publishing software programs, to create, revise, retrieve, and verify information.	<urn:uuid:4f00b9fe-bf9a-4f00-8d66-555e4f99f9b3>	CC-MAIN-2018-05	http://fofcai.com/PDF/1001370%20English%20III.pdf	2018-01-16T09:18:23Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-05/segments/1516084886397.2/warc/CC-MAIN-20180116090056-20180116110056-00681.warc.gz	130,255,207	1,849	eng_Latn	eng_Latn	0.988177	eng_Latn	0.989861	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1890, 3922, 5841, 7764, 9154 ]
From Oregon.—Sacramento Transcript 20 December 1850 — California... http://cdnc.ucr.edu/cgi-bin/cdnc?a=d&d=ST18501220.2.6&srpos=83&dl=st18501220.2.6 Sacramento Transcript, Volume 2, Number 49, 20 December 1850 — From Oregon. [ARTICLE] From Oregon. The Oregonian.—There lies before us a copy of the first number of "The Oregonian." It is published weekly, in Portland, Oregon Territory, and is edited by T. J. Dryer, Esq., formerly city editor of the San Francisco Courier. It comes out under the Whig Banner. In an article explanatory of the cause of the late appearance of the sheet, friend Dryer comes down in pretty severe terms upon one Capt. Hall, an owner of the Keoka. If Mr. Dryer's statement is not colored, we are glad to see such men as Capt. Hall "put through." The Gold Hunter pushed up the Columbia and reached Portland on the 1st inst. The people of Oregon are endeavoring to build a railroad to join Lafayette in Yam Hill county with Portland. Articles of association have been drawn up contemplating a capital of $500,000. A meeting has been held in Lafayette, and $280,000 worth of stock taken up. Afterwards Mr. W. W. Chapman, who is getting up the project, called on several farmers upon the proposed route, who subscribed liberally. So that now there are nearly $400,000 worth of stock already taken. Oregon is in this respect ahead of California. The Legislative Assembly of Oregon organized on the 2nd inst., and upon calling the roll, the following members appeared and took their seats: and took their seats; From Clackmas—Messrs. Simpson and Matlock. Marion—Harding, Shaw, Parker. Benton—Avery. Polk—Holmes. Washington—Wilcox, King. Yam Hill—Payne, Gilmore. Members absent—Messrs. Deady, Dowers, St. Clair, Campbell, Allphin, Walters, Tharp. The next morning the Assembly met and appointed the following officers: Speaker of the House, Dr. Kalph Wilcox; Clerk, Asahel Bush; Assistant Clerk, B. Genois; Sergeant-at-arms, Wm. Holmes; Doorkeeper, Septimus Huelat. For the Council, the following officers were elected: Chairman, W. W. Buck; First Clerk, G. L. Curry; Assistant Clerk, James D. Turner; Sergeant-at-Arms, Heman Buck; Doorkeeper not elected. The two Houses having completed their organization, the Governor was duly informed of their readiness to hear any suggestions he might have to make. At half past two o'clock, the Governor appeared and read his passage to the two Houses, in joint assembly. He recommended the immediate organization of the militia, and the opening of roads. He says, "to connect Puget's Sound with the Columbia River, some point on the Willamette with the mouth of Columbia, and the Willamette valley with that of the Umpqua, are among those I would name for the present." He calls the attention of the Legislature to the subject of education; and recommends that a permanent seat of government be decided upon; also the erection of public buildings. He calls also upon the public buildings. He calls also upon the citizens to furnish a block for the Washington Monument. The above is about all of interest that we can glean from the Oregonian. --- The Indians of Oregon.—In his late message to the Legislature, Gov. Gaines remarks as follows: "On the part of the Legislature, the adoption from time to time, of such measures as lie within its province, calculated to further the objects of justice and humanity towards this fading race, should in like manner be kept in view. Among those which appear to me to promote advantageous results, is the passage of an act authorizing the apprenticing of Indian children to useful trades and occupations, where the consent of the parents can be obtained, and under proper safe-guards for their good treatment and education. It is probable, at least in the beginning, their own prejudices will oppose an obstacle to the plan, but with judgment in managing the system, valuable results may possibly be obtained. The natural tractability of the tribes in this portion of Oregon, their habits of fixed residence, and great unwillingness to leave their old grounds, the ingenuity displayed by them in many articles of manufacture, indicate the direction in which they should be instructed, not only as farmers, but as carpenters, smiths, and other mechanical pursuits, they might be made useful to the community, as well as to themselves. Should the experiment be deemed worthy a trial, (and as such only I suggest,) provision should be carefully made in it, for the protection of the apprentice in his rights, and authority given to the agents of Government to enforce the fulfilment on the contract on the part of the employer." --- Impudence.—We admire downright impudence; we "cotton" to it. Hitherto we were not aware to what a sublimity it might be carried. We have received some new light, however, on the subject, and are now convinced that for perfect effrontery and shamelessness, the members of our City Council have reached the ultimate. They Council have reached the ultima thule. That they were capable of wonderful achievements no one doubted; but that they had the cheek to get up for themselves gold medals, "Presented by the Citizens of San Francisco," was something our imagination fell far short of. They'll do. Henceforth we award to them "our hat" in any thing they may achieve.—[Alta. --- The World's Cold Charity.—Last night about nine o'clock, officer De Wolf found a little boy about seven years of age, wandering near Portsmouth square. The little fellow was wet and hungry, and was taken to the station house. His story was, that his name was Alexander Dushane—that his mother was at the mines, and that his father had died the night previous at the hospital; that as soon as this was known, he was turned out from the "St. Charles," where he had been staying, to shift for himself. What St. Charles he meant we were unable to learn.—[Pacific News. --- List of Deaths in San Francisco, Dec. 17th.—Mr. Duchine, New Orleans, 47, cholera; Joseph Rollins, Alexandria, 30, cholera; A. H. Tuplett, Missouri, 28; John Crook, Maine, 29; R. B. Fresburn, Jr., 2 years and 6 months, convulsions. --- New Invention in Shipping.—A new invention by a Mr. Jordan of Liverpool, by which he proposes to substitute iron for the wooden framing of vessels is attracting a good deal of attention in that town. The inventor has taken out an American patent. M. Lagrange, an apothecary at Paris, has invented a new and most destructive kind of bullet, which, on striking any object against which it may be directed, explodes with a detonation as loud as that of the gun from which it is fired, and produces a most destructive effect.	<urn:uuid:eba046a7-2b9e-407b-8b16-041f9bcd3c91>	CC-MAIN-2018-47	http://calindianhistory.org/wp-content/uploads/2017/04/12_20_1850_Oregon_Gov_Indians_SacTranscript.pdf	2018-11-20T15:59:56Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-47/segments/1542039746465.88/warc/CC-MAIN-20181120150950-20181120172950-00092.warc.gz	49,240,636	1,539	eng_Latn	eng_Latn	0.997453	eng_Latn	0.998097	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	true	docling	[ 1518, 2949, 4983, 6689 ]
Credit Rating Announcement Ref: KW08111PRS01-2 10 January 2013 Alargan International Real Estate Company's Bond Rating Affirmed at 'BBB-' Capital Intelligence (CI), the international credit rating agency, today announced that it has affirmed the 'BBB-' Long-Term Rating of the KWD26.5mn five-year bond issued by Alargan International Real Estate Company (ARE) in April 2012. The Outlook on the Rating is 'Stable'. The Rating is supported by the sound financial profile, the geographically diversified business model, and the improving profitability. Also supporting the Rating is the improved funding structure and the diminishing reliance on short-term borrowing, which has in turn improved liquidity. The main constraints on the Rating are the size of the company in balance sheet terms, and the sector in which it operates. An improvement in the Rating continues to be unlikely in the short- to-medium term. The fact that secured borrowings still remain after the issue of the bond amounts to an element of structural subordination. However, the amount of such borrowing is not considered large enough to impact the Rating. With the exception of this factor, Alargan has a solid balance sheet with satisfactory financial ratios that are forecast to remain so during the life span of the bond. While Alargan is a small company in purely balance sheet terms, this reflects to a certain extent the corporate structure used for development projects, whereby most are held off-balance sheet through SPVs with their own non-recourse (to Alargan) financing arrangements. While any real estate development business involves risk, Alargan seeks to reduce this risk through development partnerships, through the financial and funding structures that are selected, and through the sale of developments while they are still in the construction phase. Nonetheless, risks remain. Alargan seeks to further mitigate these by keeping the exposure to any single project or financing vehicle as low as possible and by reducing activities in those markets where prospects are perceived as constrained. Alargan International Real Estate Company K.S.C (Alargan) was established in March 2002, but the origins of the group date back to 1994. The Company was listed on the Kuwait Stock Exchange in July 2007. Alargan is principally a developer of affordable housing in selected GCC markets, in particular KSA and Oman. However, the Group has also developed commercial space (often as part of a larger and mainly residential project), as well as developments in the office and hospitality segments. CONTACT Primary Analyst Senior Credit Analyst Rory Keelan Tel: +357 2534 2300 E-mail: [email protected] Secondary Analyst Senior Credit Analyst Darren Stubing E-mail: [email protected] Rating Committee Chairman Senior Credit Analyst Morris Helal The information sources used to prepare the credit ratings are the rated entity and public information. Capital Intelligence had access to the accounts and other relevant internal documents of the issuer for the purpose of the rating and considers the quality of information available on the issuer to be satisfactory for the purposes of assigning and maintaining credit ratings. Capital Intelligence does not audit or independently verify information received during the rating process. The rating has been disclosed to the rated entity and released with no amendment following that disclosure. Ratings on the issuer were first released in October 2011. The ratings were last updated in October 2011. The principal methodology used in determining the ratings is Bond Rating Methodology. The methodology and the meaning of each rating category and definition of default, as well as information on the attributes and limitations of CI's ratings, can be found at www.ciratings.com.	<urn:uuid:8694ffda-698e-45cf-9a07-191bca7aa83d>	CC-MAIN-2018-47	http://alargan.com/media/b83d36a8-02c3-4176-9837-5ce9e4b38d8b/NaD4VQ/CreditRatingAnnouncement2012.pdf	2018-11-19T15:52:54Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-47/segments/1542039745800.94/warc/CC-MAIN-20181119150816-20181119172816-00322.warc.gz	14,337,756	756	eng_Latn	eng_Latn	0.994257	eng_Latn	0.994158	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 3350, 3844 ]
What are we learning about today? Persevere! Don’t ever give up doing good! Scriptures for the day: Romans 12:1, Galatians 6:9-10, Isaiah 41:10 What is the car of the day? See if you can guess and then flip the page to find out! 1. The first company to make this type of vehicle was founded in 1900 by the Mack brothers in North Carolina. 2. This vehicle has been sold in 45 countries across the world. 3. During WWII 35,000 of these vehicles were made for the US Military. 4. Parts of these vehicles are produced in Salem, Virginia. 5. Some of the types of this vehicle are made for firefighters, bus drivers, the military, construction workers, refuse workers, and so many more! 6. This vehicle can haul up to 20,000 pounds of weight per axle that it has. Any Guesses? Car of the Day: The Mack Truck! Check out the cool facts and website below! Interested in learning more about the Mack Truck? Check out their website! Macktrucks.com On this site you can scroll to the bottom of the home page and explore the 6 different trucks they are building now! Finished with one truck? Hit the MACK symbol in the top left hand corner and scroll down to pick a new truck to read about! CAR OF THE DAY! – The Mack Truck Instructions: Color in the Mack Truck below making your own logo for the side of the truck. Memory Verse: We have been studying this memory verse all month! If you have it memorized, ask a parent to record you saying it and send it to Mrs. Liv or the Church Office! You will get an extra Life Buck when Kids Church reopens if completed by 3/29/2020! "Therefore, I urge you, brothers and sisters, in view of God’s mercy, to offer your bodies as a living sacrifice, holy and pleasing to God—this is your true and proper worship." - Romans 12:1 (NIV) Memory Verse Activity to help! Write the memory verse on a piece of paper in pencil. They read the verse aloud. After you read it, erase a random word from the paper and read it aloud again including the word you erased. Continue doing this until the entire verse is erased from the paper and you can say it! Bible Time! Today we are studying the Mack Truck. The Mack Truck is also known sometimes as an 18 Wheeler, Semi-Truck, and a Tractor Trailer. No matter what you call it, this truck is very impressive. It is a massive truck that can haul thousands of pounds of supplies to people all over the world. The Mack Truck is not built for speed, but rather endurance. Both the truck and its driver can drive on the open road for hours without needing a break. The truck drivers are very committed to get you what you need in a timely matter and never give up getting it to you. They sometimes have to drive very safely through scary, dangerous situations like wind, snow, and rain. Whether the road is boring, scary, or just pleasurable, the Mack Truck and the truck drivers always do their best to persevere and get supplies to those who need it. Today we are going to talk about how we can be like the Mack Truck and preserve through what we are going through and always choose to do good. Take some time to read our two scriptures for the week below: Galatians 6:9-10 “And let us not grow weary while doing good, for at the proper time we will reap a harvest if we do not give up. Therefore, as we have opportunity, let us do good to all people, especially to those who belong to the family of believers.” Isaiah 41:10 “So do not be afraid. I am with you. Do not be terrified. I am your God. I will make you strong and help you. I will hold you safe in my hands. I will always do what is right.” Paul the Apostle wrote the first verse in a letter to the Church of Galatia. Paul was a great example of what it means to keep moving forward for God no matter what happens. Take some time to make a list of all the times you can remember that Paul did not grow weary and kept telling others about God. One story that we can look at is the last story of Paul’s life. When Paul was very old, he was arrested for preaching about Jesus and sent to house arrest in Rome. While under house arrest, Paul continued to not only write letters to the churches in his care to encourage them to spread the gospel, he even preached to the crowds from the doorstep of where he was and people came to know Jesus. In a scary (facing jail and punishment), tiring (being very old when he was in Rome), and uncertain (not being sure what was going to happen next) time, Paul never stopped doing the right thing. He always chose to do good for the Lord. Paul knew that God was with him and he didn’t need to worry about what was happening around him because God gave him strength like our passage in Isaiah also lets us know about God’s character. So what does this mean for you? Perseverance is a word that means you choose to never give up! When we persevere, we shake off fear and the things not of God in our lives, trust the Lord completely, and choose to do good. Sometimes doing good can become tiresome and not wanted, or people or items might also scare us and try to stop us from being good. In those times, we need to be like the Mack Truck, and keep doing good, trusting that God is with us and will provide. The world needs God’s love; let’s go and deliver it! Challenges this Week: Instructions: Each week we will have a chart for our challenge of the week. Each day you complete the challenge, put a check or sticker in a box on the chart next to that challenge. At the end of the week, no matter how many stickers you have, have a parent take a picture of your chart and send it to Mrs. Liv. Upon submission, you will receive an extra Life Buck when Kids Church reopens for the store! The Challenge: 1. List 3 things you can do this week that are good! Think about something that can help your parents, siblings, a neighbor, etc. and write it in the chart under “Challenge.” Each day you do the challenge, put a check/sticker in the appropriate box. (Mrs. Liv has given an example. Feel free to use that as one of yours as well). 2. List one way you can persevere if you face something that makes you want to quit doing your challenges. Put a sticker or a check next to each day that you overcame and persevered! My Challenge Chart: Perseverance Name: ____________________________ \| Challenge \| Sun \| Mon \| Tues \| Wed \| Thurs \| Fri \| Sat \| \|-----------\|-----\|-----\|------\|-----\|-------\|-----\|-----\| \| Example: I will clean the playroom everyday without complaining! \| √ \| √ \| \| √ \| \| √ \| √ \| \| 1. \| \| \| \| \| \| \| \| \| 2. \| \| \| \| \| \| \| \| \| 3. \| \| \| \| \| \| \| \| How I will persevere? \| How I will persevere? \| Sun \| Mon \| Tues \| Wed \| Thurs \| Fri \| Sat \| \|-----------------------\|-----\|-----\|------\|-----\|-------\|-----\|-----\| \| Example: I will pray when I am feeling overwhelmed and try again. \| √ \| √ \| √ \| √ \| \| √ \| √ \| \| 1. \| \| \| \| \| \| \| \| Extra: Fun Activities to try this week! Science Experiment: This week we are talking about the Mack Truck. A Mack Truck is also sometimes called an 18 Wheeler. This week you will test how different items roll. 1. Find 18 “roll-able” items around your house. Make sure you have parental permission to use your objects. Also make sure you choose objects that are not breakable like a toy car, a lego wheel, coins, a ball, a marble, a paper plate, etc. 2. Choose a long table that is safe to use where things that fall off of it will not break or trip people as they walk by. Make sure the table is clean! 3. Place a bucket on one end of the table and stand on the opposite side of the table. 4. Take turns rolling each object down the table to see how many of your 18 “wheels” (objects) land in the bucket. 5. Have a sibling? Each of you pick different objects and try your objects to see who gets the most in the bucket! Then try again! Discuss why you think some objects were easier to roll than others? Why were some objects able to stay straight on the table and fall in the bucket but others weren’t? Did the objects that were in the bucket have more or less surface area that touched the table during the roll? Where they bigger or smaller? Have fun evaluating your experiment! Contest of Endurance: Have a contest with a sibling, parent, etc. of “Who can go the longest?” Some different ideas are below, but feel free to create some of your own! 1. Push Ups 2. Jumping Jacks 3. Sit Ups 4. Hula Hooping 5. Jump Roping 6. Standing on one foot 7. Being quiet 8. Reading a book Craft Idea: Supplies: black and white construction paper, scissors, glue, writing utensils (crayons, markers, pencil, pens, chalk, etc.) Instructions: 1. Cut out a big circle from the black construction paper. 2. Cut a smaller circle from the white construction paper. 3. On the white construction paper circle decorate your hubcap as you would like. Include on your hubcap a reminder about never giving up! 4. Glue your white construction paper hubcap in the middle of your black construction paper circle to create a wheel. Coloring: Grab your crayons and take some time coloring our verses of the day and a picture of Paul as you remember our Bible Time together. Paul Helps People Follow Jesus Let us not become weary in doing good for in due time we will reap a harvest if we do not give up. Goldiansen © Adron Coloringpagesbymradron.blogspot.com So do not be afraid. I am with you. Do not be terrified. I am your God. I will make you strong and help you. I will hold you safe in my hands. 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Helen Gwinn considers herself a native New Mexican although she was born in Texas. She attended public schools & graduated from high school in Carlsbad. During her college years & early adulthood, she lived in various places in Texas, returning to New Mexico in 1978. Helen's art, expressed in watercolor, embossing & collage, reflect her life, including her love for the flora of the desert where she lives. For example, her "Rock Concert Series" created mainly in watercolor, contains images ranging from nearly white boulders in the desert to colorful river rocks punctuated by wildflowers & cactus. To her, cactus plants represent survival & exquisite beauty in harsh environments. "I have favorite cacti," she says, "which I have watched & have been inspired by the seasons of their lives & mine. I consider them old friends." For Helen, art & the daily routines of living are integral parts of a whole. Since her first child left home for college, one of the routines of her life has been letter writing. A whole series of art pieces, 70 to date, has developed along with this meaningful aspect of communicating.	<urn:uuid:4e3e50bf-da93-4ce0-aadf-53734bbd194e>	CC-MAIN-2018-17	http://weemsgallery.com/Gwinn%20Bio.pdf	2018-04-21T19:27:19Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-17/segments/1524125945317.36/warc/CC-MAIN-20180421184116-20180421204116-00620.warc.gz	349,736,394	240	eng_Latn	eng_Latn	0.999103	eng_Latn	0.999103	[ "eng_Latn" ]	false	docling	[ 1120 ]
Application for Senior Citizen Sewer Service Charge Exemption Account Number: _____________ Customer Code Premise Code Premises Address: Owner Name: (as currently listed on bill) Last First Phone Number: Email Address: Owner Birth date: Property Index Number: - - - - (Found on Property Tax Bill) To be eligible for the sewer service charge exemption you must meet the following criteria: * You must be 65 years of age or older * Occupy the property as your principal place of residence * Residence must be a single family home or have a separate metered water service or water assessment for a residence that is not a single family home * The account must be in good standing. The account cannot be delinquent. You must provide the following documentation with your application: 1. Proof of age – copy of Driver’s License or State ID 2. Proof of ownership – copy of deed or property tax bill 3. Proof of residency- copy of utility bill The undersigned on oath deposes and says that he/she is the owner of said real property, said property is a single family dwelling or has a separate metered water service or water assessment for a residence that is not a single family home, that this is his/her principal place of residence, is 65 years of age or older and otherwise qualifies for exemption under Section 3-12-050 of the Municipal Code of the City of Chicago, and that he/she is subject to penalties for perjury for falsification herein. Print Name: Signature: Date: Approved Disapproved By: _ Date: Reason: *Required Field Persons age 65 and over who reside in their own residence but do not qualify for an exemption as explained above because their residence is a townhouse, condominium unit or cooperative apartment that does not have separate metered water service or a separate City water assessment for the residential unit may apply for a refund in lieu of the exemption provided in 3-12-050(a) of the Municipal Code of Chicago. The amount of the refund shall be $50.00 per qualified residence for each calendar year. Application for a refund in lieu of exemption shall be made to the alderman of the ward in which the applicant resides no later than August 1 st of the calendar year for which a refund is requested.	<urn:uuid:eff0d0ee-5280-417d-8c03-a0bb1f03d749>	CC-MAIN-2019-39	https://4310b1a9-a-9cce744d-s-sites.googlegroups.com/a/aldermanervin.com/home/forms/SeniorWaterSewerExemptApp.pdf?attachauth=ANoY7cpwgR4BvO0fQjXYhjuVESbNGlvXJOkQ_I0RzikeISzQ3lNZqmeBwlTPEVkBoY1ZoI-JO9p4PFe3OcnrzhKCOCx9GRXcjxGsC4ExoMCiufnMff28vwsee5wVuH0KmEXTjgEHLK3hLC_dybsRHwVabQV3sn-OSbauuRwLrQIkscjeXFsLMcJhEUmWbYSEli79sZgEQI94qL6yW1K2rXCHHc-4xEn_SVjmklQm-rMc5SA2QXZCm58%3D&attredirects=0&d=1	2019-09-16T06:47:10Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-39/segments/1568514572491.38/warc/CC-MAIN-20190916060046-20190916082046-00043.warc.gz	375,399,040	486	eng_Latn	eng_Latn	0.992673	eng_Latn	0.992673	[ "eng_Latn" ]	false	rolmOCR	[ 2277 ]
Collection Development Policy Nashville Public Library Departmental Policies Policy Information Approved Date: Effective Date: Keywords: September 21, 2021 January 20, 1998 Selection, Scope, Collection, Management, Acquisition, Weed, Development, Donation, Maintenance Policy Purpose of Collection Development Policy The collection development policy is intended to provide guidance, within budgetary and space limitations, for the selection and evaluation of materials which anticipate and meet the needs and interests of the Nashville community. It directly relates the collection to the Library's mission statement and defines the scop and standards of the various collections. As the community changes, Nashville Public Library (NPL) reassess and adapts its collections to reflect new and differing areas of interest and concern. The collection development policy is periodically evaluated and revised as necessary to provide guidance for implementing changes in the collection. NPL Mission, Vision, and Values Mission: Inspire reading, advance learning and connect our community. Vision: All members of our diverse community are empowered through limitless learning opportunities to enrich their lives. We Value: * Extraordinary Customer Service * Love of Reading * Lifelong Learning * Intellectual Freedom * Innovation * Excellence * Inclusiveness Philosophy of Selection In support of its mission "to inspire reading, advance learning and connect our community," NPL fully endorses the principles documented in the Library Bill of Rights and the Freedom to Read Statement of the American Library Association. The Library upholds the right of the individual to secure information, even though the content may be controversial, unorthodox, or unacceptable to others. A balanced collection attempts to represent all sides of controversial issues as far as availability of materials, space, and budget allow. Selection is based upon criteria stated in this policy. Materials available in the Library present a diversity of viewpoints, enabling citizens to make the informed choices necessary in a democracy. All public libraries contain materials that some patrons may find objectionable. Libraries may omit from the collection materials that some patrons feel are important. In either case, the library has procedures that patrons may use in reconsidering or recommending library materials. Scope of the Collection The primary responsibility of Nashville Public Library is to serve the citizens of Davidson County by providing a broad choice of materials to meet their informational, educational, cultural and recreational needs. Materials are selected to aid individuals, groups and organizations in the effort to attain practical solutions to daily problems, and to enrich the quality of life for all community members. Budget and space limitations, as well as local needs, preclude the Library from duplicating the specialized and comprehensive collections that exist elsewhere in Davidson County. Access to these collections is provided through cooperative networking, interlibrary loan, and direct referral. All outlets of the Nashville Public Library system are designed to provide access on an equal basis to the collections of both the Nashville Public Library and the Metro Nashville Public School system. Emphasis is placed on shared access and ease of use through the online catalog and the Limitless Libraries program of school delivery. Scope of the Main Library The Main Library serves the Davidson County community as a whole, in addition to serving as a resource for the twenty branch libraries. The size and scope of its collection attracts users from surrounding areas as well as the rest of the state, but the main purpose is to serve Nashville citizens and employees. As an urban library, the Main Library places major emphasis on the provision of information. It offers a strong reference collection that supports an extensive and in-depth reference service. A broad choice of circulating print and non-print materials is selected to accommodate the diversity of tastes, reading levels, languages and interests of users of all ages. The Main Library aims at providing a comprehensive collection of materials relating to the Civil Rights Movement, Nashville history, Genealogy, and local author collections. The Main Library also builds upon existing strengths in the arts. Scholarly and highly technical or specialized materials are not acquired but are made available through other libraries with strong collections, through our Interlibrary Loan department. Scope of the Branch Libraries The twenty branch libraries serve specific neighborhoods in the City. The interests and needs of the actual and potential users of the branch are continually evaluated so that each library has a collection reflecting the community that it serves. While each branch serves basic reference needs of its neighborhood with a core of reference materials, it does not duplicate the in-depth sources or special collections of the Main and other area libraries. Branch collections are designed to serve the current, high interest needs of library patrons. Responsibility for Selection The authority and responsibility for the selection of library materials rests ultimately with the Library Director. Under his/her direction, selection is delegated to professional collection development library staff. These decisions are made within the limitations of available space and funding, and within the scope of a written collection development plan. Materials will be selected based upon their value as a whole. Selection presumes liberty of thought and intellectual freedom within the bounds of reason and law. The general public and all library staff are encouraged to recommend materials for consideration. Nashville Public Library's collection is developed through: * Engaging in open, continuous two-way communication with library users and recognizing that individuals have different ways of expressing their needs based on age, language, economic status, culture, or other characteristics. * Interacting with customers with understanding, respect, and responsiveness. * Handling all requests equitably. * Understanding and responding to rapidly changing demographics, as well as societal and technological changes. * Recognizing that materials of varying complexities and formats are necessary to satisfy diverse needs of library users. * Balancing individual needs and broader community needs in determining the best allocation of collection budget for acquiring or providing access to materials and information. * Seeking continuous improvement through ongoing data analysis and measurement. * Reviewing the collection on a regular basis to identify areas of community interest that may need to be strengthened. Selection Criteria All materials, whether purchased or donated, are considered in terms of the criteria listed below. Materials are evaluated according to one or more of the following standards. An item need not meet all of these standards in order to be added to the collection. General Criteria * Contribution to the diversity and scope of the collection * Suitability of subject and style for intended audience * Requests by library users * Effectiveness and suitability of format in communicating the content * Relevance of format and content to the intended audience * Impact on materials expenditure plan * Popular appeal * Available space * Attention by critics and reviewers * Contemporary significance * Relevance to the needs and interests of the public * Accessibility of material * Physical Format * Quality of production Content Criteria * Authority * Objectivity * Clarity * Currency * Representation of diverse points of view * Receipt or nomination for awards * Reputation or significance of one of the creators of the work * Published evaluations or reviews * Accuracy and timeliness * Consideration of the work as a whole * Sustained interest * Relevance and use of the information * Effective characterization * Authenticity of history or social setting New or Emerging Formats NPL develops collections that include a comprehensive range of formats utilizing the unique capabilities and advantages of alternative, new and evolving technologies in delivering information and expressing creativity and ideas. Before adding new formats, the following criteria should be considered: * Impact on equipment, staff, storage, and space * Demand for format in community * Durability of format for library use * Technical quality of production or reproduction * Compliance with industry standards and specifications * Availability of adequate startup and continuing funding * Capability for networked distribution, download and printing * Suitability to be circulated or housed in a sturdy, safe and convenient manner * Availability of technical support and staff training * Accessibility of material * Ease of use by customers and staff * Ownership of product As new formats emerge, steps will be taken to phase-out duplicated, obsolete mediums. These include discontinuation of ordering new or replacement copies, redistribution, and removal of existing collection from within the system. The time frame and need for implementation of each of these steps will vary based on customer demand for product (as demonstrated by circulation statistics and customer requests), affordability, and availability of product from vendors. Independently Published Material Nashville Public Library is often asked to include items in our libraries that are written and/or published independently. This can include materials that are self-published/produced or items published through a vanity press company. NPL looks for material with regional connections and collection relevance that will appeal to a wide audience. The best way to bring an item to the Library's attention is through reviews. Review sources that specialize in independently published material include the following: * Foreword * Small Press Review * Independent Publisher A positive review in one or more of the library review journals, such as Library Journal, School Library Journal, Kirkus Reviews, Booklist, Publisher's Weekly or in the Sunday edition of the local daily paper will give an independently published book an improved chance for selection by Nashville Public Library. Information regarding the material should be sent to the NPL's Collection Development Department. The following information should be included: * A brief summary of the material * Any professional reviews * Intended audience * Author background and contact information * Publisher information * Item description (price, ISBN, date of publication) * Distributor(s) * OCLC World Cat Record Preview copies will be treated as a donation and their disposition will be covered under our Gifts and Donations Policy. Suggestions for Purchase Nashville Public Library strongly encourages input from the community concerning the collection. A suggestion for purchase procedure enables Nashville citizens to request that a particular item or subject be purchased. All suggestions for purchase are subject to the same selection criteria as other materials and are not automatically added to the collection. It is the Library's intent that suggestions for purchase be used to help NPL in developing collections which serve the interests and needs of the community. You can make a material suggestion online. Gifts and Donations NPL welcomes gifts of books and other materials. The Library reserves the right to keep, discard, sell, or make other appropriate disposal of any books or materials that are donated as determined by its mission and needs. Staff members review all donated materials for potential addition to the Library's collections. Materials may also be used to help the Friends of the Library hold successful book sales. Funds raised at these sales support the Children's Summer Reading Program and other valuable library programs. Donated material that will be sold at Friends' book sales is not covered under this policy. Friends' donation instructions are located on the NPL's website under Friends of the Library. Nashville Public Library accepts gifts at any of our facilities in Davidson County. Customers are encouraged to call ahead. Books donated in boxes are most helpful. Metro Archives and Special Collections staff follow separate guidelines for accepting donations. What will be considered for addition to the collection: * Material in like-new condition * Books * DVDs * Board Games What is not accepted for the collection: * Material in poor condition (has stains, water damage, smell, writing, etc.) * Formats not currently being collected by the Library, such as VHS, audio cassettes, LPs, etc. * Textbooks (except current Metro school textbooks) * Magazines & Newspapers as well as magazine gift subscription Requests for Reconsideration Any Davidson County resident has the right to express concerns about library resources and expect to have the objection taken seriously. Persons wishing to recommend the removal or reclassification of a particular item in the NPL collection are encouraged to discuss their concerns with a library manager. If the patron is not satisfied with the response to their request, the manager will provide the patron with information and a form to request formal reconsideration of the library resource. The request will be reviewed by the Library Director and staff, bearing in mind the Library's mission statement, philosophy and the selection criteria of this collection development policy. A questioned item will be considered in its entirety, not judged solely on portions taken out of context. Questioned items will remain in circulation during the reconsideration process. After evaluating journal reviews and other materials submitted by the patron and the staff, the Library Director, or the Collection Development Manager as his designee, will respond within 30 days of receiving the formal request. Collection Maintenance In addition to acquiring new materials, it is important to remove from the existing collection those items no longer deemed useful or relevant. This policy provides authority for the systematic and regular evaluation of the existing collection and subsequent withdrawal of worn, obsolete or infrequently used materials and supports the public's right of access to an appealing and relevant collection. Library Management Staff systematically review the collection with the goal of maintaining the quality and vitality of library resources. This process of collection analysis incorporates the use of output measures, circulation reports, and other statistical information for continuous collection evaluation. Weeding Evaluation Criteria Weeding in this context is defined as the process of evaluating a book to determine if it will be retained, relocated, or replaced. Selection of materials for discarding is based on the CREW method. * Continuous * Review * Evaluation * Weeding This system uses the acronym, MUSTIE, to help evaluate an item for withdrawal: * Misleading and/or factually inaccurate * Ugly (worn out beyond mending or rebinding) * Superseded by a new edition or a better source * Trivial (of no discernible literary or scientific merit) * Irrelevant to the needs and interest of your community * Elsewhere (the material may be easily borrowed from another source) Replacement Criteria While NPL attempts to have copies of standard and important works, it does not automatically replace all materials withdrawn. The same criteria that apply to original selection also apply to replacements. The need for replacement is based on: * The number of duplicate copies * Existence of adequate coverage of the subject in the collection * Demand for the specific title or subject area * Availability of material Removal of Withdrawn Material Materials that no longer meet the stated objectives of the Library will be withdrawn from the system. This board approved policy, allows NPL to determine how materials are removed and where they are sent after removal from the library's catalog. Duplication of Material Multiple copies of materials are purchased in response to user demand as evidenced by number of reserves, anticipated popularity, repeated requests and monitoring of the collection. For popular fiction and non-fiction titles, NPL maintains a holds ratio (i.e. for every 5 holds on a title, another copy is purchased) as allowed by budget constraints. Main Library Collections Albert Hadley Interior Design Collection Albert Hadley (1920-2012), a native of Nashville, was a renowned interior designer whose clients included Vice President Albert Gore and Tipper Gore, Jacqueline Kennedy Onassis, Diane Sawyer, and the Astor and Getty families. The Albert Hadley Interior Design Collection includes over 700 titles from his personal and professional book collection, as well as sketches and ephemera. Annex Collections The Annex of Nashville Public Library, housed near the delivery area of the Main Library, is an active, constantly maintained print and audio-visual collection with several functions. These include, but are not limited to, the following: * High demand fiction and nonfiction titles from which holds are pulled first in order to quickly deliver material to customers and lessen their wait time for material. * Preservation of certain historical and award-winning collections not in general circulation. Board Game Collection A circulating collection of board, card and tabletop games, housed in our Popular Materials division. Bookclub-In-A-Bag Collection To assist and promote book clubs, Nashville Public Library has created a collection of readyto-go book club kits. These kits contain ten copies of a book title, discussion questions for the book, an author biography, tips for starting a successful book club and circulation rules for using the kit. They are packaged in a canvas tote bag for easy conveyance. The book bags contain titles of interest to children, young adults and adults and are available in several genres: Southern fiction, Sci-Fi, Romance, African American fiction, Mysteries, Contemporary Christian fiction - a little something for everyone. The bags are not renewable but have an extended loan period of six weeks to allow time for groups to distribute, read, discuss and return the books. Children's Historical Collection The Children's Historical Collection are items of historical or local significance to children's literature, including first editions and award-winning books, that are determined to be unique and/or out of print. These items are housed in the Annex and are non-circulating but can be requested at the Children's Reference Desk and used in the library. C.I.E.C. Collection The Children's International Education Collection is a circulating collection of books that is housed in the Children's Department of the Main Library and consists of items that reflect the culture, customs, and beliefs of the country from which they came. Items are added to the collection based on their cultural relevance to the country they represent, with particular emphasis placed on items published in the native language(s) of the county or bilingual material. The circulation procedures for these items are the same as other circulating materials. Curriculum Kits Curriculum Kits are collections of 20-30 items on one topic. The Kits are located in the Main Annex division, and are housed in sturdy, covered plastic bins. Each Kit is geared at either elementary, middle or high school students with materials chosen that correspond to curriculum. Each Kit may include a mix of print books, videos, audiobook CDs, preloaded MP3 audiobooks, flashcards, maps or laminated sheets. The Kits are not renewable but have an extended loan period of four weeks. They are searchable through the online catalog and may be placed on hold. Foundation Center Collection In partnership with the Foundation Center, the Main Library makes available The Foundation Directory Online and Foundation Grants to Individuals Online. These resources, as well as others available through the Foundation Center Collection, provide directories and profiles of organizations which provide grants as well as information on grant seeking and grant writing. Government Archives of Metropolitan Nashville and Davidson County (see attached Collection Development Policy for a detailed description) Government Documents The Library system provides a variety of items published by Federal and some local governmental agencies. The Main Library is a selective depository of the United States Government publications and is subject to the regulations governing Federal depository libraries. Historical Audio-Visual Collection (see attached Audio-Visual Division Collection and Conservation Policy for a detailed description) Library Services for the Deaf and Hard of Hearing This lending library of books, media programs, and assistive communication devices is one of the largest in a public library in the country. It includes materials to educate the hearing public about hearing loss and deafness as well as accessible informational and entertaining materials for people who are deaf or hard of hearing. Materials about deaf-blindness are also available. Library Studies Collection The Library Studies Collection at the Main Library houses circulating materials to support study for staff, educators and students. The collection includes resources on all aspects of library and information science, including but not limited to: collection development, management and supervision, database management, branch management, school library studies, curriculum content, marketing, programming, outreach and fundraising. Small Business Collection This reference collection contains sample business plans and other resources for starting up a small business. Special Collections Division As the information center for the Nashville community, the library places a high priority on acquiring comprehensive information and resources about Nashville, past and present. The Special Collections Division collects reference and non-circulating materials which reflect the county's historical and cultural development, with special attention to its ethnic diversity and heritage. The collection of historical Nashville newspapers on microfilm at the Main Library is one of the most comprehensive available in Davidson County, and is supported by research and historical materials. The Special Collections Division acquires exhaustive and selective material that furthers the mission to preserve and share across generations the culture and history of Nashville. It also collects maps, pamphlets, manuscripts, and selected ephemera of local significance. Non-print materials include videos, sound recordings, oral histories, and photographs. The Nashville Public Library does not actively seek manuscripts, collections of papers, memorabilia, or three-dimensional materials, although it does selectively accept gifts of this nature, particularly when the material relates to the City of Nashville. Special Collections Division book collections include: Banner & Stahlman Collection These two book collections are from the Nashville Banner newspaper and also includes selected titles from the James G. Stahlman personal book collection. Genealogy Collection This collection includes published family histories, family name origins, early passenger lists, coats of arms, research material for the genealogist and how-to books related to the same subject. The published family histories and records included in this collection are nonTennessee, primarily relating to the areas from which Tennesseans came prior to settling in Tennessee, including Kentucky North Carolina, South Carolina, Virginia, and Great Britain. Grantham Collection The Grantham Collection consists of 5,000 titles, including a number of his personal publications, from Dr. Dewey Grantham, History Professor Emeritus at Vanderbilt University. Dr. Grantham's collection includes the social, cultural, economic, and political history of the post-Civil War South. Civil Rights Collection This monograph collection with a focus on the Civil Rights Movement in Nashville, Middle Tennessee, and the South is located in the Civil Rights Room. It is funded by the Robin and Bill King Foundation. Muirhead Collection This collection was donated by Judge Jean Muirhead and includes material related to women's civil rights and women's issues. Nashville Authors The Nashville Authors Collection is composed of both fiction and nonfiction titles not concerning Tennessee subjects authored by Nashville residents. Nashville authors who write fiction or non-fiction about Tennessee subjects will have their books housed in the appropriate Tennesseana section within Special Collections. Some of these titles may also be available elsewhere in the library system as part of the circulating collection. Tennesseana This is the largest of our monograph collections and includes Tennessee, Middle Tennessee, Davidson County and Nashville local history; Nashville City Directories; biographies about Tennesseans; and selected fiction set in Nashville or Middle Tennessee. Significant portions of the Tennesseana collection include published family histories about Tennessee families; published county records and other resource for Tennessee genealogical research; and local county and city histories for areas in Middle Tennessee. Votes for Women The Votes for Women Collection focuses on Nashville's and Tennessee's role in the ratification of the 19 th Amendment to the United States Constitution, and American women's political movements, particularly in the South. It is located in the Votes for Women Room and was initiated through the vision of Margaret Behm, Juli Mosley, and Jeanie Nelson to commemorate the 100 th Anniversary of the 19 th Amendment. The Wilson Limited Editions Collection Containing more than 800 beautifully designed and illustrated books and portfolios of featured artwork by renowned artists such as Henri Matisse, Pablo Picasso, and Jacob Lawrence, this reference collection is housed at the Main Library and is available for viewing in depth by appointment only. Branch & Main Library Collections Adult Fiction Nashville Public Library's fiction collection includes a wide variety of contemporary works of fiction representing all genres, international works of fiction, classics and important novels of the past. The Library makes every effort to acquire fiction which is representative of the cultural and ethnic community that it serves and to satisfy the diversity of interests and recreational needs of its users. Adult Non-Fiction NPL aims at acquiring materials which provide a core of basic knowledge. In addition, the Library selects, makes accessible, and promotes the use of materials which: * address contemporary issues * provide self-help information * facilitate continuing education * enhance job-related knowledge and skills * increase knowledge of affairs of the community, the country, and the world * support business, cultural, recreational and civic interests in the community * nourish intellectual, aesthetic, creative and spiritual growth * present different viewpoints on issues Audiobooks The audiobook collection contains compact discs, pre-loaded MP3 devices and digital sound recordings of fiction and nonfiction books, poetry and drama, language instruction, and other subjects, based on current demand. Emphasis is on acquiring unabridged works whenever possible. Bookpacks Pre-packaged kits of playaway audiobooks and their print versions for children and adult new readers. Bookpacks are the easiest way for emerging and struggling readers, auditory and special education learners and ESL patrons to learn literacy skills. Children's Collection To encourage life-long reading habits, the children's collection provides materials in a variety of formats to satisfy and stimulate the informational, educational, cultural, and recreational needs of the children of Nashville from infancy through grade eight. The materials are selected with regard to the stages of emotional and intellectual maturity of children. The collection also provides adults with materials that relate to the well-being of children, enrich preschool and school curriculums, and aid in the study of children's literature. Electronic Databases (Commercial) Online computerized databases extend the collection by providing timely and versatile access to information in electronic format. Databases are used by the library staff to enhance and supplement reference service. Many of the databases contain specialized information beyond the scope of the library's print collections; others have information that does not exist in print format. Some databases duplicate print sources which are carefully evaluated for retention with consideration to cost, frequency of use, and ease of access to library users. E-Media Digital versions of nonfiction, fiction, periodical, reference, video, audiobooks, music, and images are all offered by Nashville Public Library. The content criteria outlined in each of those sections apply, as appropriate, to their electronic counterparts. Large Type The large type book collection meets the needs of an increasing number of visually impaired patrons. The major thrust of the collection is popular fiction, including mysteries, romances and westerns, along with high interest non-fiction. Large type books are purchased for the majority of locations based on demographics and demand. Launchpads A circulating collection of locked e-readers, preloaded with learning apps for children. Subject-focused e-readers range from English language arts to math and science. Themed ereaders include princesses, dinosaurs, animals and more. Literacy Collection The literacy collection provides written material in a variety of formats to support NPL's adult literacy efforts. It is comprised of material to support new readers as well as tutors and teachers though the Library does not collect textbooks or workbooks meant for individual use. Lucky Day Collection Designed to allow access to bestselling titles for casual library users without the placement of advance holds, the collection is composed of print adult and young adult books in fiction and nonfiction. These items have a limit of one checkout per library card and a shortened, fourteen day loan period in order to encourage faster turnover of material. No renewals or advance reservations online or by phone allowed. Books stay in Lucky Day status for two months before converting back to regular status. Music Music recordings are available at the Main Library and most of the branch libraries. Current purchases are in compact disc (CD) and digital formats because of their availability and popularity. The adult music collection consists of works by major classical and contemporary composers, as well as popular music. An emphasis is placed on acquiring recordings of musicals, folk music, jazz, and classical music. Compact discs for children include storytelling, folk and nursery songs, holiday music, and read-alongs. Periodical Collection NPL's newspaper and magazine collection provides current and retrospective information aimed at meeting the recreational reading needs of the community. The periodical collection consists of a diversity of publications in fields which are of interest to the community. It includes basic and popular reading magazines, foreign language publications, and a wide selection of business, trade, and local music industry publications. Journals which are highly technical or scholarly are generally not included in the collection. In addition to magazines, the collection includes newspapers published locally as well as from major geographical areas of interest to the community. Back issues of magazines circulate at the branch libraries. Back issues of many titles are accessible digitally for reasons of preservation and space conservation. Reference Collection NPL maintains a reference collection to serve the informational needs of library users. Reference sources are characterized by their ability to provide information and to summarize, condense, or give a comprehensive overview of a topic. They remain in the library to be readily available to all citizens. Selection criteria of particular importance for reference sources are: accuracy, arrangement, ease-of-use, uniqueness of information, authority, documentation, and indexing. Reference sources are consulted for specific items of information rather than to be read consecutively and include: bibliographies, indexes, directories, dictionaries, catalogs, statistical compendia, atlases, biographical dictionaries, and almanacs. The reference collection at the Main Library contains standard works in areas of general reference, the humanities, social sciences, physical and biological sciences, technology, history and area studies. It maintains in-depth collections in music business and art, and Nashville and Tennessee-related information. The collection also includes rare or difficult-toreplace books in these areas of specialization. The branch reference collections contain a core of basic ready reference materials supplemented by specific subject area resources of interest to that community. Branch staff has access to a reference hotline to obtain additional reference support and to access the more comprehensive resources at Main. Talking Books Talking Book collection – a circulating collection of picture books and easy readers with embedded audio narration. Combining print with audio is the easiest way for emerging and struggling readers, auditory and special education learners and ESL patrons to learn literacy skills. Textbooks Through an agreement with Metro Nashville Public Schools, all NPL locations, including Main have a core collection of print textbooks covering the basic core curriculum areas. These are reference items used for homework assistance and are updated each year. We do not replace missing textbooks. Videos Nashville Public Library collects videos to meet the educational and recreational needs of adults and children. The collection consists of popular feature films, television movies and shows as well as documentaries, instructional and educational films and film festival selections. Formats include DVD and other digital media. Videos of feature films include film classics, such as those named to the National Films Registry, and highly rated current films of broad family appeal or potential cultural, historical, or aesthetic significance. World Language Materials NPL maintains a collection of world language materials, aimed at meeting the recreational and many of the informational needs of the Nashville community. Resources include books, magazines, and newspapers, videos and sound recordings. These materials are primarily circulating. The Library's collection also includes materials which aid in learning a second language. These resources include books such as grammars, dictionaries, audio CDs, databases, and videos for learning the languages most frequently studied in the community. NPL is committed to developing and maintaining foreign language collections which meet the needs of a changing Davidson County population. Foreign language needs are assessed through such tools as US Census data, patron requests, circulation statistics and community awareness. The information gathered is used to determine the size and scope of the collection at each site. Availability of materials may impact the development of the collections. Young Adult Collection The young adult collection exists at all NPL branches and at the Main Library. These materials are intended for patrons from the age of 13 to 18 years. It is a transitional collection for the reader moving from the children's collection to the adult collection. The young adult collection consists of fiction and nonfiction books of popular and contemporary interest. Other formats include audiobooks on CD, pre-loaded MP3 devices, graphic novels, as well as digital formats such as e-books and e-audiobooks. Resolution RESOLUTION 2021 – 09.01 WHEREAS, a Collection Development Policy is a fluid document, needing constant refreshing to keep it accurate, as well as, relevant and WHEREAS, new collections, formats and policies have recently been added to the Nashville Public Library, the collection development plan is in need of revision. NOW, THEREFORE, BE IT HEREBY RESOLVED by the Nashville Public Library Board of Trustees to adopt the revised collection development plan as presented effective upon adoption.	<urn:uuid:81aec9af-edbe-430d-8271-c1f6974c0187>	CC-MAIN-2022-05	https://library.nashville.org/sites/default/files/2021-10/collection-development-olicy-39-.pdf	2022-01-21T14:59:05+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-05/subset=warc/part-00260-1e2959d8-5649-433a-b76e-f1b876a6479d.c000.gz.parquet	393,347,810	6,622	eng_Latn	eng_Latn	0.993631	eng_Latn	0.996185	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1352, 4284, 7070, 8691, 10934, 13279, 15781, 17928, 20593, 23220, 25709, 27990, 30688, 33738, 36326, 36990 ]
The University of Manitoba Department of Sociology SOC 2290 Introduction to Research Methods (Lab Component) Mondays 10:30-11:55 (B01/10742) and 1:30-2:55 (B02/10743) Tuesdays 10:30-11:55 (B03/10739) and 2:30-3:55 (B04/10741) Wednesdays 1:30-2:55 (B05/12243) Thursdays 2:30-3:55 (B07/18525) Classroom: Room 202 Isbister Instructor: Karen Kampen Phone: 474-8903 Email: [email protected] Office: 308 Isbister Office Hours: Monday 12:00-1:30, Tuesday 12:00-2:30, or by appointment - Please consider my door always open. Because I am an Undergraduate advisor for our department I am in the office a lot, so feel free to stop in any time that I am there. Required Textbook An SPSS Lab Manual will be provided for you during first term. Objective and Format of the Labs The main purpose of the lab is to take material learned in the classroom and textbook and apply it via practical, "hands on", problem-solving activities. We normally spend a few minutes at the start of the lab on conceptual review and practical demonstration as needed, followed by work on your assignment. Preparation Your assigned readings and/or lectures are the main source of preparation for lab assignments. Normally, our labs will lag at least one week behind the associated lecture topic from class. However, because occasionally the lab material might not correspond directly with previously introduced class material, additional concepts would be introduced in the lab if needed. All lab assignments are "open book", so please bring whatever class materials you find useful. From mid-November onward, students are required to bring their SPSS lab manual. Be sure to test your INS userid and password before the labs begin in September (www.umanitoba.ca/claimid). You will be unable to access the Internet or the SPSS statistical package without a functioning INS userid and password. It is also recommended that you bring a Memory Key or be prepared to save documents to the U of M network drive ("H"). Evaluation There will be two assignments. Each one is marked out of 100 points, and each one is worth 12.5% of your course grade. Please be reminded that the policy for all sections of SOC 2290 dictates that students must receive a passing grade of 50% or higher in the lab component in order to pass this course. Your grade in the lab is independent of your grade in the remaining course component. Students who fail the lab will fail this course and will be required to retake the entire course (not just the lab component) in order to obtain credit for SOC 2290. 1. Assignment #1 (12.5% of your course grade): This assignment will involve gathering your own data through an in-class content analysis of television commercials. There will be some group work involved in this assignment. You will be required to submit a brief proposal which will comprise 20 out of the 100 points on the assignment. The proposal is due during the week of October 6. The final report will due by the end of your scheduled class time during the week of December 1, 2014 (except for section B07, for whom it is due by 4:30 p.m. on December 4.) 2. Assignment #2 (12.5% of your course grade): - This assignment will involve analysing existing survey data using appropriate statistical techniques learned in class, via the SPSS statistical package. You will be required to submit a proposal which will comprise 20 out of the 100 points on the assignment. The proposal is due during the week of January 26. The final write-up will be due the week of March 23, 2015. * Unless otherwise specified by the instructor, assignments and proposals must be submitted in MS Word format on D2L Dropbox by the end of your registered lab session during the weeks specified above. Late Assignments and Absences * Late assignments (including proposals) are happily accepted, but in fairness to others, they are subject to a 10% penalty per day late. Documented medical or compassionate reasons or religious observances are the only acceptable reasons for assignment extensions. To be eligible for one, you must submit the following, no later than 24 hours after the assignment deadline: (1) appropriate documentation (e.g. Dr. note) covering dates of illness for which to be excused, if applicable; and (2) a current draft of your assignment. * Students who miss a lab session for legitimate reasons such as illness are welcome to attend another lab section that week, space permitting, but this should be used a last resort as most of our labs are at full capacity and you might be unable to complete any group work involved. Your assignment due dates will remain unchanged. Please bear in mind that not all lab sections cover the same topic every week, and our schedules are subject to change. * Any term work that has not been claimed by students will be held for four (4) months from the end of the final examination period for the term in which the work was assigned. At the conclusion of this time, all unclaimed term work will become property of the Faculty of Arts and be destroyed according to FIPPA guidelines and using confidential measures for disposal. Website and Email - The data required in Term 2, lab marks, and other necessary materials will be made available through D2L. Please use the above email address to email me personally, as I am not likely to see all notifications through D2L. A reasonable turnaround time for responses to student emails is normally 24 hours. Please also be reminded of the university's Electronic Communications with Students policy: http://umanitoba.ca/admin/governance/governing_documents/community/electronic_ communication_with_students_policy.html. Academic Integrity and Student Conduct * Students should acquaint themselves with the University's policy on plagiarism, cheating, or exam personation, ("Personation at Examinations" (Section 5.2.9) and "Plagiarism and Cheating" (Section 8.1)) and duplicate submission by reading documentation provided at the Arts Student Resources web site at http:// www.umanitoba.ca/faculties/arts/student/index.html. Please see the attached section on Academic Honesty Guidelines for information on plagiarism and appropriate collaboration. Note that there is no required citation style in the lab. * Electronic recording of any classroom activities (e.g. taking photographs of the board or the use of other recording devices) in the lab is strictly prohibited. Such recordings are a violation of an instructor's copyright of classroom materials as well as the privacy of other students and may be subject to Canadian legislation in that regard. TENTATIVE SCHEDULE Term 1 September 8-12: Introduction to Term 1: Why study advertising? September 15-19: Looking at our variables, attributes, and units of analysis September 22-26: Conceptualizing our measures September 29-October 3: Pre-testing our instruments October 6-10: Finalize research proposals; proposal DUE at end of class October 13-17: No labs due to Thanksgiving holiday observance on the 14 th October 20-24: Levels of Measurement, and feedback on proposals October 27-31: Collecting our data (Day 1) November 3-7: Collecting our data (Day 2) November 10-14: No labs due to Remembrance Day observance on the 11 th November 17-21: Introduction to SPSS and data entry November 24-28: Summarizing our data and assessing its validity and reliability December 1-3: Assignment #1 DUE by end of regular lab time (on the 4 th for B06, the day after classes end.) No labs are held this week since classes end mid-week. Term 2 January 5-9: No labs held this week (because there are no classes on the 5 th ) January 12-16: Developing your research question January 19-23: Hypotheses January 26-30: Complete your research proposal; DUE by end of class period February 2-6: Feedback on research proposals February 9-13: Univariate descriptive statistics February 16-20: No classes (MID-TERM BREAK/LOUIS RIEL DAY) February 23-27: Data Transformation March 2-6: Bivariate descriptive statistics: Measures of Association March 9-13: Elaborating the bivariate relationship using a Control Variable March 16-20: Inferential statistics: Chi-square Test of Significance March 23-27: Correlation and regression March 30-April 3: Assignment #2 DUE by end of regular lab time April 6-10: Tutorials in preparation for your class tests * Voluntary Withdrawal Deadline: March 19, 2015 *	<urn:uuid:6c8eea7d-ddb8-4206-b282-7d1bc182a506>	CC-MAIN-2022-21	https://www.umanitoba.ca/faculties/arts/departments/sociology/media/Kampen_SOC2290_Lab_Outline_2014-15.pdf	2022-05-20T13:12:49+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-21/subset=warc/part-00146-bd7ecbba-8e15-4123-ae07-d9c98ad96845.c000.gz.parquet	1,240,989,685	1,933	eng_Latn	eng_Latn	0.976363	eng_Latn	0.994796	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2031, 4344, 6643, 8458 ]
Added to California Rare Plant Rank 1B.2 on October 5, 2011 Rare Plant Status Review: Delphinium parryi ssp. eastwoodiae Proposed New Add to Rank 1B.2, G4T2 / S2 Aaron Sims (CNPS), Danny Slakey (CNPS), and Roxanne Bittman (CNDDB) August 30, 2011 Background http://ucjeps.berkeley.edu/tjm2/review/treatments/ranunculaceae.html#50105). Delphinium parryi ssp. eastwoodiae was a proposed new addition to the Inventory, 6 th Edition (2001), but was postponed for inclusion due to a lack of information on its frequency and distribution as well as its questionable distinction from D. variegatum, which is likely the only species it is easily confused with (Flora of North America, Vol. 3). Since that time, however, more information has become available on its distribution through the review of herbarium records (see "Localities" section of attached spreadsheet) as well as field observations from a number of botanists (J. Chesnut, D. Keil, E. Painter, and M. Wetherwax); and it is known to be distinguished from D. variegatum by lacking long hairs on its proximal petioles (Flora of North America, Vol. 3). Delphinium parryi ssp. eastwoodiae is separated from other subspecies of D. parryi by generally having reflexed sepals and basal leaves present in flower, and by occupying areas at approximately less than 700 meters in elevation (The Jepson Manual, Second Edition). Delphinium parryi ssp. eastwoodiae generally flowers from March to May, but is known to flower as early as February (The Jepson Manual, Second Edition; Consortium of California Herbaria 2011). Delphinium parryi ssp. eastwoodiae is a perennial herb in the Ranunculaceae that is endemic to coastal San Luis Obispo County. It is included in the Flora of North America (Vol. 3) and The Jepson Manual (1993), and will be included in The Jepson Manual, Second Edition (available online at: Delphinium parryi ssp. eastwoodiae is a serpentine endemic occurring in valley and foothill grasslands and grassland openings in coastal chaparral. It has been observed in rocky crevices and tumbled talus with deep adobe clays, usually below larger rock outcrops (J. Chesnut pers. comm. 2011), at an approximate elevation of 75 to 500 meters. Delphinium parryi ssp. eastwoodiae is known from approximately 18 occurrences mostly throughout the Santa Lucia Range of central-western San Luis Obispo County. The type specimen was collected by Alice Eastwood on May 2, 1896 (CAS236) from McDonald's Ranch in the Carrizo Plains. This record, especially since it is the type location, is somewhat perplexing as the Carrizo Plains' not only lack serpentine, but are quite disjunct from all other known occurrences of D. parryi ssp. eastwoodiae. The precise location of the type collection is difficult to determine, however, based on USGS sources, it may have been in the southern part of the Carrizo Plains on Saucito Ranch, which was the first ranch to be established there (Dieter Wilken pers. comm. 2011). Most of the land on Saucito Ranch was apparently owned by McDonald (Dieter Wilken pers. comm. 2011), and in the 1890's the ranch may have occupied approximately 60,000 acres of land (Rebecca Peters 2011). Unfortunately, Alice Eastwood's field notes from 1896 were presumably destroyed in the 1906 conflagration, and although some of her letters and memoirs still exist in the archives at the California Academy of Sciences, a reference to the 1896 collecting trip could not be found (Rebecca Peters pers. comm. 2011). However, other collections by Eastwood on the same day were "near the boundary between Santa Barbara and San Luis Obispo Counties White Hills, Cuyama" (Consortium of California Herbaria 2011), which is in the vicinity of the fault zone in the McDonald Ranch/Carrizo Plain area. Furthermore, David Chipping (pers. comm. 2011) notes that "there are smaller and closer [serpentine] deposits to the Carrizo Plain proper along the line between T 28 S and T 27 S just west of the San Andreas Fault, at the extreme end of the Temblor Range". This area is close to where Eastwood was collecting on May 2nd, 1896, and therefore may be in the vicinity of the type locality of D. parryi ssp. eastwoodiae. Of the 18 known occurrences of D. parryi ssp. eastwoodiae, only five have been documented and/or observed in the past twenty years (occurrences that have not been documented in over twenty years are considered historic by the CNDDB). Delphinium parryi ssp. eastwoodiae is abundant in a few localities, but is usually very local (Flora of North America, Vol. 3), and is currently known only from serpentine around San Luis Obispo (D. Keil pers. comm. 2011). Nevertheless, while D. parryi ssp. eastwoodiae is infrequent, it is expected to be well distributed at low elevation in the San Luis Obispo portion of the Santa Lucia serpentine belt; where much more habitat likely exists (J. Chesnut pers. comm. 2011). Delphinium parryi ssp. eastwoodiae is considered to be a relatively minor variant by some, and Hoover (1970) regarded it as essentially the same taxon as common D. parryi. However, the most recent floras not only recognize D. parryi ssp. eastwoodiae as a distinct taxon, but indicate it as uncommon and of conservation concern (The Jepson Manual, 1993; The Jepson Manual, Second Edition; Flora of North America, Vol. 3). Threats to D. parryi ssp. eastwoodiae at Camp San Luis Obispo may include trampling by cattle, non-native plants, military training activities, feral pigs, and too frequent fires and/or fires in the wrong season (E. Painter pers. comm. 2011, from CNDDB report for an associated taxon). In the North Morro Bay region it is potentially threatened by rapid grassland and chaparral conversion to avocado production, and potentially threatened north and south of San Luis Obispo by estate home development (J. Chesnut pers. comm. 2011). Based on the available information, CNPS and CNDDB recommend that Delphinium parryi ssp. eastwoodiae be added to California Rare Plant Rank 1B.2 of the CNPS Inventory. Recommended Actions CNDDB: Add to CNDDB G4T2 / S2 CNPS: Add to CNPS 1B.2 Please review the draft CNPS Inventory record below, respond Yes or No on the proposal to add this species to the Inventory and CNDDB, and provide any edits/comments. If responding No, please provide supporting information. Draft CNPS Inventory Record Eastwood's larkspur Delphinium parryi A. Gray ssp. eastwoodiae Ewan Ranunculaceae San Luis Obispo Rank 1B.2 Arroyo Grande NE (221A) 3512025, Lopez Mtn (246D) 3512035, Morro Bay North (247A) 3512047, Morro Bay South (247D) 3512037, Port San Luis (222A) 3512027, San Luis Obispo (246C) 3512036, Tar Spring Ridge (220B) 3512024 Chaparral (openings), Valley and foothill grassland / Serpentinite, coastal; elevation 75-500 meters. Many collections old. Possibly threatened at Camp San Luis Obispo by trampling, feral pigs, military activities, alteration of fire regimes, and non-native plants. Potentially threatened in North Morro Bay region by agriculture and habitat alteration, and potentially threatened in San Luis Obispo by housing development. Similar to D. variegatum. See University of Colorado Studies, Ser. D, Phys. Sci. 2(2):55-244 (1945) for original description. Perennial herb. Blooms (February) March to May.	<urn:uuid:61a925aa-706c-433e-abd5-0e9d052b85b8>	CC-MAIN-2022-21	https://rareplants.cnps.org/Uploads/ReferenceDocs/DelphiniumParryiSspEastwoodiae_20111005_StsRevAdd.pdf	2022-05-22T22:33:13+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-21/subset=warc/part-00260-bd7ecbba-8e15-4123-ae07-d9c98ad96845.c000.gz.parquet	542,313,192	1,902	eng_Latn	eng_Latn	0.93139	eng_Latn	0.983588	[ "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 2991, 5858, 7294 ]
Mundare News Recycle Yard Open Second Saturday of the month, next date is September 14 from 10am-noon. Branches, wood, small electronics, batteries, LED bulbs accepted. Sorry no mattresses, fridges or freezers or other household waste will be accepted. Council updates If you have a complaint or concern that needs to be addressed by council– please put in writing and forward to the Town Office. All New correspondence will be tabled at the next council meeting. Council meeting is September 3 and September 17 Truck fill Closure Based on recent information received from the Regional Water Commission, our bulk fill station will be shut down tentatively from September 16 at 8:30 pm till September 19 at 8am and again on September 23 starting at 8:30 pm till September 26 8am as they are working on the main line. Sorry for any inconvenience. Please check the Town of Mundare website or Town of Mundare facebook page for updates. On-Line Account Payments Because of updating with our system and on-line banking, please ensure that account numbers are entered correctly. Make sure that you select the right account either taxes, utilities or Accounts receivable and the correct corresponding account number is entered. Tax accounts are 6 numbers, your roll number only (minus the first three zero's) ie, 110500 and utilities are the full 13 numbers ie. 000650453A000. if there are letters, make sure they are capitalized. Accounts receivable are Alpha numeric, 7 numbers, as it shows on your statement ie. ABCD001 AROUND TOWN Thank-You Frank Rosypal for being our Parade Marshall for Mundare's Agri-days Parade, also thank you to our central office and staff, Colin, Lisa & Theresa as well as Shannon Kowal, Pauleen Larson and the kids who all helped with the Parade luncheon. parent, child, or grandchild. Sometimes a brother, a sister, or some other friend or relative brings us to Al-Anon. Many of us have had more than one alcoholic family member or friend. THANK YOU Thank you to CCI Wired for donating $25.00 to our Parks Society for every new account in Mundare. This money will help us build a pickle ball court!! Check out there amazing prices. Mundare Parks Country Music Jams Taking Place at the Mundare Recreation Cente (5116-50 Ave) 1:00pm-4:30 pm September 8, October 13, November 10, February 9, March 8, and April 12. Fee is $10.00, and $5.00 for musicians. For more information contact Bob (780) 632-4141 or Charlie (780)7643062 Al-Anon meeting Our personal situations may be different, but we share as equals because of what we have in common: our lives have been affected by another person's drinking. Al-Anon is a mutual support group. We can find understanding and support when we share our common experience with each other. Some of us are here because a spouse or partner has struggled with alcoholism. For others, the problem drinker is a Starting July 13 at 2:00pm at Chesterton House (old Hospital) located at 165016– Polomark Drive. Please use west side doors as the other doors are locked and a private residence. Corner Pub Specials All day at the Pub Monday: Mundare Plate (All Day Long) Tuesday: Caesar Day (All Day Long) Wednesday: Wing Day (All Day Long) Thursday: Free Pool (All Day Long) Friday: open Mic Day(9pm-1am) Saturday: Sangria Day Karaoke Free Night September 28 from 9pm-2:30 am New Menu: Traditional Korean Food Bugogi Rice, Bugogi Noodles, Fried Rice with Beef, Ramyun (noodle soup /spicy or Mild) Come, see us in action! Do you like the excitement of group activities? Baking, crafts, bingo or birthday parties are a few possibilities. Do you prefer one to one activities? Visiting, reading or knitting might fit the bill. *Only have a few minutes to spare? Volunteer from home. The Auxiliary has a number of homebased projects to choose from. Questions? We would love to hear from you! Contact Sharon (780) 764-2447, Wendy (587) 280-1225 or any auxiliary member. Communities in Bloom It's hard to believe we are into September. The flower pots in town are still looking great with thanks to Susan for her work with watering, dead heading etc. Next meeting is Monday, September 16, 1pm in the council chambers. YOU CAN HELP by calling Irene Talaga at 780-764-3877 and saying "How can I Help?" All funds raised go back into the community 100%. Mundare Drop in Centre– Next perogy dinner is September 20 at the Mundare Drop in centre from 56:30pm. Located at 5224-50 street. Take out is available. Coffee talk runs Thursdays from 1011:30am Floor curling every Monday & Wednesday afternoon from 1-3pm Always looking for new members. Congratulations To Stawnichy's Meat Processing on your 60th anniversary! What a fantastic well organized Celebration! Servus Credit Union Is having a free Pancake Breakfast on Friday, September13 from 9am-12 pm on Mainstreet Mundare in front of their branch at (5104-50 street) We are hosting this to show appreciation for all. Unsightly Notice Procedures If a property is determined to be unsightly, a notice is sent to the landowner If the work is not completed, a contractor is hired to do the work. -the notice will explain the what needs to be done and the date by which the work must be completed After the due date, an inspection is carried out. -the owner is charged all the contractor costs plus an administration fee of $75 If you have any questions regarding a unsightly notice, please contact the Town office. -if the invoice is not paid, the amount is added to the taxes Council will be giving out free hotdogs at the community awareness in conjunction with Lamont FCSS Mundare Registries Vehicle Registration Now due for Last Names and company names starting with F, Po, and T now past due for E and Gr from your friends at : Library news Please note that the librarian may not be available at the time of the programs In the Eye of the Storm Silence is Golden Silence Breaking Please register with the library before programs so we can have enough craft supplies and peanut/ nut free snacks. Tuesday, September 10, 2:15 to 3:15 p.m. A Promise is a Promise Many animals sleep a special kind of sleep in winter. It's called hibernation. When Bruno woke he saw a beautiful flower. What happens as the summer ends and winter returns. Will Bruno ever see his friend Dandelion again? Find out at story time, that a promise is indeed a promise. Please note changes to Library Hours at the end of September Closed: Monday September 2-Labour Day Closed: September 16-20 Open: Monday, September 23 Closed: September 24 and 26 Starting September 30 the Library returns to regular hours New Arrivals: Books for Adults Robert Their's Storm and Silence Series Storm and Silence Library Hours: Monday & Tuesday 12-6pm Thursday 10am-5pm Mundare School Time to get ready for school!! Summer holidays are quickly wrapping up and I hope that everyone has been enjoying their break and taking advantage of the great outdoors that surround us. This last little bit of summertime is a great time to get back into school routines. These routines include reading each night, adhering to a set bedtime, mealtime– all on a regular basis. This will make the transition back to school in early September a little easier. The same is true with technology and the habits that go along with these great tools. Small steps each day will lead to overall success. icy and student phones in school. We will be sharing more information on this new policy as it becomes available. As well, the portables are being moved from Mundare School, so you may notice a little more activity around the facility. We are really looking forward to seeing everyone on the first day of school, right after the long weekend. It's like a family reunion! I am personally looking forward to seeing how much the students have all grown over the break. Time to start thinking about setting some short term and long term goals!! A reminder about our new EIPS technology pol- It's going to be a great year!! William Korec, Med Principal-Mundare School 5128 50 Street, Mundare, AB T0B 3H0 Phone: 780-764-3929 Fax: 780-764-2003 E-mail: [email protected]	<urn:uuid:b7fb6dfa-487c-4755-8891-349425d0356b>	CC-MAIN-2020-45	https://files.townlife.com/public/uploads/documents/25091/September.pdf	2020-10-25T03:01:47+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-45/subset=warc/part-00250-6409130e-6e9b-44d1-90ec-9f9d0ade2504.c000.gz.parquet	322,111,076	1,946	eng_Latn	eng_Latn	0.998137	eng_Latn	0.998217	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1532, 4973, 5797, 8210 ]
Irish Rates – Central Bank of Ireland Issues Warning on Unauthorised Firm 17 June 2024 Warning Notice \| Warning: \| Unauthorised Investment Firm / Investment Business Firm \| \|--------------------------\|--------------------------------------------------------\| \| Unauthorised Firm Name \| Irish Rates \| \| Website \| https://www.irish-rates.com/ \| \| Email address(es) used \| [email protected] \| \| Phone number(s) used \| N/A \| \| Authorisation in Ireland \| This firm is [not authorised](#) to provide investment services or any other financial services in Ireland. \| Notes: 1. Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800. 2. For more information on how to protect yourself from financial scams, please visit www.centralbank.ie/financialscams 3. The name of the above firm is published under section 53 of the Central Bank (Supervision and Enforcement) Act 2013.	<urn:uuid:8358e21c-27d3-4801-8165-a030f94c7f7d>	CC-MAIN-2024-38	https://www.cnmv.es/webservices/verdocumento/ver?e=ZM7AyzGX3zXf5%2FAHEFpWsi4Qg4ObeT3KmV6CavF19OEpZvB3IV0JLjfIo7PF237R	2024-09-12T11:25:37+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-38/subset=warc/part-00070-781f89b0-54ef-4e32-b51d-e5860e733e3a.c000.gz.parquet	660,431,314	216	eng_Latn	eng_Latn	0.967925	eng_Latn	0.964586	[ "eng_Latn", "eng_Latn" ]	false	docling	[ 1015, 1136 ]
Hypnosis and Meditative Techniques: A Systematic Review Mr. Nitish Kumar & Dr. Satarupa Deka Lecturer, IILM University, Gr. NOIDA, email: [email protected] ** Assistant Professor, IILM University, Gr. NOIDA, [email protected] Abstract Hypnosis and meditative techniques have garnered significant attention for their potential therapeutic benefits. This systematic review synthesizes existing research on hypnosis and various meditative techniques, examining their efficacy, methodologies, and outcomes. The review identifies key themes, including the mechanisms of action, clinical applications, and comparative effectiveness. By analyzing a broad spectrum of studies, this paper provides a comprehensive understanding of how hypnosis and meditation can be used to enhance mental and physical health and offers directions for future research. Keywords: Hypnosis, Meditation, Clinical Application, Mental Health. Introduction Hypnosis and meditative techniques have long been regarded as effective methods for achieving mental and physical healing. Their historical roots stretch back thousands of years, with ancient civilizations using these practices for various purposes, including spiritual growth, emotional balance, and physical well-being. In contemporary society, these techniques have evolved and found their place in clinical settings, where they are employed to treat a range of conditions, from chronic pain and anxiety to substance abuse and stress-related disorders (Barber, 2001; Davidson & Kaszniak, 2015). Hypnosis Hypnosis is defined as a trance-like state characterized by focused attention, heightened suggestibility, and deep relaxation. It involves guiding an individual into a state where the subconscious mind becomes more accessible and responsive to suggestions (Spiegel, 2013). This altered state of consciousness allows individuals Page No: 2127 email: to experience changes in perception, memory, and emotion. The efficacy of hypnosis in clinical settings has been widely documented. It has been shown to effectively reduce chronic pain, alleviate anxiety, and support addiction recovery (Jensen et al., 2017). For instance, in patients with fibromyalgia and irritable bowel syndrome, hypnotherapy has been found to significantly reduce pain levels (Montgomery et al., 2010). Additionally, hypnosis can be beneficial in perioperative care by minimizing preoperative anxiety and postoperative pain (Montgomery, DuHamel, & Redd, 2000). Meditative Techniques Meditative techniques encompass a broad spectrum of practices, including mindfulness meditation, transcendental meditation, and guided imagery. These practices are primarily focused on achieving a state of mental clarity, emotional balance, and heightened awareness. Mindfulness meditation, one of the most extensively studied forms, involves maintaining a non-judgmental awareness of the present moment. It has been shown to enhance cognitive function and emotional regulation by increasing gray matter density in the hippocampus and improving connectivity in brain networks associated with executive function (Fox et al., 2016). Transcendental Meditation (TM), which involves the repetition of a mantra, has been linked to reduced blood pressure and improved cardiovascular health (Rainforth et al., 2007). Guided imagery, which involves visualizing calming and peaceful scenarios, has been used to manage pain, enhance relaxation, and improve sleep quality (Posadzki & Ernst, 2011). The Intersection of Hypnosis and Meditative Techniques While hypnosis and meditative techniques have distinct characteristics, they share common ground in their ability to alter states of consciousness and promote healing. Both practices involve focused attention and relaxation, which can lead to profound psychological and physiological changes. Research indicates that both hypnosis and meditation can modulate neural pathways associated with attention, pain perception, and emotional regulation (Oakley & Halligan, 2013; Tang, Holzel, & Posner, 2015). This commonality suggests potential synergistic effects when these practices are combined or used in conjunction with traditional therapies. Methodology Given the growing body of research on hypnosis and meditative techniques, a systematic review is essential to synthesize findings, identify patterns, and highlight gaps in the current literature. This review aims to provide a comprehensive analysis of the mechanisms of action, clinical applications, and comparative effectiveness of hypnosis and meditative techniques. By doing so, it seeks to inform practitioners and researchers about the potential benefits and limitations of these interventions and to guide future research directions. Objectives The objectives of this systematic review are to: 1. Examine the mechanisms of action underlying hypnosis and meditative techniques. 2. Assess the clinical applications and efficacy of these practices in treating various conditions. 3. Compare the effectiveness of hypnosis and different meditative techniques. 4. Identify methodological approaches used in the studies and suggest areas for future research. This systematic review aims to provide a comprehensive understanding of how hypnosis and meditation can be utilized to enhance mental and physical health. By synthesizing the existing literature, this review will offer valuable insights into the therapeutic potential of these practices and guide future research in this evolving field. Studies were gathered and analyzed from various relevant literature. Databases such as PubMed, PsycINFO, and Google Scholar were searched using keywords including "hypnosis," "meditative techniques," "mindfulness," "transcendental meditation," and "guided imagery." The inclusion criteria were peer-reviewed articles published between 2000 and 2023, focusing on the therapeutic use of hypnosis and meditation. Articles not in English, not peer-reviewed, or unrelated to the topic were excluded. This approach ensured a comprehensive and rigorous analysis of the existing body of work. Results Mechanisms of Action Hypnosis Hypnosis works by inducing a state of focused attention and heightened suggestibility, which allows for greater access to the subconscious mind (Spiegel, 2013). During hypnosis, individuals may experience alterations in perception, memory, and mood, facilitated by changes in brain activity. Neuroimaging studies have shown that hypnosis can modulate neural pathways associated with attention, pain perception, and emotional regulation (Oakley & Halligan, 2013). This suggests that hypnosis can effectively alter cognitive and emotional states, making it a versatile tool for therapy. Meditative Techniques Meditative techniques typically involve focused attention, open monitoring, or a combination of both, leading to various cognitive and emotional benefits (Tang, Holzel, & Posner, 2015). Neuroimaging studies have demonstrated that meditation can induce changes in brain structure and function, particularly in areas related to attention, emotion regulation, and self-referential processing (Fox et al., 2016). For instance, mindfulness meditation has been shown to increase gray matter density in the hippocampus and improve connectivity in brain networks involved in executive function and emotion regulation. Clinical Applications Hypnosis Hypnosis has been effectively used to manage pain, reduce anxiety, and treat addictions (Jensen et al., 2017). For instance, hypnotherapy has been shown to significantly reduce chronic pain in patients with conditions such as fibromyalgia and irritable bowel syndrome (Montgomery et al., 2010). Additionally, hypnosis can be a valuable tool in perioperative care, helping to reduce preoperative anxiety and postoperative pain (Montgomery, DuHamel, & Redd, 2000). In the context of addiction treatment, hypnotherapy can enhance motivation for change and reduce withdrawal symptoms (Elkins, Johnson, & Fisher, 2012). Meditative Techniques Meditative techniques have broad applications in mental health, including the treatment of anxiety, depression, and stress-related disorders (Goyal et al., 2014). Mindfulness-based interventions (MBIs), such as Mindfulness-Based Stress Reduction (MBSR) and Mindfulness-Based Cognitive Therapy (MBCT), have been widely studied and shown to reduce symptoms of anxiety and depression (Hofmann, Sawyer, Witt, & Oh, 2010). Transcendental Meditation (TM) has been associated with reductions in blood pressure and improved cardiovascular health (Rainforth et al., 2007). Guided imagery, another meditative technique, has been used to manage pain, enhance relaxation, and improve sleep quality (Posadzki & Ernst, 2011). Comparative Effectiveness While both hypnosis and meditative techniques have demonstrated efficacy in various clinical settings, comparative studies are limited. Some research suggests that mindfulness meditation and hypnosis can produce similar effects on pain reduction and anxiety management (Grant & Rainville, 2009). However, the mechanisms underlying these effects may differ, with hypnosis often relying more on suggestion and focused attention, whereas meditation typically involves a broader range of cognitive processes (Zeidan et al., 2012). Discussion Key Themes The review identifies several key themes in the literature on hypnosis and meditative techniques: the mechanisms of action, clinical applications, and comparative effectiveness. These themes highlight the multifaceted nature of these practices and their potential to enhance mental and physical health. Mechanisms of Action Hypnosis and meditation both induce significant alterations in brain function and structure, but they do so through different mechanisms. Hypnosis primarily alters brain activity through focused attention and suggestion, impacting areas involved in pain perception, attention, and emotional regulation (Spiegel, 2013). Meditation, on the other hand, involves sustained attention and mindfulness, leading to structural changes in the brain that enhance cognitive and emotional processing (Tang, Holzel, & Posner, 2015). Clinical Applications The therapeutic applications of hypnosis and meditation are extensive. Hypnosis is particularly effective for pain management, reducing anxiety, and aiding in addiction recovery (Jensen et al., 2017). Its ability to access the subconscious makes it a powerful tool for behavioral change and emotional regulation. Meditative techniques are widely used to address mental health issues, including anxiety, depression, and stress-related disorders (Goyal et al., 2014). Mindfulness and other meditative practices improve emotional regulation and cognitive function, contributing to overall mental well-being. Comparative Effectiveness Although both hypnosis and meditation are effective in their own right, the comparative effectiveness of these techniques is an area that requires further exploration. Some studies indicate that both practices can yield similar outcomes in terms of pain and anxiety reduction, yet the processes through which they achieve these results differ significantly (Grant & Rainville, 2009; Zeidan et al., 2012). More comparative studies are needed to understand the nuances of how each technique works and to identify the contexts in which one may be more beneficial than the other. Methodological Approaches The studies reviewed employed a variety of methodologies, including randomized controlled trials (RCTs), longitudinal studies, and neuroimaging research. RCTs provide robust evidence for the efficacy of hypnosis and meditation in various clinical contexts, while neuroimaging studies offer insights into the underlying mechanisms. Longitudinal studies are essential for understanding the long-term effects and sustainability of these interventions. Randomized Controlled Trials RCTs are considered the gold standard in clinical research and have been widely used to assess the efficacy of both hypnosis and meditative techniques. These studies provide high-quality evidence by minimizing bias and allowing for clear comparisons between treatment and control groups (Montgomery et al., 2000; Goyal et al., 2014). Neuroimaging Studies Neuroimaging studies have provided significant insights into how hypnosis and meditation affect brain structure and function. Techniques such as functional MRI (fMRI) and electroencephalography (EEG) have been used to observe changes in brain activity and connectivity associated with these practices (Fox et al., 2016; Oakley & Halligan, 2013). These studies help elucidate the neurological underpinnings of the therapeutic effects observed in clinical settings. Longitudinal Studies Longitudinal studies track the effects of hypnosis and meditation over extended periods, providing valuable information on the durability and long-term benefits of these interventions. These studies are crucial for understanding how regular practice can lead to sustained improvements in mental and physical health (Hofmann et al., 2010). Comparative Effectiveness More comparative studies are needed to understand the specific contexts in which hypnosis or meditation might be more effective. These studies should consider various outcomes, such as pain reduction, anxiety relief, and overall mental health improvement, and should use standardized measures to facilitate comparison (Grant & Rainville, 2009; Zeidan et al., 2012). Cultural and Contextual Factors The effectiveness of hypnosis and meditation can be influenced by cultural and individual differences. Future research should examine how cultural backgrounds, personal beliefs, and individual preferences impact the acceptance and effectiveness of these techniques. Understanding these factors can help tailor interventions to better meet the needs of diverse populations (Davidson & Kaszniak, 2015). Integration into Clinical Practice Research should also focus on how hypnosis and meditation can be integrated into standard clinical practice. This includes exploring the training and certification requirements for practitioners, the development of standardized protocols, and the identification of best practices for various clinical settings (Montgomery et al., 2010; Goyal et al., 2014). Emerging Technologies The use of emerging technologies, such as virtual reality (VR) and mobile applications, in delivering hypnosis and meditation is an exciting area for future research. These technologies have the potential to enhance the accessibility and effectiveness of these interventions by providing immersive and personalized experiences (Spiegel, 2013). Conclusion Hypnosis and meditative techniques are powerful tools for enhancing mental and physical health. This systematic review highlights the efficacy of these interventions, their underlying mechanisms, and their broad clinical applications. By synthesizing existing research, this paper provides valuable insights for practitioners and researchers, paving the way for future studies in this vital area. Both hypnosis and meditation offer promising avenues for therapeutic intervention, with the potential to improve quality of life and well-being for individuals across diverse clinical settings. Future Recommendation Future research should explore the comparative effectiveness of hypnosis and different meditative techniques in more detail. There is also a need for studies examining the cultural and contextual factors that influence the efficacy of these interventions. Additionally, research should investigate the potential for integrating hypnosis and meditation into standard clinical practice, as well as the impact of emerging technologies, such as virtual reality, on the delivery of these therapies. References Barber, T. X. (2001). Hypnosis and suggestion in the treatment of pain: A clinical guide. Journal of Pain and Symptom Management, 3(4), 241-247. https://doi.org/10.1016/S0885-3924(01)00325-7 Davidson, R. J., & Kaszniak, A. W. (2015). Conceptual and methodological issues in research on mindfulness and meditation. American Psychologist, 70(7), 581592. https://doi.org/10.1037/a0039512 Elkins, G. R., Johnson, A. K., & Fisher, W. I. (2012). Cognitive hypnotherapy for pain management. American Journal of Clinical Hypnosis, 54(4), 294-310. https://doi.org/10.1080/00029157.2011.647036 Fox, K. C., Nijeboer, S., Dixon, M. L., Floman, J. L., Ellamil, M., Rumak, S. P., ... & Christoff, K. (2016). Is meditation associated with altered brain structure? A systematic review and meta-analysis of morphometric neuroimaging in meditation practitioners. Neuroscience & Biobehavioral Reviews, 65, 1-22. https://doi.org/10.1016/j.neubiorev.2016.03.014 Goyal, M., Singh, S., Sibinga, E. M. S., Gould, N. F., Rowland-Seymour, A., JAMA Sharma, R., ... & Haythornthwaite, J. A. (2014). Meditation programs for psychological stress and well-being: A systematic review and meta-analysis. Internal Medicine, 174(3), 357-368. https://doi.org/10.1001/jamainternmed.2013.13018 Grant, J. A., & Rainville, P. (2009). Hypnosis and meditation: Similar experiential changes and shared brain mechanisms. Medical Hypotheses, 72(3), 346-352. https://doi.org/10.1016/j.mehy.2008.10.048 Hofmann, S. G., Sawyer, A. T., Witt, A. A., & Oh, D. (2010). The effect of mindfulness-based therapy on anxiety and depression: A meta-analytic review. Journal of Consulting and Clinical Psychology, 78(2), 169-183. https://doi.org/10.1037/a0018555 Jensen, M. P., Patterson, D. R., & Hypnosis, R. (2017). Hypnotic analgesia. American Psychologist, 72(3), 218-227. https://doi.org/10.1037/amp0000067 Montgomery, G. H., DuHamel, K. N., & Redd, W. H. (2000). A meta-analysis of hypnotically induced analgesia: How effective is hypnosis? International Journal of Clinical and Experimental Hypnosis, 48(2), 138-153. https://doi.org/10.1080/00207140008410045 Montgomery, G. H., David, D., Winkel, G., Silverstein, J. H., & Bovbjerg, D. H. (2002). The effectiveness of adjunctive hypnosis with surgical patients: a metaanalysis. 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LEAGUE MATCHES THURSDAY 26 JANUARY 2017 QUESTIONS BY THE RAILWAY FLIERS First Verbal Round 1. Which Swiss cyclist, a world champion and Olympic gold medallist, had the nickname Spartacus? Fabian Cancellara 2. Who played 'Hutch' in the 1970s TV series Starsky & Hutch? David Soul 3. What is the capital city of Peru? Lima 4. The Brightside brewery is located in which north west town? Radcliffe 5. What is the administrative HQ of the county of Shropshire? Shrewsbury 6. Who wrote the plays Roots, Chicken Soup with Barley and Chips with Everything? Arnold Wesker 7. Which Australian directed the films Strictly Ballroom and Moulin Rouge!? 'Baz' Luhrmann 8. An anemometer measures the speed and direction of what? Wind 9. Which group had top ten hits in 1966 with Daydream and Summer in the City? The Lovin' Spoonful 10. On which ship did Simon Weston suffer 46% burns when it was bombed during the Falklands campaign in 1982? (RFA) Sir Galahad 11. Who, as at 19 January 2017, is the chairman of the Exiting the European Union Select Committee in the House of Commons? Hilary Benn 12. Pitchblende is a major ore of which metallic element? Uranium 13. What surname is shared by a 20th century British potter and a Jamaican reggae singer? Cliff (Clarice and Jimmy) see note 1 14. What is the capital city of Ecuador? Quito 15. Which Greek god is the equivalent of the Roman god Mercury? Hermes 16. The National League football team Forest Green Rovers are based in which town? Nailsworth 17. Who wrote the plays The Birthday Party, The Homecoming and The Caretaker? Harold Pinter 18. What is the administrative HQ of the county of Buckinghamshire? Aylesbury 19. The Jennings brewery is located in which north west town? Cockermouth 20. Which group had number one hits in 1965 and 1966 with Keep on Running and Somebody Help Me? The Spencer Davis Group 21. A nephoscope is an instrument grid for measuring the altitude, direction and velocity of the movement of what? Clouds 22. Who, as at 19 January 2017, is the Secretary of State for Exiting the European Union? David Davis 23. Which metal was discovered by William Gregor in Cornwall in 1791 and is named after pre-Olympian deities in Greek mythology? Titanium 24. What surname is shared by a British potter who developed Florian Ware and the last non-African to hold the men's world 5000 metres running record? Moorcroft (William and David) 25. The National League South team Whitehawk are based in which city? Brighton (& Hove) 26. Which Roman god is the equivalent of the Greek god Ares? Mars 27. Which Royal Navy ship was trapped in the Yangtze River for three months in 1949 during the Chinese Civil War? (HMS) Amethyst 28. Which Australian directed the films Gallipoli and Picnic at Hanging Rock? Peter Weir 29. Who played Lacey in the 1980s TV series Cagney and Lacey? Tyne Daly 30. Which French cyclist, winner of the Tour de France, had the nickname The Badger? Bernard Hinault First Written Round THERE IS A THEME 31. Who was the youngest member of England's 1966 World Cup-winning team? Alan Ball 32. Which town known as The Jewel of East Yorkshire has a 13th century Minster and a racecourse? Beverley 33. Which former miner became Chancellor of the Duchy of Lancaster and Conservative Party Chairman in July 2016? Patrick McLoughlin 34. What was the name of the building in Chicago, now known as the Willis Tower, which at its completion in 1973 was the tallest building in the world, a title it held for approximately 25 years? Sears Tower 35. Who played The Joker in the Batman film of 1989? Jack Nicholson 36. Which jazz pianist and singer, born with the forenames Thomas Wright, became known by a nickname reflecting his size? 'Fats' Waller 37. Which Scotch whisky was described by Michael Jackson of the Whisky Magazine as 'like biting into peanut brittle, then toffee, then liquorice'? Teachers 38. Who wrote the operas Nixon in China and The Death of Klinghoffer? John Adams 39. Who had three top ten hits in the 1960s including Cupid and Chain Gang? Sam Cooke 40. Which family-run furniture store in Castle Street, Edgeley has been operating for over 80 years? Tweedies Theme is all answers contain the name of someone who married a sportsman: Norma Ball (Bobby Charlton); Joy Beverley (Billy Wright); Coleen McLoughlin (Wayne Rooney); Kim Sears (Andy Murray); Rebekah Nicholson (Jamie Vardy); Kathryn Waller (Ian Botham); Poppy Teacher (Tony Adams); Victoria Adams (David Beckham); Stacey Cooke (Ryan Giggs); Cheryl Tweedy (Ashley Cole). Second Verbal Round 41. Which river runs through the Grand Canyon in the USA? Colorado River 42. What was the name of the cook in the TV series Upstairs, Downstairs? Mrs Bridges 43. The extinct bird the Dodo was endemic to which island? Mauritius 44. Which English University is named after the man credited with calling the first parliament in 1265? De Montfort 45. Which group had a number one hit in 1961 with the song Blue Moon? The Marcels 46. The Cathedral Church of Christ, Blessed Mary the Virgin and St Cuthbert is located in which city? Durham 47. Name the year: Buddy Holly died in a plane crash, Fidel Castro became Premier of Cuba and the Mini designed by Alec Issigonis is launched. 48. Who painted The Arnolfini Wedding which hangs the National Gallery? Jan van Eyck Jean Sibelius 66. Which river runs through the Three Gorges in China? Yangtze 67. What was the name of the cook in the TV series Downton Abbey? Mrs Patmore 68. Which bird, a large flightless species of penguin living in the North Atlantic's rocky coasts and islands, was hunted to extinction in the 19th century? Great auk 69. Which Scottish University is named after a jeweller and an inventor? Heriot-Watt 70. Who wrote the novels The Naked and the Dead, The Executioner's Song and Ancient Evenings? Norman Mailer Second Written Round 71. Who were the four British boxers who fought Mohammed Ali? Brian London, Henry Cooper, Joe Bugner and Richard Dunn 72. What were the three male pseudonyms used by the Brontë sisters? Acton, Currer and Ellis Bell 73. What does the medical term D & C stand for? Dilation and Curettage see note 3 74. What is code of conduct whereby the lives of women and children are to be saved first in a life-threatening situation, typically abandoning ship, when survival resources such as lifeboats are limited? Birkenhead drill 75. What name connects the first UK country act to have a top ten album, with Brave, and the beer served in the Bull at Ambridge in The Archers? (The) Shires 76. Which officer of the Royal Household of the United Kingdom had the power to prohibit the performance of plays where he was of the opinion that 'it is fitting for the preservation of good manners, decorum or of the public peace so to do', until this duty was abolished under the Theatres Act 1968? Lord Chamberlain 77. Which Greek classical author wrote the plays The Birds, The Wasps and The Clouds? Aristophanes 78. Who is the Leader of Trafford Council and the Conservative candidate for the Greater Manchester elected Mayor? Sean Anstee 79. Who succeeded Sir Ivan Rogers after his resignation as the UK's ambassador to the EU in January 2017? Sir Tim Barrow 80. Which singer's real name was Benjamin Earl Nelson? Ben E. King Spares 1. In which war was the Battle of Inkerman? Crimean War 2. Pyelitis affects which organ of the body? Kidney 3. Which American state is called The Sunflower State? Kansas 4. William George Perks is the birth name of which rocker? Bill Wyman 5. Which country has the rufiyaa as its currency? The Maldives 6. Who has been an Irish rugby international, a British Lion and CEO of the H. J. Heinz Company? Tony O'Reilly Notes 1. 'Perry' (as in Grayson and Lee 'Scratch') would also appear to be an acceptable answer. 2. The song was a top ten hit in the USA, but peaked at number 26 in the UK charts in January 1964. 3. The older term dilatation is an equally acceptable answer. Return to homepage	<urn:uuid:3b3a8749-863d-49b6-90e2-60b28775efd7>	CC-MAIN-2021-43	http://www.stockportquizleague.co.uk/201617railwayfliersL9.pdf	2021-10-23T21:14:08+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2021-43/subset=warc/part-00229-16202947-a809-4711-8221-79ab0a79d5b1.c000.gz.parquet	143,989,617	1,994	eng_Latn	eng_Latn	0.983228	eng_Latn	0.994896	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1524, 3239, 5314, 5416, 7379, 8094 ]
Minnesota Department of Labor and Industry Workers' Compensation Division PO Box 64221 St. Paul, MN 55164-0221 (651) 284-5032 1-800-342-5354 Request for Formal Hearing (under M.S. 176.106 or 176.305) PRINT IN INK or TYPE ENTER DATES in MM/DD/YYYY FORMAT FaX: 651-284-5731 DO NOT USE THIS SPACE WID or SSN DATE(S) OF CLAIMED INJURY EMPLOYEE VS. EMPLOYER AND INSURER AND ADDITIONAL PARTIES (INCLUDING INTERVENORS) Private or confidential data you supply on this form, and in communications or proceedings that occur because you file this form, will be used to process and resolve your workers' compensation dispute. The data will be used by department of labor and industry (department) staff who have authorized access to the data, and may be used for state investigations and statistics. You may refuse to supply the data, but if you refuse your claim may be delayed or denied, or the form may be returned to you. The data will be made part of the department's file for your claim and may be supplied to: anyone who has access to the file or the data by authorization or court order; the employer and insurer for your claim; the office of administrative hearings; the workers' compensation court of appeals; the departments of revenue and health; and the workers' compensation reinsurance association. TO THE ABOVE NAMED PARTIES AND THEIR ATTORNEYS: The above-named party, , requests a formal hearing. An administrative decision on the issues was previously issued by: (Name) . The decision was served and filed on: (date). The specific issues in dispute and the specific reason(s) for disputing the decision are as follows: MN RF03 (4/12) (over) Copies of this request have been served on all parties and their attorneys who are listed with addresses and attorney registration numbers as follows: (attach additional sheet if necessary) Employee: Employee Attorney: Employer: Employer/Insurer Attorney: Insurer: Other Party (Specify): REQUESTOR SIGNATURE ATTORNEY FOR PARTY SIGNATURE REQUESTOR PRINTED NAME ADDRESS DATE CITY STATE ZIP CODE ATTORNEY REGISTRATION # PHONE # (include area code) Name and address of other parties INSTRUCTIONS This form must be served on each party and each party's attorney, and received by the Department within 30 days after the date the decision was served and filed. Issues and reasons for the request must be specifically listed. For example, a general statement that the prior decision is not in conformity with the Workers' Compensation Act is not a specific statement of the disputed issues. All requests will be referred to the Office of Administrative Hearings for a formal hearing before a workers' compensation judge. This material can be made available in different forms, such as large print, Braille or audio. To request, call (651) 284-5032 or 1-800-342-5354/Voice or TDD (651) 297-4198. ANY PERSON WHO, WITH INTENT TO DEFRAUD, RECEIVES WORKERS' COMPENSATION BENEFITS TO WHICH THE PERSON IS NOT ENTITLED BY KNOWINGLY MISREPRESENTING, MISSTATING, OR FAILING TO DISCLOSE ANY MATERIAL FACT IS GUILTY OF THEFT AND SHALL BE SENTENCED PURSUANT TO SECTION 609.52, SUBDIVISION 3.	<urn:uuid:c7b227ab-ab54-4e38-bb7d-bc9b61c28f2a>	CC-MAIN-2018-05	http://www.dli.mn.gov/WC/PDF/rf03.pdf	2018-01-20T22:36:35Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-05/segments/1516084889736.54/warc/CC-MAIN-20180120221621-20180121001621-00706.warc.gz	424,245,425	745	eng_Latn	eng_Latn	0.987915	eng_Latn	0.990358	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1667, 3163 ]
CONTENTS Background Introduction Context Existing situation Parliament's starting position Council & European Council starting position Proposal Preparation of the proposal The changes the proposal would bring Views Advisory committees National parliaments Stakeholders' views Legislative process References EP supporting analysis Other sources 6 July 2018 Third edition The 'EU Legislation in Progress' briefings are updated at key stages throughout the legislative procedure. Please note this document has been designed for on-line viewing. Print Briefing EU Legislation in Progress Body of European Regulators for Electronic Communications (BEREC) On 14 September 2016, the European Commission proposed an updated regulation on the Body of European Regulators of Electronic Communications (BEREC). The proposal aims at transforming BEREC into a fully fledged agency. The Commission proposes allocating new tasks to BEREC and granting it legally binding powers. New tasks include providing guidelines for national regulatory authorities (NRAs) on geographical surveys, developing common approaches to meet end-user interests, and also developing common approaches to deliver peer-reviewed opinions on draft national measures (e.g. radio spectrum assignments) and on cross-border disputes. Parliament and Council found a compromise in trilogues. The BEREC Office will have legal personality, but not BEREC itself, which remains a body of NRAs. Parliament and Council also agreed on giving new tasks to BEREC and on moving from simple majority to twothirds majority for key decisions of the Board of Regulators and of the Management Board. The Council endorsed the compromise on 29 June 2018, Parliament's ITRE committee is due to vote on it on 10 July 2018. EN Introduction Context Existing situation Parliament's starting position Council & European Council starting position Introduction On 14 September 2016, the European Commission adopted a set of initiatives and legislative proposals as announced in the digital single market (DSM) strategy for Europe (adopted in May 2015). The overhaul of the regulatory framework for electronic communications (also called the telecoms or connectivity package), aims to ensure 'a more effective regulatory institutional framework in order to make the telecoms rules fit for purpose as part of the creation of the right conditions for the digital single market.' 1 These include, amongst others, the deployment of very high capacity connectivity networks and more coordinated management of the radio spectrum for wireless networks. In addition, the Commission aims at creating a level playing field for advanced digital networks and innovative services. In its 2016 resolution, Towards a digital single market act, the European Parliament (EP) called on the Commission to further integrate the DSM digital single market by ensuring that a more efficient institutional framework is in place. According to the Commission, this can be done, inter alia, by updating the Regulation on the Body of European Regulators of Electronic Communications (BEREC). The Commission considers that the changing market and technological environment make it necessary to strengthen the role, capacity and decisionmaking powers of BEREC. Furthermore, BEREC's tasks need to encompass all areas which have an effect on the internal market for electronic communications (e.g. e-market shaping aspects of radio spectrum assignment procedures or general authorisation). Lastly, BEREC needs to mirror the tasks assigned to the national regulatory authorities (NRAs) as these will soon be harmonised. The Commission argues that the present set-up of BEREC creates unecessary administrative burden, for example 'duplication of programming and reporting processes for BEREC and the BEREC Office, conferral of the appointing authority powers to the vice-chair of the management committee without possibility of delegating to the administrative manager and further sub-delegating.' 2 Furthermore, BEREC has apparently only been partially able to build up regulatory capacity to achieve some its main objectives. For this purpose, the administrative capacity of BEREC needs to increase. Its current architecture is made up of a body with legal personality (BEREC Office), which is (in terms of staffing) the smallest agency-like entity in the EU, plus the BEREC board of regulators (see below for more). BEREC delivers opinions and recommendations in the area of its competence to the Commission and NRAs, which are obliged to take 'utmost account' of BEREC's positions. 1 European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing the Body of European Regulators for Electronic Communications, COM(2016) 591 final, 2016/0286(COD), 14.9.2016, p. 2. 2 Ibid., p. 47. EPRS Body of European Regulators for Electronic Communications (BEREC) Legislative process References Introduction Context Existing situation Parliament's starting position Council & European Council starting position Context The initial Commission proposal for a regulation establishing a European electronic communications market authority in order to improve consistency of the EU telecoms rules and to contribute to the development of the Single Market dates back to 2007. In 2009, Regulation (EC) No 1211/2009 of the European Parliament and of the Council establishing the Body of European Regulators for Electronic Communications (BEREC) and the BEREC Office was adopted. BEREC became fully operational in 2010. BEREC replaced the European regulators group (ERG) for electronic communications networks and services, which was established as an advisory group to the Commission in 2002. The Commission's proposal to update BEREC is part of the review of the regulatory framework for electronic communications, which contributes to one of the pillars of the DSM strategy launched in May 2015. The strategy and new legislation aim at promoting competition, the internal market, end-users' interests and widespread access to very high capacity data connectivity. Existing situation The mission of BEREC 'is to assist the European Commission and the NRAs in the implementation of the EU telecoms rules, to give advice on request and on its own initiative to the European institutions and to complement at European level the regulatory tasks performed at national level by the regulatory authorities'. BEREC's mains tasks are, among others: > > to disseminate regulatory best practices, assisting the NRAs in the implementation of the EU telecoms rules; > > to advise the EU institutions on telecoms and assist the institutions and the NRAs in their relations with third parties; > > to deliver opinions on draft decisions and recommendations on harmonisation; > > to ensure the development of common rules and requirements for providers of cross-border business services; > > give opinions on cross-border disputes; and > > monitor and report on the electronic communications sector. BEREC is composed of two bodies: (i) the BEREC Office in Riga (Latvia) which provides assistance and support; and (ii) the board of regulators which is made up of the chief executives of the NRAs. The BEREC Office is an EU body with a legal identity, providing several functions and support for programme management, executive support and administrative and finance support. NRAs are an important resource in the discharge of BEREC's role. Introduction Context Existing situation Parliament's starting position Council & European Council starting position The board of regulators appoints its chair and vice-chairs from among its members. The term of office of the chair and of the vice-Chairs is one year. Before serving the one-year term as chair, the chair has firstly to serve one year as a vice-chair. To help ensure the continuity of BERECs' work, the chair also serves as a vice-chair for the year following their term as chair. According to BEREC's rules of procedure, the board of regulators shall act by a two-thirds majority of all its members (unless otherwise provided in the Regulation). According to the Commission, BEREC's current institutional set-up is 'often opting for greater flexibility or the lowest common denominator instead of focusing on a harmonised approach for the internal market'. 3 In addition, the Commission maintains that there is insufficient consistency across Member States regarding the implementation of the existing framework. Parliament's starting position In its resolution of 10 December 2013, the EP issued its opinion on the Commission's evaluation report regarding BEREC and the Office (2013/2053(INI)). The EP, inter alia, recommended that BEREC's role, in particular its relationship with NRAs, should be better defined. It also recommended strengthening BEREC's responsibilities to facilitate the definition of common positions with a view to enhancing the internal market approach, including by evaluating the efficiency of current cooperation with NRAs and the Commission. Furthermore, the EP suggested providing 'more room' to BEREC to produce its own analysis and studies, enabling the agency's decision-making process to be more top-down and independent. In its legislative resolution of 3 April 2014 on the proposal for a regulation of the European Parliament and of the Council laying down measures concerning the the European single market for electronic communications and to achieve a connected continent, the EP suggested, amongst other things, that the NRAs take into account the BEREC guidelines when considering the proportionality of imposing on providers of electronic communications services an obligation to publish a wholesale reference offer. 4 In its resolution Towards a digital single market act, adopted on 19 January 2016, the EP called on the Commission to further integrate the digital single market by ensuring that a more efficient institutional framework is in place. In this context, the EP asked in point 61 of its resolution for the role, capacity and decisions of BEREC to be strengthened in order to achieve consistent application of the regulatory framework and to ensure oversight in the development of the single market and resolve cross-border disputes. In this context, the EP stressed the need to improve the institutional capacities (financial and human resources) and the governance structure of BEREC. Council & European Council starting position In its conclusions of 28 June 2016, the European Council adopted an agenda calling for swift and determined progress to bring the full benefits of the DSM to stakeholders. The European Council considered this could be achieved through, amongst other things, pursuing 'efforts towards better regulation' and creating 'the 3 Ibid., p. 47. 4 On wholesale reference offers, see chapter 3 of the BEREC Report on the wholesale roaming market. Introduction Context Existing situation Parliament's starting position Council & European Council starting position right conditions for stimulating new business opportunities'. In this context, the European Council says that 'the review of the telecoms regulatory framework should aim to incentivise major network investments while promoting effective competition and consumer rights.' In December 2016, the Council held a policy debate on the revision of the EU telecoms regulatory framework. Most Member States agreed that the existing framework, including the radio spectrum policy group, could easily support the required cooperation for spectrum management. According to the Council, there was no need to create additional layers of cooperation or turn BEREC into a European agency, which would just add to the administrative burden. On 22 May 2017, the Maltese Presidency published a Council progress report on the European Electronic Communications Code (Recast) and BEREC. At the 9 June Council meeting on Transport, Telecommunications and Energy, ministers discussed the desired extent of EU-level coordination. The Maltese Presidency is of the view that its compromise proposals provide a strong foundation for finalising the Council position on the BEREC regulation under the upcoming Estonian Presidency. EPRS Body of European Regulators for Electronic Communications (BEREC) Views Legislative process References Preparation of the proposal The changes the proposal would bring Proposal Preparation of the proposal In accordance with the founding Regulation (EC) No 1211/2009, the Commission had an obligation to publish reports on the operation and functionality of BEREC and the BEREC Office within three years of the effective start of operations. The evaluation report done for the Commission in 2012 was mainly focused on determining the efficiency of BEREC in contributing to the development of the internal market for electronic communications. The scope of the evaluation was to provide an assessment of BEREC's and the BEREC Office's working practices, organisation and remit. The evaluation study was also transmitted to the European Parliament and Council; with the European Parliament adopting a resolution on it. The Commission has published several external studies on the DSM which, amongst other things, also assessed the structure and performance of BEREC. 5 The Commission carried out an ex-post evaluation ('REFIT'), which assessed the effectiveness, efficiency, relevance, coherence and EU added value of the BEREC Regulation. The staff working document accompanying the proposal concluded that the regulatory framework for electronic communications has broadly achieved its general objective (promoting competition, developing the internal market and cultivating end-user demands). According to the Commission, however, it appears necessary to review the BEREC Regulation in order to address the growing need for increased connectivity of the digital single market, and to streamline provisions taking into account market and technological developments. 6 The changes the proposal would bring The Commission proposes to revoke and replace the exisiting BEREC Regulation from 2009 with the proposed updated regulation. The new proposal for a BEREC regulation aims to contribute to: (1) the better functioning of the internal market for electronic communications networks; (2) the better functioning of cross-border electronic communications services; and (3) its effectively carrying out the (new) tasks. 7 The new proposal will transform BEREC into a fully fledged agency and make changes to its governance structure, with the aim of making BEREC more efficient and effective. 5 The external studies are summarised in the Commission's Impact Assessment which accompanies the BEREC Regulation proposal (SWD(2016) 303 final). 7 Ibid., p. 45. 6 European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing the Body of European Regulators for Electronic Communications, COM(2016) 591 final, 2016/0286(COD), 14.9.2016, p. 6. Preparation of the proposal The changes the proposal would bring The governance structure will be simplified by replacing the two current managing structures (the board of regulators for regulatory decisions, and the management committee for administrative and financial decisions) with a single management board, presided by the chair of the management board. According to the Commission, this will reduce the administrative burden by putting an end to the current duplication of agendas, working programmes, documents, etc. For the time being, the Commission can only attend the board of regulators as an observer, and has one representative on the management committee of the BEREC Office (with mainly administrative support tasks). For the future, the agency's management board would consist of one representative from each Member State, and two from the Commission. Each management board member would have voting rights. In addition, an Executive Director (selected from a shortlist prepared by the Commission) will be appointed to head the agency. They will be the legal representative of BEREC and responsible for the performance of the tasks assigned to the agency. In particular, the Executive Director will have delegated 'appointing authority powers'. This aims to would make management of the staff of the agency more efficient. Under the current BEREC Regulation, these powers are given to the vice-chair, whose term of office is one year, and they cannot be delegated/sub-delegated. The chair of the management board (to be elected for four years, renewable, whereas under the current regulation, their term is one year) and the Executive Director (elected for five years, renewable; under the current regulation: three years, renewable) will have longer terms of office to ensure continuity and stability. 8 One potential problem regarding the chair's term could arise from the the length of national NRA terms and their inability to commit to chairing BEREC for four years. Another aspect is that the expert working groups would be chaired by permanent members of staff rather than NRA experts, which might erode the link between BEREC outputs and national markets. Furthermore, a broader mandate and additional authority will be given to extend BEREC's remit and tasks. The new mandate includes tasks such as: 9 > > developing an economic model in order to assist the Commission in determining the maximum termination rates in the Union; > > issuing opinions on the resolution of cross-border disputes; > > issuing opinions on draft national measures related to the internal market procedures for market regulation; > > issuing opinions on draft national measures related to the internal market procedures for radio spectrum peer review; > > issuing guidelines on the implementation of NRAs' obligations as regards geographical surveys; 8 Ibid., p. 12. 9 Ibid., pp. 24-25. Preparation of the proposal The changes the proposal would bring > > issuing guidelines on common approaches to the identification of the network termination point 10 in different network topologies; > > issuing guidelines on common approaches to meet transnational end-user demand; > > issuing guidelines on the implementation of NRAs' obligations as regards open internet access; > > issuing guidelines on wholesale roaming access; and > > setting up a register of the extraterritorial use of numbers and cross-border arrangements and on providers of electronic communications networks and services. Given the new regulatory functions, the Commission proposes to increase the current BEREC staff. Currently some 27 people work at the BEREC Office, and the Commission envisages that rising to an overall staff figure of 60 full-time equivalents (FTE) at the end of the implementation period – 2019-2022. 11 The increase in staff and tasks would result in total costs of some €215 million per year, €13 million more than currently (see point 22.214.171.124 of the Commission's impact assessment report). BEREC is expected to play an important role in the coming years in furthering the DSM. The new regulation should increase the calls made upon BEREC to contribute to shaping technical and policy orientations. BEREC's work will remain dependent on the expertise of NRAs' representatives, as they will continue to work on the implementation of regulation at national level. In addition, the expertise of the NRAs will remain key given the technical character of the decisions BEREC will be called on to make, as well as of the current context of the agencies' resource constraints. 12 The Commission and BEREC have only non-binding powers with regard to market remedies. To improve the effectiveness of BEREC, a 'double-lock' system is proposed. This would mean that, if BEREC and the Commission agree on their position regarding the draft remedies proposed by a NRA, the Commission could require the NRA to amend or withdraw the draft measure and, if necessary, to re-notify the market analysis. 13 10 The network termination point (NTP) is defined in Article 2 (da) of the 'Framework Directive' (Directive 2002/21/EC of 7 March 2002 on a common regulatory framework for electronic communications networks and services), meaning the physical point at which a subscriber is provided with access to a public communications network. Cf. BEREC Guidelines on the Implementation by National Regulators of European Net Neutrality Rules, p. 8. 12 Ibid., p. 47 (see chapter 1.5.2). 11 European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing the Body of European Regulators for Electronic Communications, COM(2016) 591 final, 2016/0286(COD), 14.9.2016, p. 13. 13 Ibid., p. 11. Views Advisory committees Consultation of the European Economic and Social Committee (EESC) as well as the Committee of the Regions (CoR) is mandatory on this proposal. On 20 September 2016, the EESC appointed Jorge Pegado Liz (various interests – group III, Portugal) as rapporteur. Its opinion was adopted in plenary on 25 January 2017. The EESC, broadly speaking, supports the Commission's proposal to increase the responsibilities and coordinating powers of BEREC, but regrets that the agency will not become a genuine regulatory authority. National parliaments The deadline for the submission of 'reasoned opinions' on the grounds of subsidiarity was 12 December 2016. A reasoned opinion was sent by the French Parliament. Stakeholders' views 14 A 12-week open public consultation was launched by the European Commission on 11 September 2015, accompanied by a public hearing on 11 November 2015. The consultation aimed to get input for the evaluation process in order to assess the current rules and to seek external views on the framework. It also covered the review of specific parts of the framework, such as network access regulation, radio spectrum management and wireless connectivity, sector-specific regulation of communications services, universal service rules, and institutional set-up and governance. 15 The consultation received a total of 244 replies from stakeholders (consumers, providers of electronic communications networks and services, national and EU operator associations, NGOs, broadcasters, technology providers, etc.) in all Member States and from outside the EU. BEREC also contributed to the review process and published its opinion in December 2015. There were mixed views in the public consultation on the telecoms review as regards the effectiveness of BEREC's role in supporting consistent outcomes. While the role of NRAs is widely acknowledged, almost half of the respondents stressed that the institutional set‑up at EU and BEREC level should be adjusted. Suggestions included, inter alia, a clearer division of powers between the different institutions, making sure that institutions are politically and legally accountable for their decisions, and a high level of transparency in decision-making (greater stakeholder involvement). 16 14 This section aims to provide a flavour of the debate and is not intended to be an exhaustive account of all different views on the proposal. Additional information can be found in related publications listed under 'EP supporting analysis'. 16 Ibid., pp. 8-9. 15 Ibid., p. 8. EPRS Body of European Regulators for Electronic Communications (BEREC) Advisory committees National parliaments Stakeholders' views Legislative process The legislative proposal was published on 14 September 2016. Parliament has referred the dossier to the ITRE committee, which appinted Evžen Tošenovský (ECR, Czech Republic) as rapporteur. The Culture and Education (CULT) Committee provided an opinion to the report, with Silvia Costa (S&D, Italy) as rapporteur. Ivan Štefanec (EPP, Slovakia) drafted the opinion on behalf of the Internal Market and Consumer Protection (IMCO) Committee and Morten Helveg Petersen (ALDE, Denmark) on behalf of the Civil Liberties, Justice and Home Affairs (LIBE) Commitee. The draft report was presented in ITRE on 27 February 2017. According to the report, the status quo is functioning well. Therefore, the rapporteur suggested not to change the status of BEREC to a fully fledged agency. The deadline for tabling amendments in the ITRE committee was 4 April 2017 with the amendments discussed in committee on 22 June. The committee adopted its report on 2 October 2017. In line with Rule 69c, the decision to enter into interinstitutional negotiations with the Council was confirmed by plenary on 25 October 2017. The Council adopted its general approach on 4 December 2017. The first trilogue meeting was held on 6 December 2017. A final meeting took place on 5 June 2018, with Parliament and Council reaching agreement. This is based, inter alia, on a compromise regarding legal and governance questions: the BEREC office will have legal personality, but not BEREC itself, which will remain a body of national regulators. Financing and staffing have also been addressed for the BEREC office, so that it will be able to fulfil the new tasks given to it under the new European Electronic Communications Code. In this context, the two co-legislators decided to include a recital committing to support it within the powers and scope of the common framework for decentralised agencies. Parliament also agreed with the Council proposal on moving from simple majority to two-thirds majority for key decisions of the Board of Regulators and of the Management Board. In detail, it reads as follows: > > For the Management Board: The default rule is a simple majority. However, a 2/3 majority applies for the following: the adoption of the single programming document; the adoption of the budget; the election of the Chair and Vice-Chairs; and the appointment of the Director. > > For the Board of Regulators: The default rule is a simple majority. However, a 2/3 majority applies for the following: the adoption of the rules of procedure; the election of the Chair and Vice-Chairs; the adoption of decisions relating to Arts. 12, 22, 32, 33, 59, 66, 67, 73, and 97. When a decision under Art. 33(5) applies to Art. 74, it should be taken by a 2/3 majority, unless there is a simple majority in favour of taking a decision by a simple majority (this should be done on a case-by-case basis). Regarding the participation of other competent authorities in the working groups, in principle, the Council procedure is accepted. The Council (at Coreper level) approved the BEREC compromise text, together with the European Electronic Communications Code on 29 June 2018, which means that the two files should be ready for a vote in the ITRE committee on 10 July 2018. The European Parliament is expected to vote in plenary at first reading on the proposal during one of its autumn 2018 sessions. References EP supporting analysis Kononenko, V., The European Electronic Communications Code and the Body of European Regulators for Electronic Communica tion (BEREC), EPRS, European Parliament, January 2017. Negreiro, M., Bridging the digital divide in the EU, EPRS, European Parliament, December 2015. de Streel, A. and Hocepied, C., Optimal Regulatory Model for Telecommunications Services in the EU, Policy Department A, Euro pean Parliament, March 2017. Szczepański, M., A Digital Single Market Strategy for Europe, EPRS, European Parliament, September 2015. Other sources Body of European Regulators for Electronic Communications, European Parliament, Legislative Observatory (OEIL) Disclaimer and Copyright This document is prepared for, and addressed to, the Members and staff of the European Parliament as background material to assist them in their parliamentary work. The content of the document is the sole responsibility of its author(s) and any opinions expressed herein should not be taken to represent an official position of the Parliament. Reproduction and translation for non-commercial purposes are authorised, provided the source is acknowledged and the European Parliament is given prior notice and sent a copy. © European Union, 2018. 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RODERICK TIMBER Consent Decree for Cleanup Proposed The Washington Department of Ecology proposes, under terms of the Model Toxics Control Act (MTCA, Chapter 70.105D RCW), a consent decree with the City of Aberdeen and the Grays Harbor Historical Seaport Authority to clean up petroleum- and metals-contaminated soil, groundwater, surface water, and ditch sediment at the Roderick Timber site. A consent decree is a legal document, approved and issued by a court, formalizing an agreement between Ecology and potentially liable persons (PLP’s). This agreement ensures that proposed activities are conducted in a timely fashion, in accordance with MTCA and other applicable laws and regulations. As part of the consent decree, a draft cleanup action plan describing the site cleanup alternatives has been prepared. In addition, Ecology is issuing a State Environmental Policy Act (SEPA, Chapter 197-11 WAC) determination of non-significance (DNS) for the cleanup action proposed in the cleanup action plan. After review of the completed checklist and other information on file, Ecology (as SEPA lead agency) has determined that this proposal will not have a probable adverse impact on the environment. This action will benefit the environment by diminishing the release of toxic chemicals from the site. Your comments on the proposed consent decree, cleanup action plan (as an exhibit of the consent decree), remedial investigation/feasibility study (RI/FS), and SEPA DNS are welcome through June 27, 2003. The public is also invited to a meeting on June 12, 2003 to discuss the proposal, ask questions, and offer comments or concerns. The meeting will be limited to issues covered by this consent decree only. The box to the right provides information about where to review the proposed consent decree, where to submit comments, and details about the public meeting. Site Background The 295-acre Roderick Timber site is a former truck maintenance shop and log sort yard located at 712 Hagara Street in Junction City, near Aberdeen. The site is in the Chehalis River floodplain and was originally all wetlands. Beginning in the 1920s, a large portion of the property was used as a landfill for dredge spoils (from dredging along the Chehalis River), wood waste, and garbage from the City of Aberdeen between about 1958 and 1968. Phillip Roderick owned the site from the mid-1970s until 1988 when he went bankrupt. The property then defaulted to Grays Harbor County. Grays Harbor Historical Seaport Authority bought 214 Continued from Page 1 acres of the property in 1998 and the Grays Harbor Audubon Society owns 80 acres at the southern end. The Grays Harbor Historical Seaport Authority uses the large metal building in the former maintenance area to build wooden ships, and train students in shipbuilding and woodworking. Sierra Pacific Lumber Company owns the western portion of the property (across Hagara Street), which was also formerly owned by Phillip Roderick. This property, now listed as the Sierra Pacific site, is being cleaned up through an independent (without Ecology oversight) action. Phillip Roderick disposed of wood waste from his former log yard across Hagara Street at the Roderick Timber site. He operated a truck maintenance yard which included gasoline and diesel underground storage tanks, a truck wash area, a solvent cleaning station as well as a waste oil tank. Neighbors reported a tar pit and an oily sludge disposal pit on the property. In July 1987, during a salvage operation, DePaul Timber Company spilled a solvent tank which contained phenols and dichlorobenzene. Ecology cleanup contractors removed and disposed of solvent-contaminated soil, disposed of drums of hazardous waste and sludge, removed the waste oil tank, removed the contents of the underground storage tanks, and fenced off the maintenance area. Two site investigations in 1988 and 1989 were conducted by potential purchasers. Groundwater wells were installed and sampled. Soil, ditch sediments, and ditch surface water were also sampled. Ecology conducted a site hazard assessment in March 1991 to determine the environmental or human health threats, and to evaluate the site’s relative risk to other sites statewide. The Roderick Timber site was ranked as a one (one being the greatest risk; five being the lowest) and placed on the Hazardous Sites List. At the time the site was ranked on the list, it was compared to relatively few sites. The site received its score based on the high toxicity level of the spilled solvent and its impact on surface water. In the late 1990s, the City of Aberdeen received two EPA brownfields grants to conduct a remedial investigation to determine the nature, extent, and magnitude of site contamination. This included sampling soil, groundwater, surface water, and sediment. Some of these samples exceeded cleanup standards for petroleum hydrocarbons, carcinogenic polycyclic aromatic hydrocarbons (PAHs), arsenic, lead, and chromium. No large area of contamination or contaminated groundwater was discovered. Wetlands to the south and east do not appear to be affected. Ditches on the north and west site boundaries have some metals and petroleum contamination in surface water and sediment. These ditches discharge surface water to the Chehalis River. Some of these affected ditches are off-site and in a residential area. Although there is groundwater contamination, all residents are on city water. Based on the results of the remedial investigation, a feasibility study was prepared to evaluate site cleanup alternatives. What Is Being Done? The proposed consent decree, including the cleanup action plan, requires the City of Aberdeen and the Grays Harbor Historical Seaport Authority to take the following actions: - excavate contaminated ditch surface sediment and soil; - cover the fenced area with gravel; - construct a bio-swale (specially-engineered treatment ditch) and install a groundwater interception trench to route contaminated groundwater to the bio-swale and away from neighborhood ditches; - cap the garbage with soil and vegetation; - plant, where needed, around the landfill perimeter with vegetation that can draw up metals from soil; - monitor groundwater and bio-swale surface water to verify the effectiveness of the cleanup action; - place deed restrictions to ensure that future owners will not disturb the cap and will continue maintaining elements of the cleanup. Earlier this year, the removal of the underground storage tanks, and cleanup of soil and groundwater around the underground storage tanks and former truck parking/washing area using bioremediation (treatment of pollution using microorganisms that break down the contaminants) were completed as an interim action. Ecology will oversee the project to ensure that all terms of the consent decree are satisfied. What Happens Next? Public comment on the proposed consent decree, cleanup action plan, and remedial investigation/feasibility study will be considered and the consent decree will be modified, if necessary. The decree will be finalized by being entered in court and final cleanup work will begin. The work for the cleanup should be completed by September 2004. Further formal public comment opportunities will occur after the cleanup is completed. Ecology Wants Your Comments! You may review and comment on the proposed consent decree, cleanup action plan, RI/FS, and SEPA DNS through June 27, 2003. The public comment period presents a chance to have your ideas and comments heard by Ecology. A public meeting is being held on June 12, 2003. This will be a chance to learn about the site and proposed consent decree, and to state your comments or concerns. The box on page one provides details about where the documents can be found and how to submit comments. To review more detailed site documents than those in the information repositories, call Ecology’s Southwest Regional Office records center at (360) 407-6365 to schedule an appointment. Please submit your comments to Dom Reale, Site Manager at the Ecology address listed in the box on page one. Ecology will review and respond to all comments received, and may revise the consent decree. Updates of site activities will be provided to those who submit comments or request to be placed on the site mailing list. 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THIS ANNOUNCEMENT AND THE INFORMATION CONTAINED HEREIN IS RESTRICTED AND IS NOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, IN WHOLE OR IN PART, DIRECTLY OR INDIRECTLY, IN, INTO OR FROM THE UNITED STATES, AUSTRALIA, THE REPUBLIC OF SOUTH AFRICA, NEW ZEALAND OR JAPAN OR ANY OTHER JURISDICTION IN WHICH SUCH RELEASE, PUBLICATION OR DISTRIBUTION WOULD BREACH ANY APPLICABLE LAW OR REGULATION. THIS ANNOUNCEMENT IS FOR INFORMATION PURPOSES ONLY AND DOES NOT CONSTITUTE OR CONTAIN ANY INVITATION, SOLICITATION, RECOMMENDATION, OFFER OR ADVICE TO ANY PERSON TO SUBSCRIBE FOR, OTHERWISE ACQUIRE OR DISPOSE OF ANY SECURITIES IN CORNISH METALS INC OR ANY OTHER ENTITY IN ANY JURISDICTION. NEITHER THIS ANNOUNCEMENT NOR THE FACT OF ITS DISTRIBUTION, SHALL FORM THE BASIS OF, OR BE RELIED ON IN CONNECTION WITH ANY INVESTMENT DECISION IN RESPECT OF CORNISH METALS INC. CORNISH METALS TO RAISE UP TO £40.5 MILLION THROUGH A £25 MILLION STRATEGIC INVESTMENT BY SIR MICK DAVIS' VISION BLUE RESOURCES AND A UK PLACING AND CANADIAN SUBSCRIPTION OF UP TO £15.5 MILLION Vancouver, March 28, 2022 Highlights * Offering to raise up to £40.5 million (approximately C$66.8 million) comprising o £25 million (approximately C$41.2 million) strategic investment by Vision Blue Resources ("VBR"), a vehicle founded by Sir Mick Davis to invest in green energyrelated metal and mineral resource companies o £15.5 million (approximately C$25.6 million) from a private placing to existing and new UK institutional investors as well as a subscription by existing Canadian investors and eligible accredited private investors * Net proceeds will advance the South Crofty tin project - a fully permitted, former producing high-grade underground tin mine, located in Cornwall, UK o Work will include dewatering of the mine, resource drilling, completion of a feasibility study, evaluation of further downstream beneficiation opportunities, and on-site early works in advance of a potential construction decision * Demand for tin is expected to increasingly outstrip supply in coming years driven by growing demand from the electronics sector, EVs, and renewable power, especially solar cells o Since March 2021, LME cash tin prices have risen from approximately US$25,000 per tonne to in excess of US$40,000 per tonne Cornish Metals Inc. (TSX-V/AIM: CUSN) ("Cornish Metals" or the "Company"), a mineral exploration and development company focused on tin / copper projects in Cornwall, United Kingdom, is pleased to announce that, subject amongst other things to receipt of the requisite shareholder approvals and the approval of the TSX Venture Exchange ("TSX-V"), the Company plans to raise gross proceeds of up to £40,500,000 (C$66,800,700) through a unit offering (the "Offering") comprising one common share priced at 18p (C$0.30 for Canadian investors) per common share and a warrant to purchase one common share priced at 27p (C$0.45 for Canadian investors) for a period of 36 months (details provided below). Richard Williams, CEO of Cornish Metals, stated; "This announcement marks a transformational moment for the Company, its shareholders and all stakeholders in relation to the redevelopment of South Crofty, the Company's principal asset. It is testament to the quality of both the project and the Company that an investor of the calibre of Vision Blue Resources is proposing such a significant investment, and we are delighted to welcome them as a major strategic shareholder. "Tin is essential to anything electronic, including electric vehicle (EV) components, computing, 5G, robotics, renewable power generation, and the electrification of the economy, making South Crofty a strategic asset with the ability to provide a secure, traceable, sustainable supply of this important metal. "We are excited to embark on this new chapter of Cornwall's mining history which will see South Crofty make a significant contribution to the local and UK economy, with the potential to create up to 1,000 direct and indirect jobs, as well being at the forefront of the drive towards net zero." Sir Mick Davis, CEO of VBR, stated: "VBR was founded to accelerate the responsible supply of commodities necessary to facilitate the transition to clean, green energy. The investment in South Crofty has the potential to deliver significant tin production to meet an expected supply shortfall and enable the deployment of new, green technologies. At the same time, restarting production at an historic underground mine, within the existing footprint, and with the benefit of modern production techniques, provides an opportunity to minimise environmental and other impacts whilst creating significant benefits for local communities." About Vision Blue Resources VBR aims to create lasting value for all stakeholders by accelerating the supply of the commodities necessary to facilitate the green energy transition. The growth in demand for these metals is unprecedented, driven by regulation and social change, and is taking place against a backdrop of limited supply due to years of underinvestment in the sector. VBR aims to unlock value in its investments by providing transformational investment capital and its financial, technical, ESG, construction and operating experience in the mining and metals sector, ensuring its investments are advanced into production and beyond. Compelling Opportunity Demand for tin is expected to grow rapidly as it is essential for the high-tech, low carbon economy and, according to research by the Massachusetts Institute of Technology, it is the metal most likely to be positively impacted by new technologies. Tin is primarily used in the production of lead-free solder used in almost all circuit boards and semiconductors, as well as renewable energy systems where tin is used in the production of photo voltaic cells, and there is growing demand from the automotive sector where it is utilised in EV components and has been shown to enhance the performance of EV batteries themselves. At the same time there is no primary mine production of tin in Europe or North America and the metal has been designated as a mineral critical to economic and national security by the USA. South Crofty has one of the highest grade tin Mineral Resources in the world not currently in production and has the potential to be amongst the lowest cost producers globally. Having previously operated until 1998, there is significant mine infrastructure still in place, most notably several mine shafts that can be used for future production and ventilation purposes, and the operation is located within an industrial area with access to the national electricity grid as well as existing transport infrastructure. Details of the Offering In connection with the Offering: (i) VBR and the Company have entered into a conditional agreement dated March 28, 2022 (the "Investment Agreement") pursuant to which VBR has agreed to purchase, on a private placement basis (the "VBR Subscription"), an aggregate of 138,888,889 units of the Company (each, a "Unit"); (ii) the Company is undertaking a concurrent placing in the UK, on a private placement basis, of up to 76,872,728 Units (such Units being the "UK Placing Units") with certain existing and new institutional investors (the "UK Placing"); and (iii) the Company is also undertaking concurrent subscriptions, on a private placement basis, of up to 9,238,383 Units (such Units being the "Subscription Units") with certain existing Canadian and UK investors and eligible private investors (the "Concurrent Private Placements" and, collectively with the VBR Subscription and the UK Placing, the "Offering"). The subscription price for all Units issuable under the Offering is £0.18 (C$0.30 for Canadian investors) each (the "Offering Price"). Each Unit comprises one common share of the Company (each, a "Common Share") and one common share purchase warrant of the Company (each, a "Warrant"). Each Warrant shall entitle the holder thereof to purchase one additional Common Share (each, a "Warrant Share") at an exercise price of £0.27 (C$0.45 for Canadian investors) per Warrant Share for a period of 36 months from the closing date of the Offering. Use of Proceeds The planned use of the proceeds of the Offering is to complete a dewatering programme and feasibility study at South Crofty, evaluation of downstream beneficiation opportunities, and potential on-site early works in advance of a potential construction decision. Assuming the issuance of all 225,000,000 Units pursuant to the Offering, the proceeds raised under the Offering are budgeted to be spent in the following manner to finance a 30 month programme (from closing of the Offering) covering mine dewatering and resource drilling through to the completion of a feasibility study in respect of the South Crofty mine. Total £40.5m Other Relevant Information * The 225,000,000 Common Shares comprised in the Units to be issued pursuant to the Offering (the "New Shares") will comprise 44 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering 1 , with VBR expected to hold 138,888,889 Common Shares or 27.2 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering. 1 All references in this announcement to percentages of the Company's issued and outstanding Common Shares exclude the proposed issue at AIM Admission of the Galena / Tin Shield Shares referred to in "Deferred Consideration Payable to the Sellers for the Cornwall Assets" below as it is not yet possible to determine the number of Galena / Tin Shield Shares that will be issued.. * Pursuant to the Investment Agreement, following closing of the Offering, for so long as VBR maintains at least a 10 per cent. shareholding in the Company, VBR is expected to have the right to nominate one person to the Company's board of directors. * Certain directors and officers of the Company intend to subscribe for £146,000 (approximately C$240,800) in aggregate of Units in the Concurrent Private Placements at the Offering Price. * VBR will on the closing of the Offering enter into a relationship agreement with the Company and the Company's nominated adviser, SP Angel Corporate Finance LLP ("SP Angel"), relating to the carrying on of the Company's business in an independent manner following the closing of the Offering (the "Relationship Agreement"). * VBR and all other subscribers in the Offering have agreed to a 12 month lock-in, in respect of the shares being subscribed for. The directors and officers have agreed to a 12 month lock-in in respect of their holdings and the shares being subscribed for and to orderly market arrangements for a further 12 month period following the expiry of the initial lock-in. * Certain Shareholders (including all those directors and officers of the Company who hold Common Shares) who together are beneficially interested in a total of 98,233,961 Common Shares (representing 34.4 per cent. of the Company's issued and outstanding Common Shares), have entered into irrevocable undertakings pursuant to which each have agreed to vote in favour of the requisite resolutions at the Special Meeting. * The Offering is conditional, inter alia, upon the approval of shareholders of the Company ("Shareholders") at a special meeting of the Shareholders expected to be held on or around May 19, 2022 (the "Special Meeting"). * The New Shares are expected to be admitted to trading on AIM and to be listed and for trading on the TSX-V on or around May 24, 2022. Closing of the Offering is subject to certain conditions including, among other things: (i) receipt of the requisite Shareholder approvals at the Special Meeting to approve the creation of VBR as a new "Control Person" of the Company within the meaning of applicable Canadian securities laws and the issuance of all Units and the Warrant Shares pursuant the Offering in accordance with certain provisions in the Company's constating documents (collectively, the "Shareholder Approvals"); (ii) the conditional approval of the TSX-V for the issue of the Units pursuant to the Offering and the listing of the New Shares and the Warrant Shares on the TSX-V (the "TSX-V Conditional Approval"); (iii) the Secretary of State confirming, inter alia, that no action will be taken under the UK National Security and Investment Act 2021 in relation to VBR's acquisition of more than 25 per cent. of the Company's issued and outstanding Common Shares; (iv) the satisfaction of other customary closing conditions in each of the Investment Agreement, the conditional agreement dated March 27, 2022 between the Company, SP Angel and H&P Advisory Ltd. ("Hannam & Partners") in respect of the UK Placing (the "UK Placing Agreement") and the conditional subscription agreements dated March 27], 2022 between the Company and certain existing Canadian and UK investors, directors and eligible private investors (the "Subscribers") in respect of the Concurrent Private Placements (the "Subscription Agreements"); and (v) the admission of the New Shares to trading on AIM ("AIM Admission") taking place on or before May 24, 2022 (or such later date as SP Angel and Hannam & Partners (together the "Joint Brokers") may agree, but in any event not later than June 24, 2022). Neither the VBR Subscription, the UK Placing nor the Concurrent Private Placements have been underwritten by the Joint Brokers nor by anyone else. The Company and VBR may agree (but are under no obligation to agree) that VBR may subscribe for any of the UK Placing Units not, or is likely to not be, subscribed for pursuant to the UK Placing Subject to completion of the Offering, including the TSXV Conditional Approval, the Company expects to pay certain cash commissions to the Joint Brokers in connection with the Offering. No fees or commissions are payable by the Company in connection with the Concurrent Private Placements. Application will be made by or on behalf of the Company to the London Stock Exchange for AIM Admission which is expected to take place on or before 8.00 a.m. (London time) on May 24, 2022 and that dealings in the New Shares on AIM will commence at the same time. The closing of the Offering is not conditional on the listing for trading of the New Shares on the TSX-V. Upon closing of the Offering, the New Shares will be issued credited as fully paid and will, on AIM Admission, rank pari passu in all respects with the Existing Common Shares including the right to receive all dividends or other distributions declared, made or paid after AIM Admission. The New Shares: (i) have not been qualified for distribution by prospectus in Canada, and (ii) may not be offered or sold in Canada during the course of their distribution except pursuant to a Canadian prospectus or in reliance on an available prospectus exemption. Subject to completion of the Offering, all the New Shares to be issued as part of the Offering would be subject to a hold period of four months and one day in Canada from the date of their issuance in accordance with applicable Canadian securities legislation. Under applicable Canadian securities legislation, such hold period will only apply to trades (as defined under applicable Canadian securities legislation) of the New Shares in Canada. The New Shares being offered under the Offering will not be registered under the United States Securities Act of 1933, as amended (the "US Securities Act") and may not be offered or sold within the United States absent registration or an exemption from the registration requirements. This news release does not constitute an offer to sell or a solicitation of an offer to buy any of the New Shares in the United States. Special Meeting and Irrevocable Undertakings Subject to receipt of the TSX-V Conditional Approval, the Company expects to file the management information circular in respect of the Special Meeting (the "Circular") on SEDAR, and to post the Circular to Shareholders, on or about April 20, 2022, providing further details of the Offering and including a notice convening the Special Meeting, to seek the Shareholder Approvals for the closing of the Offering and the issue of the Common Shares and Warrants comprising the Units and the issue of the Warrant Shares following exercise of the Warrants pursuant to the Offering. The Company expects to schedule the Special Meeting on or about May 19, 2022, and will issue a further news release announcing the details of the Special Meeting, including the Circular in respect of the Special Meeting, once finalized. Certain Shareholders (including all those directors and officers of the Company who hold Common Shares) who together are beneficially interested in a total of 98,233,961 Common Shares (representing 34.4 per cent. of the issued and outstanding Common Shares) have entered into irrevocable undertakings pursuant to which each have agreed to vote in favour of the requisite resolutions at the Special Meeting. Related Party Transactions The Company advises that Patrick Anderson, Grenville Thomas, Stephen Gatley, John McGloin, Richard Williams and Owen Mihalop, being directors and / or officers of the Company, have agreed to subscribe for Units pursuant to the Concurrent Private Placements. As such, the Concurrent Private Placements will constitute a "related party transaction" within the meaning of Policy 5.9 of the TSX-V rules and Multilateral Instrument 61-101 - Protection of Minority Security Holders in Special Transactions ("MI 61-101"). Related party transactions require a formal valuation and minority shareholder approval unless exemptions from these requirements are available under applicable Canadian securities laws. In connection with the Concurrent Private Placements, the Company expects to rely on the exemption from the formal valuation requirement in section 5.5(b) of MI 61-101 (as a result of the Common Shares being listed on the TSX-V and being admitted for trading on AIM). With respect to an exemption from the minority approval requirement in connection with the Concurrent Private Placements, the Company expects to rely on the exemption in section 5.7(1)(b) of MI 61-101 (as neither the fair market value of the Common Shares which may be distributed to, nor the consideration which may be paid by, the related parties will exceed $2,500,000). Further details in respect of the Offering will be included in a material change report to be filed by the Company. The participation of Patrick Anderson, Grenville Thomas, Stephen Gatley, John McGloin, Richard Williams and Owen Mihalop, being directors of the Company or a subsidiary of the Company, in the Offering is considered a related party transaction for the purposes of AIM Rule 13 of the AIM Rules for Companies. Ken Armstrong, the Director independent of the Offering, considers having consulted with SP Angel Corporate Finance LLP, the Company's Nominated Adviser, that their participation in the Offering is fair and reasonable in so far as the Company's shareholders are concerned. Details of the PDMRs' participation can be found in the Appendix to this announcement. Further Information on the Offering Further information on the Offering and the Investment Agreement, the UK Placing Agreement, the Subscription Agreements, the lock-ins and orderly market arrangements, and the Relationship Agreement can be found in the Appendix to this announcement. Deferred Consideration Payable to the Sellers for the Cornwall Assets Further, subject to closing of the Offering, in accordance with the deferred consideration payment terms pursuant to a Share Purchase Agreement dated March 16, 2016, as amended, among the Company, Galena Special Situations Limited (formerly Galena Special Situations Master Fund Limited) ("Galena") and Tin Shield Production Inc. ("Tin Shield" and, together with Galena, the "Sellers"), the Company expects to issue to the Sellers, on or about the closing of the Offering, Common Shares with an aggregate value of US$4,750,000 at the Offering Price (converted into US dollars at the US$/£ exchange rate on the fifth business day before the date of the issue) (the "Galena / Tin Shield Shares"), subject to receipt of approval of the TSX-V. For further information on such deferred consideration, please see the Company's news releases dated March 17, 2016, June 30, 2021, October 4, 2021 and November 3, 2021, all available on the Company's profile on SEDAR at www.sedar.com. All Common Shares issuable to each of the Sellers will be subject to a hold period in Canada of four months and one day from the date of their issuance in accordance with applicable Canadian securities legislation. ABOUT CORNISH METALS Cornish Metals completed the acquisition of the South Crofty tin and United Downs copper / tin projects, plus additional mineral rights located in Cornwall, UK, in July 2016 (see Company news release dated July 12, 2016). The additional mineral rights cover an area of approximately 15,000 hectares and are distributed throughout Cornwall. Some of these mineral rights cover old mines that were historically worked for copper, tin, zinc, and tungsten. The South Crofty project covers the former producing South Crofty tin mine located beneath the towns of Pool and Camborne, Cornwall. The South Crofty mine closed in 1998 following over 400 years of continuous production. Since acquiring the project in 2016, Cornish Metals has completed and published maiden NI 43-101 Mineral Resources for South Crofty using the vast archive of historical production data and more recent drilling completed between 2007 and 2013. In 2017, Cornish Metals completed a Preliminary Economic Assessment that demonstrated the economic viability of reopening the mine. Additionally, Cornish Metals has undertaken extensive pilot-scale water treatment trials and successfully applied for and received the necessary environmental permits to abstract, treat and discharge mine water in order to dewater the mine. Planning permissions for the operation of the mine and re-development of the surface facilities have been secured and construction of the water treatment plant foundations commenced. The dewatering pumps, variable speed drives and new high-voltage power supply have been delivered to site. For an updated Mineral Resource Estimate in respect of the South Crofty Mine, please see the Company's technical report entitled "South Crofty Tin Project Mineral Resource Update" dated effective June 7, 2021, a summary of certain portions of which is set out below: All technical information contained within this news release has been reviewed and approved for disclosure by Owen Mihalop, (MCSM, BSc (Hons), MSc, FGS, MIMMM, CEng), the Chief Operating Officer for the Company, and a "qualified person" as defined in NI 43-101. For additional information please contact: In North America: Irene Dorsman at (604) 200 6664 or by e-mail at [email protected] In UK: SP Angel Corporate Finance Tel: LLP (Nominated Adviser & Joint Broker) Richard Morrison Charlie Bouverat Grant Barker Hannam & Partners (Joint Broker) Tel: +44 207 907 8500 Matthew Hasson Andrew Chubb Ernest Bell BlytheRay (Financial PR/IR-London) Tel: +44 207 138 3204 Tim Blythe Megan Ray [email protected] [email protected] For Vision Blue Resources Aura Financial Tel: +44 207 321 0000 +44 7834 368 299 +44 7841 748 911 Michael Oke Andy Mills [email protected] ON BEHALF OF THE BOARD OF DIRECTORS "Richard D. Williams" Richard D. Williams, P.Geo Market Abuse Regulation disclosure The information contained within this announcement is deemed by the Company to constitute inside information pursuant to Article 7 of EU Regulation 596/2014 as it forms part of UK domestic law by virtue of the European Union (Withdrawal) Act 2018 as amended ("MAR") encompassing information relating to the Offering described above, and is disclosed in accordance with the Company's obligations under Article 17 of MAR. In addition, market soundings (as defined in MAR) were taken in respect of the UK Placing with the result that certain persons became aware of inside information (as defined in MAR), as permitted by MAR. This inside information is set out in this Announcement. Therefore, upon publication of this announcement, those persons that received such inside information in a market sounding are no longer in possession of such inside information relating to the Company and its securities. Neither the TSX Venture Exchange nor its Regulation Services Provider (as that term is defined in the policies of the TSX Venture Exchange) accepts responsibility for the adequacy or accuracy of this release. Caution regarding forward looking statements This news release contains "forward-looking statements". These forward-looking statements are statements regarding the Company's intentions, beliefs or current expectations concerning, among other things, the Company's projections, outlook, forecast, estimates, plans, potential results of operations or upcoming work programs, financial condition, prospects, growth, strategies and the industry in which the Company operates, including, without limitation: statements in connection with the Offering and the issuance of the Units, including the amounts expected to be invested, the timeline of certain events in respect thereof, expected security holdings in the Company of VBR and investors following closing of the Offering, the related parties expected to participate in the Concurrent Private Placements, including the applicable exemptions, the board nomination rights and other rights expected to be granted to VBR following closing of the Offering, the terms and conditions of the lockin agreements and orderly market arrangements following closing of the Offering, the potential payment of cash commissions, the expected use of proceeds, including in respect of certain work programs and the potential completion of a feasibility study on the South Crofty mine, the expected supply and demand for tin generally, the potential benefits to the Company, to the economy and to the environment in respect of the development of the South Crofty mine, exploration potential, the expected holding of the Special Meeting, the filing of the related management information circular and the irrevocable undertakings entered into in respect of voting at the Special Meeting, the satisfaction of conditions for closing of the Offering, including the potential receipt of Shareholder Approval and approval from the TSX-V in respect of the Offering, the listing of the New Shares on the TSX-V and the AIM Admission, VBR's aims and goals, and the expected issuance of the Galena / Tin Shield Shares. Forward-looking statements, while based on management's best estimates and assumptions at the time such statements are made, are subject to risks and uncertainties that may cause actual results to be materially different from those expressed or implied by such forward-looking statements, including but not limited to: risks related to receipt of regulatory approvals, risk of non-compliance with planning and environmental permissions / licences, risks related to general economic and market conditions; risks related to the COVID-19 global pandemic and any variants of COVID-19 which may arise; risks related to the availability of financing; the timing and content of upcoming work programs; actual results of proposed exploration activities; possible variations in mineral resources or grade; risks associated with the unplanned departure of key personnel, environmental risks, failure of plant, equipment or processes to operate as anticipated; accidents, labour disputes, title disputes, claims and limitations on insurance coverage and other risks of the mining industry; changes in national and local government regulation of mining operations, tax rules and regulations. Although Cornish Metals has attempted to identify important factors that could cause actual results to differ materially from those contained in forward-looking statements, there may be other factors that cause results not to be as anticipated, estimated or intended. There can be no assurance that such statements will prove to be accurate, as actual results and future events could differ materially from those anticipated in such statements. Accordingly, readers should not place undue reliance on forwardlooking statements. Cornish Metals undertakes no obligation or responsibility to update forwardlooking statements, except as required by law. Information to distributors Solely for the purposes of the UK's implementation of Articles 9 and 10 of Commission Delegated Directive (EU) 2017/593 supplementing MiFID II, and in particular paragraph 3.2.7R regarding the responsibilities of UK Manufacturers under the Product Governance requirements contained within Chapter 3 of the FCA Handbook Product Intervention and Product Governance Sourcebook (the "Product Governance Requirements") and disclaiming all and any liability, whether arising in tort, contract or otherwise, which any "manufacturer" (for the purposes of the Product Governance Requirements) may otherwise have with respect thereto, the UK Placing Units have been subject to a product approval process, which has determined that the UK Placing Units are: (i) compatible with an end target market of (a) retail investors, (b) investors who meet the criteria of professional clients and (c) eligible counterparties, each as defined in Product Governance Requirements; and (ii) eligible for distribution through all distribution channels as are permitted by Product Governance Requirements (the "Target Market Assessment"). Notwithstanding the Target Market Assessment, distributors should note that: the price of the UK Placing Units may decline and investors could lose all or part of their investment; the UK Placing Units offer no guaranteed income and no capital protection; and an investment in the UK Placing Units is compatible only with investors who do not need a guaranteed income or capital protection, who (either alone or in conjunction with an appropriate financial or other adviser) are capable of evaluating the merits and risks of such an investment and who have sufficient resources to be able to bear any losses that may result therefrom. The Target Market Assessment is without prejudice to the requirements of any contractual, legal or regulatory selling restrictions in relation to the UK Placing. For the avoidance of doubt, the Target Market Assessment does not constitute: (a) an assessment of suitability or appropriateness for the purposes of MiFID II; or (b) a recommendation to any investor or group of investors to invest in, or purchase, or take any other action whatsoever with respect to, the UK Placing Units. Each distributor is responsible for undertaking its own target market assessment in respect of the UK Placing Units and determining appropriate distribution channels. SP Angel, which is a member of the London Stock Exchange, is authorised and regulated in the United Kingdom by the FCA and is acting as joint broker and nominated adviser in connection with the UK Placing. H&P, which is a member of the London Stock Exchange, is authorised and regulated in the United Kingdom by the FCA and is acting as joint broker in connection with the UK Placing. Each of the SP Angel and H&P are acting exclusively for the Company in connection with the matters referred to in this announcement and for no-one else and will not be responsible to anyone other than the Company for providing the protections afforded to their respective clients, nor for providing any advice in relation to the contents of this announcement or any transaction, arrangement or matter referred to herein. This announcement has been issued by and is the sole responsibility of the Company. No representation or warranty, express or implied, is or will be made as to, or in relation to, and no responsibility or liability is or will be accepted by either SP Angel or H&P (apart from the responsibilities or liabilities that may be imposed by the Financial Services and Markets Act 2000,or the regulatory regime established thereunder) or the Company or by any of their respective affiliates or agents as to, or in relation to, the accuracy or completeness of this announcement or any other written or oral information made available to or publicly available to any interested party or its advisers, and any liability therefore is expressly disclaimed. Dates only indicative Each of the dates referred to in this announcement as to the publication of the Circular and the date of the Special Meeting is indicative only and may be subject to change by the Company. Such dates will be notified to shareholders by announcement through a Regulatory Information Service and a news release disseminated through Globe Newswire and filed on the Company's profile on SEDAR at www.sedar.com. Exchange rate All C$ equivalents of the amounts being raised referred to in this announcement have been calculated using the Bank of Canada's closing exchange rate for March 25, 2022 of C$1.6494/£. APPENDIX Further Information on the Offering This Appendix contains further information on the Offering and of the material contracts entered into by the Company in relation to the Offering. The Investment Agreement VBR has entered into the Investment Agreement with the Company to subscribe for 138,888,889 Units at the Offering Price to invest £25 million (approximately C$41.2 million) in the Company. VBR's obligation to subscribe for the VBR Subscription is conditional, amongst other things, on the TSX-V Conditional Approval, the Shareholder Approvals, the UK Placing Agreement and the Concurrent Private Placements becoming unconditional (other than, in each case, for AIM Admission) and not having been terminated and on AIM Admission taking place on or before May 24, 2022 (or such later date as the Company and VBR may agree, but in any event not later than June 24, 2022) and the Investment Agreement becoming unconditional and not being terminated prior to AIM Admission. The VBR Subscription is not conditional upon the listing for trading of the New Shares on the TSX-V. The Investment Agreement contains representations and warranties from the Company in favour of VBR. The Investment Agreement may be terminated by VBR in certain circumstances prior to AIM Admission, including circumstances where any of the representations and warranties are or could reasonably be expected to become untrue, inaccurate or misleading, the UK Placing Agreement is terminated or there has occurred, in VBR's opinion, acting in good faith, any fact, matter, event, circumstance, condition or change occurring which materially and adversely affects the business, operations, assets, liabilities, condition (whether financial or otherwise) of the Company and its affiliates (the "Group") or the South Crofty project (or the permits relating to the same) taken as a whole. The Investment Agreement grants the following rights to VBR for so long as its shareholding and those of its affiliates in the Company is not less than 10 per cent. of the Company's issued and outstanding Common Shares: (i) VBR may nominate from time to time one person to the Company's board of directors, a further person as an observer at board meetings and one person to a technical committee of the Company; and (ii) VBR will have a participation right to maintain its percentage ownership interest in the Company upon any offering of securities at the subscription price and similar terms as are applicable to the offering. The Company has undertaken to VBR to use its reasonable commercial efforts to complete a bankable feasibility study in respect of the South Crofty project on or before 31 December 2024. The UK Placing Agreement The Company and the Joint Brokers have entered into the UK Placing Agreement pursuant to which, the Joint Brokers have agreed to act as agents of the Company in connection with the UK Placing and each of them has severally agreed to use their reasonable efforts to procure placees for the UK Placing Units at the Offering Price to raise £13.8 million (approximately C$22.8 million) (before expenses) for the Company. The Common Shares comprised in the UK Placing Units will represent approximately 15.0 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering. The UK Placing is conditional upon, inter alia, the TSX-V Conditional Approval, the Shareholder Approvals, the Investment Agreement and the Concurrent Private Placements becoming unconditional (other than, in each case, for AIM Admission), AIM Admission taking place on or before May 24, 2022 (or such later date as the Joint Brokers may agree, being not later than June 24, 2022) and the UK Placing Agreement becoming unconditional and not being terminated prior to AIM Admission. The UK Placing is not conditional upon the listing for trading of the New Shares on the TSXV. The UK Placing Agreement contains warranties and indemnities from the Company in favour of the Joint Brokers. The UK Placing Agreement may be terminated by either Joint Broker in certain circumstances prior to AIM Admission, including circumstances where any of the warranties are or could reasonably be expected to become materially untrue, inaccurate or misleading, or a matter arises that gives, or might reasonably be expected to give, rise to a claim under the indemnities or any change in national or international political, diplomatic, financial, economic, monetary or market conditions occur which in the opinion of either Joint Broker is likely materially and adversely to affect the business, financial position or prospects of the Group or is or will or is likely to be prejudicial to, or make it impracticable or inadvisable to proceed with, the UK Placing and/or AIM Admission. The Subscription Agreements Each Subscriber has entered into a Subscription Agreement with the Company to subscribe for the Subscription Units at the Offering Price to raise approximately £1.67 million (approximately C$2.7 million) (before expenses) for the Company. The Common Shares comprised in the Subscription Units will represent approximately 1.8 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering. The Subscription Agreements contain customary certifications and undertakings from the Subscribers as to its identity and level of sophistication including, without limitation, indicating that it satisfies the requirements of an available prospectus exemption under applicable Canadian and UK securities legislation. Each Subscriber's obligation to subscribe for the Subscription Units is conditional, amongst other things, on the TSX-V Conditional Approval, the Shareholder Approvals, the Investment Agreement and the UK Placing Agreement becoming unconditional (other than, in each case, for AIM Admission) and not being terminated prior to AIM Admission and on AIM Admission taking place on or before May 24, 2022 (or such later date as the Joint Brokers may agree, but in any event not later than June 24, 2022). The Concurrent Private Placements are not conditional upon the listing for trading of the New Shares on the TSX-V. Lock-ins and Orderly Market Arrangements On March 28, 2022, the Company, the directors of the Company and Owen Mihalop and Matthew Hird (the "Senior Managers"), who will together be beneficially interested in a total of 13,862,740 Common Shares as enlarged by the Offering (representing 2.7 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering), have undertaken in an agreement with the Company and the Joint Brokers (the "Directors' Lock-in Agreement") not to, and to procure that their connected persons do not, dispose of any interest in Common Shares or other securities in the Company held at the date of the Directors' Lock-in Agreement, together with any New Shares and Warrants acquired in the Offering and any Warrant Shares or other Common Shares acquired after the date of the Directors' Lock-in Agreement, (together "Relevant Shares") for the period from the date of the Directors' Lock-in Agreement until the first anniversary of AIM Admission, subject to certain exceptions. The directors and the Senior Managers have also agreed, subject to certain exceptions, for a further 12 months following the expiry of the initial lock-in period only to, and to procure that their connected persons only, dispose of an interest in Relevant Shares through either of the Joint Brokers (or any other nominated adviser or broker appointed to act for the Company in place of either or both of the Joint Brokers) or, in the case of Canadian directors and with the consent of the Joint Brokers and the Company, their Canadian broker. The Company, VBR, and the Joint Brokers will enter into an agreement (the "VBR Lock-in Agreement") on the closing of the Offering pursuant to which VBR, which will be beneficially interested in a total of 138,888,889 Common Shares as enlarged by the Offering (representing 27.2 per cent. of the Company's issued and outstanding Common Shares as enlarged by the Offering), will undertake with the Company and the Joint Brokers not to, and to procure that its connected persons do not, dispose of any interest in the New Shares and Warrants acquired by it in the VBR Subscription and any Warrant Shares acquired on the exercise of the Warrants or other Common Shares acquired after the date of the VBR Lock-in Agreement, (together "VBR Relevant Shares") for the period of 12 months following AIM Admission, subject to certain exceptions. 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VRtangibles: Assisting Children in Creating Virtual Scenes using Tangible Objects and Touch Input Andrii Matviienko [email protected] Technical University of Darmstadt Darmstadt, Germany Marcel Langer [email protected] Technical University of Darmstadt Darmstadt, Germany Florian Müller [email protected] Technical University of Darmstadt Darmstadt, Germany Martin Schmitz [email protected] Technical University of Darmstadt Darmstadt, Germany Max Mühlhäuser [email protected] Technical University of Darmstadt Darmstadt, Germany ABSTRACT Children are increasingly exposed to virtual reality (VR) technology as end-users. However, they miss an opportunity to become active creators due to the barrier of insufficient technical background. Creating scenes in VR requires considerable programming knowledge and excludes non-tech-savvy users, e.g., school children. In this paper, we showcase a system called VRtangibles, which combines tangible objects and touch input to create virtual scenes without programming. With VRtangibles, we aim to engage children in the active creation of virtual scenes via playful hands-on activities. From the lab study with six school children, we discovered that the majority of children were successful in creating virtual scenes using VRtangibles and found it engaging and fun to use. CCS CONCEPTS • Human-centered computing → Interaction devices; • Social and professional topics → Information science education. KEYWORDS virtual reality, tangibles, touch input, children, education ACM Reference Format: Andrii Matviienko, Marcel Langer, Florian Müller, Martin Schmitz, and Max Mühlhäuser. 2021. VRtangibles: Assisting Children in Creating Virtual Scenes using Tangible Objects and Touch Input. In CHI Conference on Human Factors in Computing Systems Extended Abstracts (CHI ’21 Extended Abstracts), May 8–13, 2021, Yokohama, Japan. ACM, New York, NY, USA, 7 pages. https://doi.org/10.1145/3411763.3451671 1 INTRODUCTION Young children are commonly mentioned as examples of creative thinkers who create their own worlds and play with imaginary friends, which allow them to develop new skills or compensate for the skills they cannot demonstrate in the real world [15, 38]. Today’s virtual reality (VR) technology allows a transfer of these imaginary worlds from imagination into an outside world of virtual reality. However, the process of creating new virtual worlds requires a technical background, which restricts the user group of active virtual world creators primarily to software developers. The issues of a technical barrier are particularly challenging for children, who are usually exposed to virtual reality as passive users and miss an opportunity to become active creators. Although there has been a big body of work done to facilitate children’s entry point into technology using physical computing toolkits [8, 32], tangible [3, 30, 36] and visual [13, 29] programming environments, and wearable computing platforms [20, 28], there has been little to support children’s active participation in creating virtual reality scenes. In this work, we aim to provide an intermediary step towards familiarization with VR as active creators by allowing non-tech savvy users, e.g., children, to create virtual scenes playfully without writing a code, and instead focus on creative expression. To facilitate the fun and quick creation of virtual scenes, we developed a virtual environment, where children can create virtual scenes while being inside the virtual world. From the interaction perspective, we have employed two interaction techniques to facilitate direct manipulation of virtual objects, known to children from daily interaction: (1) tangible input (from playing with toys) and (2) touch input (from playing with smartphones). We combined the virtual space and the interaction techniques in the system called VRtangibles, which includes a tablet, a set of tangible objects, and a virtual reality environment shown in the headset. Children can create virtual scenes by placing tangible objects on the tablet while wearing VR glasses and the virtual objects will instantaneously appear in the virtual world. To evaluate the effectiveness of the proposed system in facilitating children’s familiarization with VR via hands-on activities, we collected preliminary findings from a user test with six children. We found that children were successful in creating virtual scenes using VRtangibles and found interaction with the system to be fun. In this paper, we provide two primary contributions: • We present the design and implementation of VRtangibles – a system aimed at lowering the barrier of entry to primary school children’s in creating virtual reality scenes. • We present and discuss preliminary findings from an empirical evaluation with six school children that offers a view into the future improvements for VR educational systems for children. 2 RELATED WORK Although there has not been much work about creating virtual scenes focused on children, researchers have designed support systems to create VR environments in general. In this section, we outline existing work related to (1) tangible objects and (2) touch input for VR content creation, followed by (3) educational technology for children. 2.1 Tangible Objects for VR Content Creation Tangible user interfaces emerged a link between the digital and physical world, which in particular enabled the manipulation of digital objects using physical proxies [18, 33]. It was previously shown that people can better comprehend the manipulated information, when they physically interact with it, for instance, using tangible user interfaces [10]. Moreover, from the interaction perspective, tangible interfaces are faster for 3D manipulation tasks and more intuitive than mouse or touch interaction [5], which benefits spatial memory tasks [9]. In recent years, researchers facilitated the interaction in the virtual environment using tangible user interfaces, such as LEGO-proxies and 3D-printed objects, to extend the limited interaction experiences with standard VR controllers. A good example of physical manipulation in a virtual environment includes VirtualBricks. It is a LEGO-based toolkit that facilitates physical manipulation in VR by offering a set of feature bricks, which emulate and extend the capabilities of default controllers [1]. Using this toolkit users can build a proxy of a virtual object using LEGO bricks and operate a virtual object using its physical proxy. In another toolkit, called TanGi, Feick et al. [12] added more flexibility to the interaction with tangible objects by introducing stretching and bending of 3D-printed objects in addition to translation and rotation. They showed that the 3D-printed proxies were quicker and more accurate in completing matching tasks, which required manipulating different parts of a proxy, compared to traditional controllers. Muender et al. [27] took a step further and compared LEGO-based proxies of virtual objects to their 3D-printed models. In the task of building and exploring virtual scenes aimed at architects, film, and theater-makers, they found that both 3D-printed and LEGO-based representation showed similar results in perceived grasping accuracy, performance, and haptic impression. Although the experts from their experiment mentioned a high benefit of the system and saw great potential for non-technical users, tangible objects have a limited precision for selection and manipulation of virtual objects, which we aim to overcome with touch input. 2.2 Touch Input for VR Content Creation Virtual content creation is often a tedious and time-consuming task. To turn this task into a more joyful activity, Billinghamst et al. [6] introduced 3D Palette, which combines pen and tablet to create virtual scenes by drawing primitives on a tablet and visualizing them in 3D space, using widgets for parameter adjustment. Many recent works used a tablet as a supporting plane for sketching in virtual reality [2, 11] or as a slicing volume for 3D data selection [37]. However, usage of a tablet in a virtual environment was not only restricted to a single touch input in sketching tasks and was recently explored as a multi-touch device for 3D modeling tasks, such as selection, position, orientation, and specifying a path [26]. In our work, we aim to build on the successful usage of touch input combined with tangible objects, which together facilitate tactile feedback and precise object manipulation. 2.3 Educational Technology for Children There is a broad body of work on educational technology for children, which includes several computational toolkits and programming environments [7, 21]. However, only a small subset of these is aimed at primary school children, despite the quick growth of the area [41]. Programming environments typically employ block-based interfaces, such as Scratch Jr. [13] and KidSim [35], tangible physical manipulatives, e.g., KIBO [36] and IoT toolkit [39], or hybrid environments [16] like Strawbies [17] in the design of these programming environments. Another group of toolkits, such as Cubelets [30], and LittleBits [3], have been increasingly popular with younger children due to the immediate sensory engagement [42], visibility, and concreteness [4]. More recent works employed VR environment to teach children programming [19, 31], however, they lack empirical evaluation with younger children and tangible interaction. Compared to previous works which focused on toolkits for learning programming, we aim to provide children an introduction to the process of creating virtual scenes in real-time without writing a code. We focus on the encouragement of children’s creative expression rather than learning a new programming environment and see it as a pre-step for programming. Perhaps the work closest to our own is CoSpaces Edu for kid-friendly 3D creation and coding \footnote{https://cospaces.io/edu/}. It uses a drag-and-drop metaphor to place 3D objects in the virtual scene using a mouse and keyboard. After creating a scene, a child can put on VR glasses to see the results of her effort in the 3D space. With this, CoSpaces requires constant switching between scene creation and seeing a result in VR, and lacks the playfulness necessary to engage children in the creative process. This is where we see a benefit of VRTangibles, which we describe in detail in the following section. 3 VRTANGIBLES VRTangibles facilitates an immersive interaction with a virtual world by allowing a user to be located in a virtual scene while creating it. It is enabled via a VR headset, a set of tangible objects, and touch input. In the following two subsections, we describe in detail both interaction concepts and the implementation of VRTangibles. 3.1 Interaction Concept From the interaction perspective, VRTangibles consists of one output (virtual environment) and two input (tangible objects and touch input) components (Figure 2). The VR headset, which users wear throughout the whole time of interaction, plays a role in the instantaneous output for the input provided by tangible objects and a tablet. Tangible objects are used to create virtual objects in the scene and can be further granularly modified using touch input. ![Figure 1: Inputs of the VRtangibles: three tangible objects on the 3D-printed platform (left) and a tablet as an interaction surface (right). The tablet is overlaid with a VR interface. The tangible objects and a tablet are tracked in the virtual space using VR trackers.](image) ### 3.1.1 Tangible Objects We employed tangible objects due to their learning benefits. As pointed by Klahr et al. [22, 23], using physical objects in a learning task might change the nature of the knowledge relative to that gained through interaction with virtual objects. Moreover, 3D shapes might ease the perception and understandability through the haptic and proprioceptive perception of tangibles compared to visual representation alone [14, 25]. Thus, we implemented the following interaction with tangible objects while creating virtual scenes. After putting a VR headset on, a user is located in a virtual world, where she can add static, e.g., trees, and dynamic objects, e.g., cars, to the virtual scene using tangible objects. A user can create a new virtual object by touching the tablet’s touch surface with a 3D-printed tangible object, e.g., an abstract tree, house, and car. For exploratory purposes, we chose these three types of tangibles to facilitate their combination into a single context of urban environment familiar to children. The initial instance of a virtual object looks like a tangible object and its properties can be modified using touch input. Virtual objects appear instantaneously after placing a tangible one on the tablet, similar to interaction paradigms in Nintendo\textsuperscript{2}, Lego Dimensions\textsuperscript{3}, and AwareKit calendaring system [24]. When placing multiple objects with the same properties on different locations, a user can use a tangible as a “stamp” and tap at multiple locations. ### 3.1.2 Touch Input The tablet’s surface is mapped to the rectangular area with red borders in VR and represents an interaction surface and employs four modes of interaction: (1) scene control, (2) object modification, (3) trajectory creation, and (4) object deletion. A user can switch between the modes by tapping soft buttons on the physical tablet, which are mapped one-to-one in VR and are placed in the corners of both physical and virtual tablets (Figure 1 right). Scene control. In the scene control mode, similarly to interaction with Google Maps\textsuperscript{4}, a user can move the virtual scene using single-finger swipe gestures or zoom in and out using two fingers. Moving the scene also allows the selection of a virtual object. The selected object is marked with a semi-transparent cube placed next to the object, which represents the middle point of the interaction area (red rectangle in the virtual scene) (Figure 3 right). To change the position of a virtual object in a scene, a user has to move the scene and change the middle point of the interaction area. Object modification and deletion. When the object is selected, a user can change its color and type by tapping on the up-down and left-right buttons respectively (object modification mode), specify a trajectory for dynamic objects by drawing a path with a finger on the touch surface (trajectory creation mode) and delete it by tapping on the delete button (object deletion mode) (Figure 1 right). Trajectory creation. We employed trajectory creation to allow the movement of virtual objects on the 2D surface. With this, we aimed to showcase one possibility to interact with dynamic elements in VR. In the trajectory mode, the object starts moving with a constant speed when a finger is released from the touch surface after drawing a trajectory. A user can start drawing a trajectory by touching anywhere on the surface. This mode also allows a simultaneous movement of multiple dynamic objects. For example, a user selects a car in the virtual scene, draws a trajectory for it and it starts moving in the scene. While the first car is moving, a user can select another car and specify a second trajectory and let the car move. One object is, however, restricted to a single trajectory. If users want to change an existing trajectory, they have to draw another trajectory for a selected object and the previous trajectory will be deleted. The trajectory is visually depicted in the scene and disappears when a dynamic object finishes the trajectory. Given that the trajectory is connected to the world, it moves together with it in the scene control mode. ![Figure 2: Study setup: a child is wearing VR glasses as an instantaneous output for the input provided by tangibles and a tablet. New virtual objects are created by placing tangibles on the tablet surface and can be modified via touch input.](image) ### 3.2 System Implementation The current implementation consists of three tangible objects and can be further extended to a higher number. Each tangible object is placed on the 3D-printed platform (H = 11 cm), which contains a 3D-printed model on the top and a VR tracker on the bottom to enable visibility of the objects in VR (Figure 1 left). VRtangibles includes three generic tangible objects: (1) a tree (H = 7 cm), (2) a house (H = 6 cm), and (3) a car (H = 3 cm). As for the VR headset, we used HTC Vive with tracking 1.0 via two HTC base stations. The VR environment is implemented using Unity SDK (2019.4.1f1) and SteamVR assets. For the tablet, we used Samsung Galaxy Note Pro (SM-P900) with a 12.2-inch display, a resolution of 2560 x 1600 pixels, and Android 5.0.2. The data communication between the tablet and the Unity environment was enabled via Wi-Fi. Similarly to tangible objects, the tablet was tracked using a VR tracker, placed on top of the tablet (Figure 1 right). The virtual surface of the tablet was mapped to the VR tracker and was aligned with its physical surface. Similarly, the bottom of the 3D platform with tangible objects was aligned with its virtual surface. The intersection of virtual surfaces between tangible objects and tablets created a point, where a virtual object is created. 4 EVALUATION We evaluated VRtangibles in the lab experiment and compared it to the state-of-the-art tool called CoSpaces Edu for kid-friendly 3D creation and coding \footnote{https://cospaces.io/edu/}, which employs keyboard and mouse interaction on the desktop and a drag-and-drop interaction concept. To this end, we recruited six children (3 male and 3 female) aged between seven and twelve (M = 9.5, SD = 1.9). One 12-years old child had previous experience with VR by trying out a demo in a shopping mall. Another 8-years old child had no previous experience with touch input devices due to parental restrictions. The rest of the children had no previous experience with VR, but use smartphones and tablets on an everyday basis. The evaluation of the system consists of two parts: (1) creation of virtual scenes based on the provided descriptions using VRtangibles and CoSpaces, and (2) free play with VRtangibles. The order of conditions with VRtangibles and CoSpaces in the experiment was counterbalanced. We began with a brief introduction of the VRtangibles and CoSpaces to help children explore and familiarize themselves with both systems. This was followed by two tasks (Figure 3) and an unstructured free play part. For the first task (static setting), children had to create a virtual scene with two houses, two trees, and one car. For the second task (dynamic setting), children had to create a virtual scene with three houses placed in the middle, two forests (with three trees each) to the left and right sides from the houses, and two cars in the front and behind the houses. After placing the cars, children had to assign driving trajectories to the cars to bring them to movement. Children had to adjust the sizes and colors, and spatially arrange the objects comparable to the placement on the picture. Given the limitation of CoSpaces to create dynamic virtual objects and VR space, with CoSpaces children performed only the task in the static setting and could see the result of their work only after the scene was created. In the case of VRtangibles, the pictures with the tasks were placed in the virtual environment to avoid switching between the virtual and real-world, while with CoSpaces the task was printed on a piece of paper and placed in front of children. After children finished both tasks, they freely explored VRtangibles to express their ideas. The study concluded with a brief semi-structured interview to help children showcase their creations and gather overall impressions. Additionally, we measured the task completion time for all the tasks, the number of times children switched between different tangibles and the task load (excluding the free play) by verbally asking them about each metric of the NASA TLX scale using language children can understand. 5 RESULTS 5.1 CoSpaces On average children spent 255 s (SD = 88) solving the task with CoSpaces and reported an average score of 20.3 for the task load. Four children have successfully solved the task and two had minor difficulties in changing the color and scaling an object, because it was complicated (P2, F, 8 years old) and not intuitive (P1, M, 10 years old). As one child mentioned, “It was easy to place a car and a house, but I forgot how to change a color.” [P1, M, 10 years old]. Additionally, two children (P2 and P5) reported problems with using a mouse, because it was new to them and they lacked experience. 5.2 VRtangibles: Static setting Solving the first task with a static setting using VRtangibles took on average 698 s (SD = 169). The task load was higher than with CoSpaces (49.7) and led to changing a type of tangibles on average 9 times. Only one participant [P2, F, 8 years old] did not finish the task, because she unintentionally removed all the objects from the scene. The rest of the children successfully solved the task and had minor deviations in the mistakes they made, e.g., changing the color or type of an object, and hitting the soft buttons on the tablet. All children, however, reported that they had fun interacting with VRtangibles. For example, P1 [M, 10 years old] mentioned: “It was so much fun. Better than an actual school”. Children mentioned that they experienced higher immersiveness in the virtual world with VRtangibles compared to CoSpaces. As P4 [F, 12 years old] commented: “It is very cool to see it before my eyes as if I were in this [virtual] world”. 5.3 VRtangibles: Dynamic setting The task in a dynamic setting was solved on average in 543 s (SD = 151). Participants reported an average task load comparable to the previous task (50.1) and changed a type of tangible on average 9 times. The same two participants (P2 and P5) who did not finish the task in the static setting had difficulties with this task and the experimenter terminated the task when no further improvements were observed. Four participants (P2, P4-P6) reported difficulties with moving and recognizing which object is currently selected. Additionally, P2 (F, 8 years old) mentioned that hair was restricting her view in the VR glasses and the VR glasses were too heavy, while P3 (F, 11 years old) forgot to make the last changes in the scene to solve the task completely. In the end, one child [P4, F, 12 years old] mentioned that she enjoyed being in the virtual world: “I enjoyed being in the world and moving it. [It is] almost like looking from outside a window.” 5.4 Free play The average duration for the free play was 257 s (SD = 108) and led to changing a type of tangible on average 5 times. All children enjoyed this task a lot and mentioned that it was fun. “Nice task! It was cool to explore new stuff.” [P5, M, 7 years old]. Although all children found interaction with mouse and keyboard easier, the free play part has demonstrated that all six children enjoyed it the most, found it more fun than CoSpaces, and felt freer to build whatever they wanted compared to the predefined tasks. Two children built new worlds, which looked like villages and cities, two other children scaled the objects to the real world sizes, and the remaining two who had most difficulties with the previous tasks used tangibles to stamp on the tablet as many objects as possible. The overview of examples from the free play is shown in Figure 4. Five (out of six) children found tangibles objects helpful in creating virtual objects because they “feel natural” [P1, P6] and “grasping physical objects feels real” [P4]. 6 DISCUSSION & FUTURE WORK We have shown that a combination of a VR headset with tangibles and touch input can successfully engage children in VR world and turn them into active creators of virtual scenes. Although children were on average quicker in creating virtual objects with mouse and keyboard, showed lower task completion times and task load index, all of them mentioned that they had more fun interacting with VRtangibles. We assume that this observation can be explained by a higher comfort interacting in the real world compared to a new virtual world, which might require a field evaluation with a longer familiarization period for children. All of our participants were new to virtual reality and some of them were feeling fatigued after wearing a VR headset for a long time. However, older children (e.g., P4, 12 years old) enjoyed a permanent presence in VR due to possible immersiveness and novelty. Only two children had difficulties understanding the interaction concepts, while the rest of the participants have successfully solved the tasks in both static and dynamic settings. Additionally, we found that children tend to switch more between tangible objects when they solve a predefined task and less when they play around and are free in their creative decisions. In this case, children might have felt less restricted in the free play and focused more on the virtual properties of the scene rather than adding new objects. We see our work as a basis for familiarization with the VR environment and an approach to include non-tech savvy users in the active creation of virtual scenes. Admittedly, the current implementation of VRtangibles is restricted to three tangible objects, which can be further extended to a larger number of smaller objects. Dynamic interaction is limited to the creation of trajectories and can be further extended to jumping and flying. We aim to further extend the idea of the proposed system by integrating tracking of children’s hands using off-the-shelf VR gloves, e.g., Sensoryx VR gloves\footnote{https://www.sensoryx.com/}, and enable the creation of virtual models by scanning children’s own toys to facilitate personalized interaction. The question we ask ourselves is whether children still need additional physical proxies to create virtual scenes or operating directly with virtual objects will suffice. In our future work, we aim to evaluate the system with groups of children to study the suitability of the approach for collaborative learning\cite{34} and communication over distance\cite{40}. 7 CONCLUSION We presented a design, implementation, and a preliminary evaluation of a system aimed at lowering the barrier of entry to primary school children’s in creating VR scenes. Our results suggest that children gained an understanding of the basics of creating virtual in a playful way and showed a high level of engagement during free play. Given the rise of VR technologies and the complexity created by devices, our “ready to use” approach focuses on exposing VR concepts in an age-appropriate modern way and without requiring computer programming knowledge. 8 ACKNOWLEDGMENTS We would like to thank all the children who participated in our study. REFERENCES [1] Jatin Anca, Aryan Saini, Nirmita Mehra, Varnit Jain, Shwetank Shrey, and Aman Parmar. 2019. Virtualubricks: Exploring a Scalable, Modular Toolkit for Enabling Physical Manipulation in VR. In Proceedings of the 2019 CHI Conference on Human Factors in Computing Systems (Glasgow, Scotland UK) (CHI ’19). Association for Computing Machinery, New York, NY, USA, 1–12. https://doi.org/10.1145/3206295.3300286 [2] Rahul Arora, Rubaia Habib Kazi, Tovi Grossman, George Fitzmaurice, and Karan Singh. 2018. SymbiosisSketch: Combining 2D 3D Sketching for Designing Detailed 3D Objects in Situ. 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LilyPad in the Wild: How Hardware’s Long Tail is Supporting New Engineering and Design Communities. In Proceedings of the 8th ACM Conference on Designing Interactive Systems (Aarhus, Denmark) (DIS ’10). Association for Computing Machinery, New York, NY, USA, 199–207. https://doi.org/10.1145/1858171.1858206 [9] Andy Cockburn and Bruce McKenzie. 2002. Evaluating the Effectiveness of Spatial Memory in 2D and 3D Physical and Virtual Environments. In Proceedings of the SIGCHI Conference on Human Factors in Computing Systems (Minneapolis, Minnesota, USA) (CHI ’02). Association for Computing Machinery, New York, NY, USA, 203–210. https://doi.org/10.1145/503576.503415 [10] J. Dourish. 2004. Where the action is: the foundations of embodied interaction. MIT press. [11] Tobias Drey, Jan Gugenheimer, Julian Karlhauer, Maximilian Milo, and Enrico Rukzio. 2020. VRSketchInk: Exploring the Design Space of Pen and Tablet Interaction for 3D Sketching in Virtual Reality. 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TabletInVR: Exploring the Design Space for Using a Multi-Touch Table in Virtual Reality. In Proceedings of the 2019 CHI Conference on Human Factors in Computing Systems (Glasgow, Scotland Uk) (CHI ’19). Association for Computing Machinery, New York, NY, USA, 1–13. https://doi.org/10.1145/3200976.3300243 [38] Gabriel Tronfi and Elaine Reese. 2009. A good story: Children with imaginary companions create richer narratives. Child development 80, 4 (2009), 1301–1313. [39] Torben Wallbaum, Swamy Ananthanarayan, Andrii Matviienko, and Susanne C.J. Boll. 2020. A Real-Time Distributed Toolkit to Ease Children’s Exploration of IoT. In Proceedings of the 11th Nordic Conference on Human-Computer Interaction: Shaping Experiences, Shaping Society (Tallinn, Estonia) (NordiCHI ’20). 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Maryvale Cre8s Paint Night—32 painters! Hooters West Phoenix — March 9, 2015 classes, so she brought friends! Right, 3 generations again—so cool to see families come together! Maryvale Cre8s Paint Night—32 painters! Hooters West Phoenix — March 9, 2015 On the left—a couple young families—kids enjoy too! On right—the smile says, I will be back!	<urn:uuid:b3ff213f-e3dd-4846-a6df-713ee32de151>	CC-MAIN-2017-34	http://maryvalerevitalization.com/wp-content/uploads/2006/08/March-Paint-Night.pdf	2017-08-18T21:51:24Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-34/segments/1502886105187.53/warc/CC-MAIN-20170818213959-20170818233959-00225.warc.gz	261,067,183	95	eng_Latn	eng_Latn	0.992	eng_Latn	0.989646	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 177, 349 ]
Ultimate Fitness Specials Assess Your Imbalances Get a new Work out Program Empty Studio Special When our regularly scheduled clients are gone we have empty spots to fill! ½ hour training sessions 4 for $100	<urn:uuid:0efb77cb-53ab-4b43-8608-5e9763407984>	CC-MAIN-2017-34	http://www.ultimatefitnessor.com/wp-content/uploads/Ultimate-Fitness-Specials-1-2.pdf	2017-08-21T15:32:32Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-34/segments/1502886109157.57/warc/CC-MAIN-20170821152953-20170821172953-00075.warc.gz	691,375,961	47	eng_Latn	eng_Latn	0.997733	eng_Latn	0.997733	[ "eng_Latn" ]	false	rolmOCR	[ 211 ]
RARE & PRESTIGIOUS COLLECTION Malt Whisky Ardbeg AURIVERDES (Limited Edition) £18.00 49.9% Islay, distillery committee bottling The whisky of GOLD (auri) in an unmistakable GREEN (verde) bottle uses TOASTED cask lids to create Mocha Coffee flavours that team up with creamy vanilla –it's a dram of TWO HALVES. Balvenie Portwood 21yrs £15.0046.0% Speyside, distillery bottling Jammy fruity expression from Balvenie Ben Nevis 1991 23yrs £15.0056.3% Highlands, Signatory bottling You don't see much well-aged Ben Nevis, but thankfully Signatory have some stocks. This 1991 vintage was aged in a sherry butt for 23 years, picking up a lot of colour as well as dried fruit and chocolate flavours. Dalwhinnie 25yrs £25.00 52.1% Highlands, distillery bottling Quite spicy with some good sticky fruit and general sweetness, as well as not falling in to the trap of being too woody. Glenlivet 1981 33yrs £30.0051.0% Speyside, Signatory bottling for The Whisky Exchange The classic fruity Glenlivet character runs through the dram, with the cask adding gentle spice and rich, rounded sweetness. An excellent whisky. Glen keith 1968 Connoisseurs Choice £26.0046.0% Speyside, Gordon & Macphail Top quality aged expression Isle of Jura Tastival (Limited Edition) £11.0044.0% Islands, distillery bottling Rich Amber in colour, on the nose Rhubarb and Custard (boiled sweets), Marmalade, Freshly baked bread and Manuka honey, finishes in palate with Wine Gums, liquorice allsorts and Ginger bread Kilchoman Loch Gorm 2014 £11.0046.0% Islay, distillery bottling The second annual release of Loch Gorm, Kilchoman's sherry-cask-matured expression. Building on the previous release, this edition has some spirit matured in sherry hogsheads, as well as the usual oloroso butts. Bottled at around five years of age, it's an intensely smoky and sherried whisky, but carefully balances the peat and fruit. Knockando 1985 25yrs Old (special Release 2011) £30.0043.0% Speyside, distillery bottling From first fill ex-sherry European Oak Casks, A most unusual, richly flavoured expression. Littlemill 1991 21yrs £16.00 50.0% Lowland, The OldMalt Cask From the sadly-defunct Lowland distillery Littlemill (demolished in the 1990s) Macallan 18yrs Sherry Oak £22.0043.0% Speyside, distillery bottling This benchmark Macallan has been fully matured in ex-sherry casks and remains one of the most highly-regarded after-dinner drams thanks to its slick, sweet smoothness. Super sweet and lingering on the palate. Macallan Rare Cask £22.0043.0% It is comprised of 16 different sherry-cask styles.Rich and complex with notes of dark honey and dried fruit All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. There will be an optional service charge of 12.5% on all table service and all prices are inclusive of V.A.T. There is a minimum spend of £10.00 on any debit or credit card payments. Old Pulteney 21yrs £10.50 Highlands, distillery bottling Apple, butterscotch, Malted Milk biscuits, bananas and a little bit of lime. Port Ellen 26yrs 1983 (Limited Edition) £50.50 Islay, Duglas McGibbon bottling A perfect Legendary whisky from a Closed Islay Distillery. Rosebank 21yrs 1990 (Special Release 2011) 46.0% 46.0% £25.0053.8% Lowlands, Distillery bottling A Closed Distillery from Lowlands. Oldest stocks now held by the original distillers charming whisky whose attractive citric notes suggest a feminine elegance, and whose subtleties are best revealed with water. Fresh and clean excellent shared as an aperitif. Talisker 25yrs Bottled 2009 (Limited Edition) £30.0054.8% Isle of Skye, distillery bottling Pungent aroma, peppery flavour and big finish. SINGLE BLEND WHISKY Lochside 46 yrs £30.00 42.1% Highlands, The whisky Exchange Unusually, the whisky was blended before ageing, with the mix of grain and malt maturing in the same cask for 46 years. A very rare style from this now closed distillery. BLENDED MALT Johnnie Walker Odyssey £74.5040.0% An incredible decanter for a special edition blended malt entry into the Johnnie Walker range - The John Walker & Sons Odyssey. It's blended from whisky from just three distilleries and presented in a self-righting frame, just the thing they'll need on The John Walker & Sons Voyager, the company's yacht that is travelling the world in the wake of the whisky. JAPANESE Suntory Yamazaki 12yrs £10.0043.0% Sweet vanilla and fruity notes derived from white oak casks are accented with fine aromas of spirits aged in sherry and Japanese oak casks Suntory Yamazaki 18yrs £26.0043.0% Extremely smooth, with Characteristic sweetness of dried fruits and aromatic chocolate that comes from sherry casks Karuizawa 31yrs £65.0060.6% An intense and impressive 31 year old whisky from closed Karuizawa, bottled specially for The Whisky Exchange. Matured in a sherry cask this has picked up an incredible intensity of flavour. Malt Whisky Price ABV % Salt Whisky bar Single Malt 16Yrs £8.0047.8% Balblair 2005 £4.50 46.0% Highland, distillery bottling All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. There will be an optional service charge of 12.5% on all table service and all prices are inclusive of V.A.T. There is a minimum spend of £10.00 on any debit or credit card payments. The Three Wood Cask Married to a Solero Vat, made with Oregon pine. Excellent Balance!! Balanced combination of ripe fruits, citrus, vanilla and hints of spices Islay, distillery bottling Oaky and bittersweet with black pepper, toffee apples, dark chocolate, aniseed and warm, spicy peat. Very complex, with a development of star anise. All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. There will be an optional service charge of 12.5% on all table service and all prices are inclusive of V.A.T. There is a minimum spend of £10.00 on any debit or credit card payments. Knockando 12yrs Old £4.5040.0% Speyside, distillery bottling oakspice on the palate. All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. There will be an optional service charge of 12.5% on all table service and all prices are inclusive of V.A.T. There is a minimum spend of £10.00 on any debit or credit card payments. Royal Brakla 12 yrs £5.50 A real charmer, this is a great introductory malt. All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. 40.0% All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. FRENCH Armorik Double Maturation £5.0046.0% Finished in rum casks and bottled at 46% without chill-filtration, it's an excellent statement of intent. The blend is said to contain a high proportion of first-fill bourbon cask whiskey, and a higher-than-normal ratio of malt to grain. Yellow Spot Single Pot Still 12yr old £8.0046.0% A second entry into the 'Spot' range, aged for 12 years and made up in part from spirit matured in malaga casks for a sweet and moreish dram. AMERICAN Bakers 7yrs £5.0053.5% It is a powerful small-batch bourbon, which utilises a special kind of yeast for extra All the Whiskies are priced at 25ml measures, all other spirits priced at 25ml & 50ml measure. There will be an optional service charge of 12.5% on all table service and all prices are inclusive of V.A.T. There is a minimum spend of £10.00 on any debit or credit card payments. JAPANESE Suntory Hakushu Distillers Reserve £6.0043.0% A green and crunchy entry in the Hakushu Range, combining whisky of a wide variety of ages, from across the range of casks used by the distillery to create a gently smoky dram, packed with fruity flavour. Suntory Hibiki Harmony (Blended) £8.0043.0% A fruity bouquet, followed by sweet honey and custard cream. The artistry of blending combined with bamboo charcoal filtering makes this whisky silky smooth to the palate. Suntory Yamazaki Distillers Reserve (Single Malt) £6.0043.0% A fresh and fruity whisky from Yamazaki, full of red fruit and a touch of sherry cask. It's also got some mizunara (Japanese oak) matured whisky in the mix, which comes through as a complex spicy and almost incense-like note. A well put together and deep dram. TAIWANESE KAVALAN CONCERTMASTER £9.00 40.0% A port-finished whisky from Taiwan's Kavalan, marrying their fruity young whisky with extra maturation in wine casks to create a balance of rich and fresh flavours. KAVALAN SINGLE MALT £9.0040.0% It is full flavoured whisky, concentrating on their signature flavours of tropical fruit. KAVALAN Solist (Sherry) £19.0045.0% A whisky matured in Fino sherry casks, rather than the more usual darker sherry styles. 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What Makes Love Happy Text: I Corinthians 12 If I speak in the tongues of men and of angels, but have not love, I am a noisy gong or a clanging cymbal. And if I have prophetic powers, and understand all mysteries and all knowledge, and if I have all faith, so as to remove mountains, but have not love, I am nothing. If I give away all I have, and if I deliver up my body to be burned, but have not love, I gain nothing. Love is patient and kind; love does not envy or boast; it is not arrogant or rude. It does not insist on its own way; it is not irritable or resentful; it does not rejoice at wrongdoing, but rejoices with the truth. Love bears all things, believes all things, hopes all things, endures all things. Love never ends. As for prophecies, they will pass away; as for tongues, they will cease; as for knowledge, it will pass away. For we know in part and we prophesy in part, but when the perfect comes, the partial will pass away. When I was a child, I spoke like a child, I thought like a child, I reasoned like a child. When I became a man, I gave up childish ways. For now we see in a mirror dimly, but then face to face. Now I know in part; then I shall know fully, even as I have been fully known. So now faith, hope, and love abide, these three; but the greatest of these is love. Introduction: We are making our way slowly and carefully through Paul's definition of love in I Corinthians 13: 4-8. We are taking the time to carefully examine each of the fifteen verbs that he uses to describe how love acts. We have examined love's two principal characteristics; it is patient and kind, and we have looked at the seven things that love doesn't do. Now we are going to consider love's joy. In one short verse we are told that love does not rejoice in wrongdoing, but rejoices in the truth. You can tell a lot about a person by the things which make him happy. Our joy reveals the condition of our heart. A heart in tune with the heart of God will take joy in the things that give joy to God and be grieved by the things that grieve the heart of God. Since love is, as we have seen, a divine gift that reflects the very nature of God, it can take pleasure in nothing that is contrary to God. Rejoicing for the right reasons is a sure sign that the love of God is being perfected in us. To help us feel the impact of this verse as we should, I want first to look at what it means by the words "wrongdoing", and "truth", and then to look at some biblical examples of this principle in action. I. Wrongdoing and Truth The clearest translation of the word that the ESV translates "wrongdoing" and the KJV translates "iniquity" would be "unrighteousness". It is formed in exactly the same way that the word "unrighteousness" is formed in English by adding a privative prefix to a positive noun. Righteousness in the Bible is that which conforms to the character of God. "God is Light and in him is no darkness at all" (I John 1:5). Sin, or unrighteousness, is that which does not conform to the holy character of God. This is the reason that when Jesus, who is the "Light that lights every man by his coming into the world" (John 1:9) came into the world he was rejected, and became the source of condemnation for those who rejected him. He says in John 3:19-21: And this is the judgment: the light has come into the world, and people loved the darkness rather than the light because their works were evil. For everyone who does wicked things hates the light and does not come to the light, lest his works should be exposed. But whoever does what is true comes to the light, so that it may be clearly seen that his works have been carried out in God." Notice how, in this passage, truth and wickedness are contrasted. Jesus, who is the light, that is God-incarnate, hence, righteousness incarnate, comes into the world, but men do not rejoice at his coming. In fact, the majority rejects him, and wants nothing to do with him. Why? Because, as Jesus says here, their works are evil. Evil men do not rejoice in the truth, but rejoice in unrighteousness. Therefore, instead of coming to the Light which reveals their wickedness and brings salvation from it, they flee from it least their deeds should be revealed for what they are. The person who loves and does the truth, on the other hand loves the Light, Christ. He comes to him he rejoices in him. This is the reason that in the Gospels, from the time Christ is first born, the characteristic reaction of all those who recognize him is joy. So when Paul says that love "rejoices in the truth", he is not thinking of the truth as an abstraction, but as the concrete reality that has been revealed in Jesus Christ. He sums up his understanding of the truth in Ephesians 4:21 where he says simply: "the truth is in Jesus". This truth, when it is embraced, produces righteous behavior. This is the reason the Scriptures do not speak of just knowing the truth or believing the truth but of doing the truth. On the other hand, all that is contrary to this truth that has been revealed in Jesus Christ is unrighteousness. It is contrary to God and to his kingdom. It is darkness and destruction and could never be a source of joy for anyone who has embraced the gospel, who has come to the Light, who has become a follower of Jesus Christ. II. Biblical Examples In order to implant this picture of love's joy in our hearts let us look at some biblical examples both negative and positive. First we will look at a couple of negative examples of the wicked rejoicing at unrighteousness, and then we will see some positive examples of love rejoicing in the truth. For a first example consider these verses from Psalm 10:1-7: Why standest thou afar off, O LORD? why hidest thou thyself in times of trouble? The wicked in his pride doth persecute the poor: let them be taken in the devices that they have imagined. For the wicked boasteth of his heart's desire, and blesseth the covetous, whom the LORD abhorreth. The wicked, through the pride of his countenance, will not seek after God: God is not in all his thoughts. His ways are always grievous; thy judgments are far above out of his sight: as for all his enemies, he puffeth at them. He hath said in his heart, I shall not be moved: for I shall never be in adversity. His mouth is full of cursing and deceit and fraud: under his tongue is mischief and vanity. This passage illustrates precisely what Paul is saying in Romans 1:32, where after describing sinful humans in vivid terms mostly drawn from the Old Testament he concludes his description with these words: "Who knowing the judgment of God, that they which commit such things are worthy of death, not only do the same, but have pleasure in them that do them." This principle is confirmed in our own time by common topics of conversation and the subjects of entertainment. The things that people do, the things that they discuss in their leisure time, the books they read, the movies they watch all tend to confirm that hearts devoid of divine love rejoice in iniquity. This is the reason Paul tells believers in Romans 12:9 to "abhor that which is evil; cleave to that which is good". For a second example of "rejoicing in wrongdoing" consider this passage from Luke's account of the betrayal of Jesus: "And the chief priests and scribes sought how they might kill him; for they feared the people. Then entered Satan into Judas surnamed Iscariot, being of the number of the twelve. And he went his way, and communed with the chief priests and captains, how he might betray him unto them. And they were glad, and covenanted to give him money" (Luke 22:2-5). The officials who were conspiring against Jesus were on the verge of committing history's most evil deed, and when they find a co-conspirator in Judas Iscariot, one of Jesus' disciples, they rejoice. Their hearts devoid of grace and divine goodness are filled with joy at the prospect of extinguishing the light that has revealed the corruptness of their hearts. It is with delight that they seal their heinous deal with Judas. Let us now look at a couple of examples of rejoicing in the truth. When Paul founded the church in Thessalonica, he was forced to leave after having spent only a very short time with them. Worried that lack of teaching and encouragement for these new believers might have stunted their progress in the faith and their growth in righteousness and love, he sends Timothy to check on them. Timothy brings back a good report and in response Paul writes the letter that we call I Thessalonians. In that letter he writes: For this reason, when I could bear it no longer, I sent to learn about your faith, for fear that somehow the tempter had tempted you and our labor would be in vain. But now that Timothy has come to us from you, and has brought us the good news of your faith and love and reported that you always remember us kindly and long to see us, as we long to see you-- for this reason, brothers, in all our distress and affliction we have been comforted about you through your faith. For now we live, if you are standing fast in the Lord. For what thanksgiving can we return to God for you, for all the joy that we feel for your sake before our God, as we pray most earnestly night and day that we may see you face to face and supply what is lacking in your faith? (I Thessalonians 3:510). For our final example consider the Apostle John. He has been rightly called the "Apostle of Love". Perhaps as no one else before or since he understood the love of God manifested in Jesus Christ and the joy that that love brings when it is experienced and lived out. It is John who records Jesus' new commandment: "love one another as I have loved you". It is that commandment that summarizes Christian live and action for John. The story is told that he spoke his last words as a very old man, when unable to walk he was carried into the assembly, and there seated in the midst of his beloved brothers and sisters in Christ he repeated three times "love one another". So what was the deepest joy of the Apostle of Love? He tells us twice; once in his second letter and again in the third: "I have no greater joy than to hear that my children walk in truth". 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CITY OF SANTA BARBARA REGULAR MEETING PARKS AND RECREATION COMMISSION Wednesday April 24, 2019 4:00 p.m. City Council Chamber City Hall - 735 Anacapa Street MEETING AGENDA CALL TO ORDER PLEDGE OF ALLEGIANCE ROLL CALL CHANGES TO THE AGENDA WRITTEN COMMUNICATIONS PUBLIC COMMENT Any member of the public may address the Commission for up to two minutes on any subject within the jurisdiction of the Commission that is not scheduled for a public discussion before the Commission. The total amount of time for public comments will be 15 minutes. YOUTH COUNCIL REPORT COMMISSIONER COMMITTEE ASSIGNMENT REPORTS COMMISSION AND STAFF COMMUNICATIONS CEREMONIAL ITEMS CONSENT ITEMS 1. Subject: Employee Recognition – Service Award Pins 2. Subject: Summary of Council Actions – For Information (Attachment) 3. Subject: Minutes – For Action (Attachment) Recommendation: That the Commission waive the reading and approve the minutes of the Regular Meeting of March 27, 2019. STREET TREE ADVISORY COMMITTEE ITEMS Any action of the Parks and Recreation Commission made pursuant to Santa Barbara Municipal Code (SBMC) Chapter 15.20, Tree Planting and Maintenance or SBMC Chapter 15.24, Preservation of Trees, may be appealed to the City Council within ten days, pursuant to provisions of Section 1.30.050 of the Municipal Code. 4. Subject: Street Tree Advisory Committee Recommendations – For Action (Attachments) Recommendation: That the Commission: A. Approve the following Street Tree removal requests with conditions: 1. 1030 Calle Malaga – Pinus canariensis, Canary Island Pine – Richard Elliot B. Approve the following Setback Tree removal requests with conditions: 1. 1318 Carpinteria St. – (1) Albizia Spp, Mimosa, (1) Afrocarpus gracilior, African Fern Pine – Arelhy Arroyo Alvarez C. Deny the following Setback Tree removal request: 1. 2131 Red Rose Way – Araucaria heterophylla, Norfolk Island Pine – Karen and Byron Blanco D. Deny the following changes to the Street Tree Master Plan: 1. 400 block of Alan Rd. – consider King Palm trees as co-designation – Sean Shahrouzi ADMINISTRATIVE AND STAFF REPORTS 5. Subject: Director's Report – For Information (Attachment) Recommendation: That the Commission receive a presentation on the status of the various Parks and Recreation Department initiatives and activities. 6. Subject: Parks and Recreation Recommended Fiscal Year 2020-21 Budget – For Action (Attachment) Recommendation: That the Commission recommend City Council approval of the Recommended Fiscal Years 2020 and 2021 Parks and Recreation Department Budget, including the General Fund, Creeks Fund, Golf Fund, Capital Program, and Fees and Charges Schedule. 7. Subject: Park Safety Update – For Information (Attachment) Recommendation: That the Commission receive an update on public use and misuse issues at City parks and recreation facilities. OLD BUSINESS NEW BUSINESS ADJOURNMENT REPORTS: Copies of documents relating to agenda items are available for review at the Central Library at 40 E. Anapamu Street, Parks and Recreation Administrative Office at 620 Laguna Street, or online at the City's website (http://www.SantaBarbaraCA.gov). Materials related to an item on this agenda submitted to the Parks and Recreation Commission after distribution of the agenda packet are available for public inspection in the Parks and Recreation Department located at 620 Laguna Street, during normal business hours. AMERICANS WITH DISABILITIES ACT: In compliance with the Americans with Disabilities Act, if you need auxiliary aids or services or staff assistance to attend or participate in this meeting, please contact Rose Nevarez, 564-5430. If possible, notification at least 48 hours prior to the meeting will usually enable the City to make reasonable arrangements. Specialized services, such as sign language interpretation or documents in Braille, may require additional lead time to arrange. TELEVISION COVERAGE: Each regular Parks and Recreation Commission meeting is broadcast live in English on Channel 18, and rebroadcast in its entirety the Friday immediately following the meeting at 6:00 p.m. and the Sunday immediately following the meeting at 9:00 a.m. ANNOUNCEMENT Next regular meeting: City Hall Council Chamber Wednesday, May 22, 2019, 4:00 p.m.	<urn:uuid:f83ea734-d09c-47b5-8035-b9f654080cbd>	CC-MAIN-2019-35	https://www.santabarbaraca.gov/SBdocuments/Advisory_Groups/Park_and_Recreation_Commissions/Archive/2019_Archives/02_Agendas/2019-04-24_April%2024%202019%20Regular%20Meeting%20Agenda.pdf	2019-08-25T00:57:24Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-35/segments/1566027322160.92/warc/CC-MAIN-20190825000550-20190825022550-00328.warc.gz	970,438,766	962	eng_Latn	eng_Latn	0.881646	eng_Latn	0.942586	[ "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 744, 2442, 4311 ]
Applicant Information KEMPSEY SHIRE COUNCIL Thank you for your enquiry regarding a position advertised by Kempsey Shire Council. The Council is an equal opportunity employer and uses merit-based selection techniques. Please read these notes carefully as they are designed to help you understand Kempsey Shire Council's selection process and to put forward your best case for appointment. Kempsey Shire Council chooses the applicant who best meets the selection criteria for the position. You will find these selection criteria in the advertised position description. The Position Description Before a position is advertised, Council staff analyse the requirements of that position. They then develop a list of duties and the selection criteria (qualities to perform the job). This information is used in the Position Description. If you require further information on the position, a contact is listed in the advertisement. The position description will give you all the details and an idea of whether you have the essential requirements to perform the role, and whether the job is what you are looking for. It details the necessary skills, abilities, experience and qualifications Council is looking for. This detail forms the basis of the Selection Criteria. The role description can be downloaded from the website or you can call Council on (02) 65663200 to request it. As stated above, our selection process is based on an assessment of the relative merit of each candidate. We do this by examining how well your knowledge, skills and abilities meet each of the selection criteria in the advertised position description. As the first stage of the selection process is based on your written application, it is important that you provide the panel with information that shows how you satisfy the selection criteria. Should you be selected for interview, a panel of people (2 or 3) will be responsible for selecting the successful applicant. Your Application Although there is no right or wrong way to format your written application, you must address each selection criteria. Also, please include a current Resume/ CV. To be considered for the position, you must address all ideal criteria. Short listing (or selection for interviews) is based on how well your knowledge, skills and abilities meet the selection criteria. Write your application so that the selection panel can fully appreciate your capabilities against each selection criterion. As an applicant it is your responsibility to demonstrate to the panel how you meet the selection criteria. The following information is required as part of your application: o Statements that fully describe how you consider yourself suitable against each of the selection criterion. Do not simply state that you meet the selection criteria, but give examples or evidence which demonstrates how you have met them. o Maybe you have transferable skills, ability or knowledge in areas relevant to the selection criteria but these skills, ability or knowledge have been developed outside the workplace. If so, you should include them as evidence of your capacity to meet the criteria, eg leadership, organising, coordinating role in a community group, etc. o A Curriculum Vitae or Resume containing contact information (full name, address and telephone contact number) and a summary of your work experience. The summary should include where you have worked, positions held, period of employment and brief details of duties performed. o The names, position titles, addresses and telephone numbers of at least two work related referees who could provide comments against the selection criteria. o Any other relevant information. In your application you should: o Give complete information. Your application is a tool to sell yourself and is the first step in gaining an interview. Supply as much detail as is necessary to fully explain your capabilities. o Be clear and concise; o Be positive in the language you use. If you have been responsible for something, use active language (e.g. I implemented.....) rather than passive language (e.g. A system was implemented.....) or a plural (e.g. We implemented.....) o Supply examples and figures to support your case (e.g. numbers of staff supervised; examples of suggestions which have been implemented, etc.) o Supply a business hours contact phone number Please do not: o Be long winded or pad your application with irrelevant information. o Overstate your case. As part of the selection process, the panel may contact your referees. o Include original documents, eg references, certificates, etc. or folders Above all, remember that the selection process is competitive. Ensure that your application addresses the selection criteria, is well presented and clear. Applying for a Position Step 1: Assess your eligibility and suitability for the position Before you apply for a position, assess your eligibility and suitably by carefully reading the advertisement and position description. Download the position description and this job application information. Step 2: Apply online To apply for a position, you need to fill in an online application. You will need to complete your application in one sitting as you will not be able to save the application or return to it at a later date. Before commencing, read through the online application questions and check what information is required to be attached. Complete online questions The online application will ask you questions about your qualifications, experience and other key requirements of the position. Your responses to these questions will help determine which applicants progress to the interview stage. Please contact the person nominated in the advertisement or the HR Team if advice or assistance is needed in completing your application. Attach your Resume and other information Generally, after completing the online application questions, you will be asked to attach your Resume or other supporting material to complete your application. Note: All applications received will become the property of the Kempsey Shire Council. Applications will be retained on file and remain confidential and will not be distributed to any third party. Kempsey Shire Council may contact applicants on file to advise them of other opportunities in the organisation that may suit their experience and qualifications. Should you not have access to the internet for the on-line application process you can mail your application. Please ensure that your application and attachments are securely held together and; Address your written application to: PRIVATE AND CONFIDENTIAL TEAM LEADER HUMAN RESOURCES KEMPSEY SHIRE COUNCIL PO BOX 3078 WEST KEMPSEY NSW 2440 Please note: It is essential that you clearly identify the Position Title and Position Number as quoted in the advertisement. Please make mention of where the advertisement was sighted (e.g. Macleay Argus, Seek, Job Search Kempsey Shire Council Website) Step 3: Acknowledgement of your application Applications received through the on-line application process will receive an email of receipt of application, immediately. Applications received through the mail will be acknowledged by letter or email within 10 days, where appropriate, after the closing date. Late Applications Where a closing date is advised applicants are responsible for ensuring they meet the closing date. The closing date, where appropriate, appears in the position vacant advertisement. Applications received after the closing date will only be accepted in exceptional circumstances. The onus of proof regarding reasons why the closing date was not met will be on the applicant. Late applications will only be considered up to the close of Short listing and in all cases the selection panel will assess each late application on its merits and the panel's decision will be final. The Interview Applicants are selected for interview based on the strength of their responses to the questions in the online application as well as their relevant knowledge and experience outlined in their resume and/or cover letter. If you are shortlisted for an interview, you will be contacted by email, where you can make a selection of a suitable time on the nominated date. A confirmation email will then be provided advising of the interview date, time and venue. If you are not selected for an interview, you will be advised by email as soon as possible after the shortlisting process has been completed (usually within 2 weeks of the closing date for the position). The Selection Panel will endeavour to meet any special requirement(s) you may have to be able to attend the interview. Examples of special requirements may include wheel chair access or communication assistance. Please inform the Human Resources Unit - telephone (02) 6566 3326. All interviewees will be asked the same set of questions. These questions will have been developed by the selection panel to assess how well you match the selection criteria. Mostly you will be asked two types of questions: behavioural and situational. Behavioural questions ask for examples of how you have handled certain situations in the past. Situational questions, on the other hand, focus on how you would handle a particular situation or part of the job. We suggest that you give some thought to the type of questions that you might be asked and also to answers that directly reflect your capabilities. Other Selection Techniques - in certain circumstances, applicants may be asked to provide examples of previous work. Appropriate tests, structured group and individual exercises may also be elements of the selection process. Reference Checks These are carried out only for the interviewee(s) with the strongest overall performances at interview. Where possible, the selection panel will obtain this information from either your present or most recent referees. Pre Employment As part of Council's Work Health and Safety Policy short listed applicants who progress to the next stage will be contacted by telephone and requested to attend a pre employment medical at Council's expense. A "Working with Children Check" may be required for some positions. Notification of Appointment As soon as possible, usually within five (5) days following confirmation of the selection decision. Then all other interviewed applicants are notified of the decision within fourteen (10) working days of the selection decision. Conclusion Hopefully you will have found this information useful in preparing your application. However, if you need more information or clarification on any part of this information, please phone the Human Resources Unit on 02 6566 3326.	<urn:uuid:d630baa7-4136-43dc-9486-676da66d4ada>	CC-MAIN-2018-34	https://candidate-office-paperclip-production.s3-ap-southeast-1.amazonaws.com/files/attachments/0333/6844/REC009_Job_Application_Information_V3.pdf?X-Amz-Algorithm=AWS4-HMAC-SHA256&X-Amz-Credential=AKIAJCZ6JWCHVDSOUUWA%2F20180814%2Fap-southeast-1%2Fs3%2Faws4_request&X-Amz-Date=20180814T140913Z&X-Amz-Expires=3600&X-Amz-SignedHeaders=host&X-Amz-Signature=031267620a21563a4a917271476bed22097897c16bf30c3fea7650b0a1925b8c	2018-08-14T14:09:18Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-34/segments/1534221209040.29/warc/CC-MAIN-20180814131141-20180814151141-00335.warc.gz	664,265,302	2,004	eng_Latn	eng_Latn	0.996343	eng_Latn	0.996798	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 3499, 6262, 9341, 10751 ]
DERIVATIVES AND FRÉCHET DIFFERENTIALS MAX A. ZORN 1. Generalities. A function $f(x)$, defined on an open set $S$ of a complex Banach space $X$, with values in a complex Banach space $Y$, is said to have a Fréchet differential at a point $x_0$ of $S$ if for $x = x_0$ the following conditions (G), (D), and (P) are satisfied: (G) The limit $\lim_{\xi \to 0} [f(x + \xi h) - f(x)]/\xi = \delta_x f = \delta f(x, h)$ exists for all $h$ in $X$; (D) this limit is a continuous linear function of $h$; (P) the Gâteaux differential $\delta f(x, h)$ is a principal part of the increment, that is, $[f(x + h) - f(x)] - \delta f(x, h) = o(\\|h\\|)$. We say that $f(x)$ is $F$-differentiable on $S$ if these conditions hold at every point of $S$; if the condition (G) is satisfied for every point in $S$ we call the function $G$-differentiable on $S$. The reader will find in [2] or [6] a proof to the effect that a function which is $G$-differentiable on $S$—or indeed on more general sets—leads to a function $\delta f(x, h)$ which is linear, in the algebraic sense, with respect to $h$. We may thus replace the condition (D) by the requirement that the Gâteaux differential be continuous with respect to the argument $h$, which in turn is equivalent to $\delta f(x, h)$ being $O(1)$, $o(1)$ or $O(\\|h\\|)$ as $\\|h\\|$ tends to zero. Our main purpose is to show that (P) is satisfied automatically if (G) and (D) hold on $S$, giving a new answer to the question: under which conditions is a $G$-differentiable function $F$-differentiable? Previous solutions of this problem have been of two kinds. The first kind operates with topological conditions on the function $f(x)$, like continuity (see [4]), local boundedness (see [2]), or essential continuity (see [6]). The most general characterization theorem of this type seems to be the following: Let $f(x)$ be $G$-differentiable on the connected open set $S$, and bounded on a set $V - M$, where $V$ is a nonvoid open subset of $S$ and $M$ is such that the whole space $X$ is not the sum of a countable number of homothetic images $\alpha_n M + a_n$ of $M$; under these conditions the function $f(x)$ is $F$-differentiable on $S$ (see [7]). A solution of the second kind may be abstracted from [2] or [6]: if the higher differentials $\delta^n f(x; h_1, \cdots, h_n)$ are continuous functions of their $h$-arguments for one value $x_0$ of $x$, then $f(x)$ will be $F$-differentiable on a suitable neighborhood of $x_0$. The two kinds of characterizations are rather different; the first type refers to the behaviour Received by the editors September 4, 1945. 1 Numbers in brackets refer to the references cited at the end of the paper.	<urn:uuid:86323fa0-2b7e-433b-8e71-e5c0187ad5b0>	CC-MAIN-2023-40	https://projecteuclid.org/JournalArticle/PreviewFirstPage?urlid=bams%2F1183507701	2023-09-25T09:47:36+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-40/subset=warc/part-00143-7aa0a1e5-33a6-434b-89a2-950f294b40c1.c000.gz.parquet	519,212,163	784	eng_Latn	eng_Latn	0.994319	eng_Latn	0.994319	[ "eng_Latn" ]	false	docling	[ 2683 ]
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION AUDRY KING,) ) Plaintiff,) ) vs. ) CIVIL ACTION NO. 11-0480-KD-C ) BISHOP STATE COMMUNITY COLLEGE and DEPARTMENT OF POST-SECONDARY EDUCATION, ) ) ) ) Defendants.) ORDER The action is before the Court on transfer from the docket of Magistrate Judge William E. Cassady (doc. 12). Accordingly, the Rule 16(b) Scheduling Order heretofore entered (doc. 8), is amended as follows: 8. FINAL PRETRIAL CONFERENCE. This jury action shall be pretried by the undersigned on December 13, 2012 at 10:30 a.m., in Room 508, United States Courthouse, 113 St. Joseph St., Mobile, Alabama. Requests for extending the convening of the pretrial conference will be granted only if good cause for the extension has been exhibited. A COPY OF JUDGE DuBOSE'S STANDING ORDER GOVERNING HER FINAL PRETRIAL CONFERENCE IS ATTACHED. NO ADDITIONAL NOTICES REGARDING THE FINAL PRETRIAL CONFERENCE WILL BE NECESSARY. All other provisions and deadlines remain in effect. DONE and ORDERED this the 16th day of February, 2012. s/ Kristi K. DuBose KRISTI K. DuBOSE UNITED STATES DISTRICT JUDGE Dockets.Justia.com	<urn:uuid:fcfac39c-ec0f-496b-9577-c4f987cce23a>	CC-MAIN-2018-34	https://cases.justia.com/federal/district-courts/alabama/alsdce/1:2011cv00480/50444/13/0.pdf	2018-08-16T04:30:59Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-34/segments/1534221210413.14/warc/CC-MAIN-20180816034902-20180816054902-00270.warc.gz	658,053,183	325	eng_Latn	eng_Latn	0.910595	eng_Latn	0.910595	[ "eng_Latn" ]	false	rolmOCR	[ 1186 ]
HOLLYWOOD CASINO AT CHARLES TOWN RACES - March 19, 2013 - Race 5 FOR ACCREDITED WEST VIRGINIA-BRED MAIDENS, FILLIES AND MARES FOUR YEARS OLD AND UPWARD. Weight, 122 MAIDEN CLAIMING - Thoroughbred lbs. Claiming Price $10,000, For Each $1,000 To $8,000 1 lb. (S) Claiming Price: $10,000 - $8,000 Purse: Four And One Half Furlongs On The Dirt Track Record: (Immortal Eyes - 50.09 - April 16, 2011) Available Money: $15,000 Value of Race: $15,000 1st $9,000, 2nd $3,000, 3rd $1,500, 4th $750, 5th $450, 6th $300 Weather: Clear Track: Fast Off at: 9:05 Start: Good for all $15,000 Fractional Times: 22.23 47.31 Final Time: 54.07 Split Times: (25:08) (6:76) Run-Up: 10 feet Winner: Little Madison, Dark Bay or Brown Filly, by Scrimshaw out of She's a Warrior, by Crafty Friend. Foaled Apr 01, 2009 in West Virginia. Willie (Mike) Bradley. Winning Owner: Phyllis M. Susini LLC Breeder: Claiming Prices: 4 - Little Madison: $10,000; 7 - Grecian Lyric: $8,000; 5 - Prospective Peace: $10,000; 2 - Prized Storm: $8,000; 3 - Run Lucy: $10,000; 6 - Red Bop Road: $10,000; 1 - Slew's First Lady: $10,000; Total WPS Pool: Pgm Horse $32,313 Past Performance Running Line Preview Trainers: 4 - Contreras, Javier; 7 - Harper, Jack; 5 - Stehr, Joseph; 2 - Shawyer, James; 3 - Atkins, Michael; 6 - Cramer, Jeffrey; 1 - Reightler, Sr., Jeffery Owners: 4 - Phyllis M. Susini LLC; 7 - Hasty Rebel Stables; 5 -Tabitha M. Wilhelm; 2 -James W. Shawyer; 3 -Michael G. Atkins; 6 -Jeffrey D. Cramer; 1 -Audrey Reightler; Footnotes LITTLE MADISON chased the early pace about the three path, dug in from the head of the lane to take over inside the sixteenth pole and drew clear nearing the wire. GRECIAN LYRIC was hustled along off the rail to set a clear lead through the backstretch, came under a drive in the upper stretch but leveled off after giving up control late yards. PROSPECTIVE PEACE gave chase toward mid track, rounded the turn about the four path, leveled off in the stretch and just lasted in show. PRIZED STORM chased the early pace from the inside, eased out in the upper stretch and just missed show. RUN LUCY gave distant chase off the rail, eased outward through the turn, entered the stretch about the four path and leveled out down the lane. RED BOP ROAD veered sharply out leaving the gate, angled in to give chase about the three path through the backstretch, showed no further response from the head of the lane, burnt through a rear bandage and was vanned off. SLEW'S FIRST LADY, well back toward mid track, ran out on the turn, was eased from that point and walked off post race.	<urn:uuid:a4c98b5b-6563-42d6-a571-778cdc21030c>	CC-MAIN-2016-44	http://www.equibase.com/premium/eqbPDFChartPlus.cfm?BORP=P&STYLE=EQB&DAY=D&tid=CT&dt=03/19/2013&ctry=USA&race=5	2016-10-22T11:43:50Z	s3://commoncrawl/crawl-data/CC-MAIN-2016-44/segments/1476988718957.31/warc/CC-MAIN-20161020183838-00394-ip-10-171-6-4.ec2.internal.warc.gz	437,796,196	817	eng_Latn	eng_Latn	0.986164	eng_Latn	0.986164	[ "eng_Latn" ]	false	rolmOCR	[ 2605 ]
Revolution in Boston: &Evolution Changes & Innovations in the Construction Industry 2003 Annual Meeting May 8-9, 2003 • The Sheraton Hotel Back Bay • Boston, MA Lawyers Serving the Construction Industry Through Education and Leadership In Cooperation with the Construction Litigation Committee of the ABA Section of Litigation Dear Colleagues Bos Each spring, the Forum brings together a distinguished array of speakers and a schedule of meetings and receptions where members of its 12 Divisions share ideas and have a chance to meet other construction industry professionals from across the country. Each year, we work hard to improve the quality of program content and the technical media by which it is presented. We are confident that our May 2003 Annual Meeting will meet the high expectations of our members. Our location is the great city of Boston. We will meet in the historic Back Bay area, within a few blocks of Copley Square, the Museum of Fine Arts, and the old brick shops of Newbury Street.The Old North Church, Quincy Market, Boston Common, Harvard Square and Fenway Park are among the many other venues waiting nearby for you to explore. Our program will consist of five plenary sessions and eight workshops, offering a wide spectrum of information on important changes and innovations affecting lawyers and consultants in the construction industry.Topics have been selected to provide valuable training from the most junior practitioner to the most senior. Electronic discovery, liability for mold, project cost accounting, project labor agreements, smart building technology, dispute review boards, form contract comparisons, force majeure insurance, scheduling (introductory and advanced), lender assignments, mandatory federal provisions and ethical conflict resolution will all be discussed. In addition, the speaker for the Thursday luncheon will be Michael Lewis, the Director of the Central Artery Tunnel Project in Boston (a/k/a "The Big Dig"). Mr. Lewis will be providing us with a multimedia insider's tour of this $14 billion project. Besides the excellent programs being offered, you will have the opportunity to catch up with old friends, meet new ones, and become more involved in Forum activities. Whether it's taking part in one of the 12 Division breakfasts or committee meetings, or just attending the Forum's annual business meeting at the Friday luncheon, you can get as involved as you choose in the Forum's educational and networking activities. Special orientation will be provided to first time attendees and new Forum members. The Forum's annual reception on Thursday night should be a particularly splendid event. We have reserved several of the main galleries in Boston's prestigious Museum of Fine Arts where you can enjoy great food, drink and company while surrounded by classic art. For a preview of the collection, you can visit www.mfa.org online. For an exciting, informative and enjoyable program, please join us for the Revolution & Evolution in Boston. ANNE E. GORHAM Program Co-Chair Stites & Harbison Lexington, KY GEORGE J. MEYER Program Co-Chair Carlton Fields, P.A. Tampa, FL DOUGLAS S. OLES Governing Committee Liaison Oles, Morrison, Rinker & Baker, L.L.P. Seattle, WA t ton 2003 Forum on the Construction Industry Leadership Social Event May8 Thursday Governing Committee Chair DEBORAH S. BALLATI Farella, Braun & Martel L.L.P. San Francisco, CA W. ALEXANDER MOSELEY Hand Arendall, L.L.C. Mobile, AL Immediate Past Chair C. ALLEN GIBSON, JR. Buist, Moore, Smythe & McGee, P.A. Charleston, SC Chair-Elect & Budget Chair JOHN R. HEISSE, II Thelen Reid & Priest L.L.P. San Francisco, CA Governing Committee LYNN R. AXELROTH Ballard Spahr et al Philadelphia, PA DOUGLAS C. GREEN Minneapolis, MN KIMBERLY A. HURTADO Hurtado & Dagan, SC Brookfield, WI TY D. LAURIE Schiff Hardin & Waite Chicago, IL KENNETH R. KUPCHAK Damon Key, et al. Honolulu, HI DOUGLAS S. OLES Oles, Morrison, Rinker & Baker, L.L.P. Seattle, WA MICHAEL D. TARULLO, SR. Schottenstein, Zox & Dunn, L.P.A. Columbus, OH FRED D. WILSHUSEN Thomas, Feldman & Wilshusen, L.L.P. Dallas, TX Staff Director KELLY RODENBERG American Bar Association Chicago, IL Meetings Manager ALANNA SULLIVAN American Bar Association Chicago, IL Spouse Tour Complete Tour of Boston: 350 Years in a Day With fascinating history, beautiful architecture and charming neighborhoods, it's no wonder Boston welcomes more than 10 million visitors annually.The ABA invites you to spend a day getting to know one of America's oldest architectural and cultural gems with a guided tour through many of Boston's most celebrated sites, including: * Beacon Hill — Boston's first and most prestigious address. * Back Bay — The new face of Boston's waterfront, built over one hundred years ago. * Fenway Park — A historic ballpark, home to Babe Ruth and other baseball greats. * South End — An area boasting the United States' largest Victorian neighborhood. * North End — Boston's famous Italian neighborhood, home to Old North Church, where lanterns were hung to signal the beginning of Paul Revere's "Midnight Ride". * USS Constitution, Freedom Trail, Massachusetts State House, Quincy Market and more! Venture through historic neighborhoods, famous sites and along Boston's waterfront. The tour is 4 hours in duration and the $30 per person includes transportation, guide service, admissions, taxes and gratuities. 3:00 - 7:00 p.m. Registration/Information 6:00 - 7:00 p.m. Young Lawyers Reception 7:15 a.m. - 5:00 p.m. Registration/Exhibition Open 7:30 - 8:30 a.m. Continental Breakfast (available to paid registrants) Breakfast Meetings Division 11 Corporate Counsel (division members only) Construction Litigation Committee/New Member Breakfast 8:30 - 8:35 a.m. Welcome from the Chair 8:35 - 8:45 a.m. Opening Remarks and Announcements 8:45 - 10:15 a.m. Plenary 1 Discovery of Electronic Information in Construction This panel will explore the intricacies of electronic discovery in construction disputes, with a focus on identifying electronicallystored records, where to look, how to request production, and how to protect such documents. JAMES BUTLER Smith, Currie & Hancock L.L.P. Atlanta, GA ON H . W ILLIAM G. Y OUNG Boston, MA PHILLIP HOMES, P.E. InteCap, Inc. Boston, MA GENE E.K. PRATTER Duane Morris, L.L.P. Philadelphia, PA 10:15 - 10:45 a.m. Plenary Construction Cue Mold & Mildew: Evolving Liability and Insurance Do mold or poor air quality constitute design and/or construction defects? If so, will the parties' insurance cover costs of remediation? This segment will discuss evolving standards, causation issues and insurance coverage and exclusions. LAURENCE KIRSCH Shea & Gardner Washington, DC 10:45 - 11:00 a.m. Break 11:00 - 12:00 noon Workshop A Counting the Beans: Analyzing Project Costs Tracking costs is essential in project management and in supporting a construction claim. This program will offer guidance in tracking, segregating, testing and analyzing both direct and indirect project costs. RICHARD F. SMITH Smith, Pachter, McWhorter & Allen P.L.C. Vienna, VA PETER BADALA Navigant Consulting, Inc. San Francisco, CA Workshop B How Effective Are Project Labor Agreements? Our speakers will offer two contrasting views on the merits and enforceability of PLA's, including an update on test cases in federal and state courts. LAWRENCE H. KAY Sacramento, CA CHRISTOPHER C. WHITNEY Little, Bulman & Whitney Providence, RI 12:00 - 12:15 p.m. Transition to Lunch 12:15 - 1:45 p.m. Lunch and Luncheon Speaker THE BIG DIG – A Multimedia Insider's Tour of Boston's Central Artery Tunnel Project MICHAEL LEWIS Project Director Boston, MA 1:45 - 2:00 p.m. Transition to Afternoon Workshops 2:00 - 3:15 p.m. Workshop C The Revolution in "Smart Building"Technology Stocks in tech companies may be down, but the influence of their innovations is here to stay.This program will review how new technologies have revolutionized design, construction materials, and building systems. It will also provide an introduction to emerging legal issues in so-called "smart buildings". JEFFREY A. MOERDLER Mintz Levin Cohn Ferris Glovsky & Popeo P.C. New York, NY Siemens Building Technologies JAMES M. MUNDY Wantagh, NY Workshop D The Evolution in Dispute Resolution The "Big Dig" in Boston was fertile ground for development and use of innovative dispute resolution procedures.This program will discuss some of the lessons learned (including dispute review boards) and offer contrasts with recent practice in the United Kingdom and elsewhere. MICHAEL BLACK QC Chambers of Dermod O'Brien QC London, England CHUCK SCHAUB Hinckley, Allen & Snyder Boston, MA 3:15 - 3:30 p.m. Break 3:30 - 5:00 p.m. Plenary 2 Standard Contract Forms: Do They Meet Client Needs and Expectations? Savvy owners, designers and contractors–and their counsel– must weigh and allocate the various contract rights, risks and responsibilities when selecting among the myriad of standard form documents published by industry professional and trade associations.The speakers will survey the current offerings of major standard form contract documents, highlighting their significant differences and biases and generally putting them to the test. MARK J. HELEY Meagher & Geer P.L.L.P. Minneapolis, MN PENNY PITTMAN COBEY Los Angeles, CA MARK MCCALLUM Associated General Contractors Bethesda, MD 5:00 - 6:00 p.m. Break Before Annual Reception 6:00 - 8:00 p.m. Annual Reception at Museum of Fine Arts 7:15 a.m. - 5:00 p.m. Registration/Exhibition Open 7:30 - 9:00 a.m. Breakfast/Business Meetings Divisions 1-10 & 12 (please specify interest on registration form) 9:00 - 9:15 a.m. Transition to Morning Session 9:15 - 9:20 a.m. Announcements 9:20 - 10:50 a.m. Plenary 3 Force Majeure in the 21st Century Since the September 2001 terrorist attacks, "force majeure" clauses and related insurance coverage have been sorely tested. This program will discuss the common law scope of force majeure relief and the evolving limits on available insurance. BOB BURCHETTE Johnson, Allison & Hord Charlotte, NC FRED MUSE Marsh USA, Inc. Atlanta, GA CARY WRIGHT Carlton Fields Tampa, FL 10:50 - 11:05 a.m. Break 11:05 a.m. - 12:05 p.m. Workshop E Scheduling 101: Preparing and Interpreting Complex Construction Schedules This program will help practitioners understand how various forms of construction schedules are prepared and updated, discussing the most common software and providing guidance for interpretation and cross-examination of schedules. KEITH BERGERON Deutsch, Kerrigan New Orleans, LA ROY WILSON Wilson Management Consultants Glen Head, NY Program Schedule Workshop F Negotiating a Lender's Consent & Assignment Agreement KATHLEEN OLDEN BARNES Watt, Tieder, Hoffar & Fitzgerald, L.L.P. McLean, VA Over the past several years, lenders increasingly are requiring broad consent and assignment agreements from designers and contractors.This program provides an introduction to such agreements, offering guidance on what is negotiable and what isn't. JEFF FORD Ford, White & Nassen Dallas, TX ALAN RITTERBAND Ballard Spahr Philadelphia, PA 12:05 - 12:15 p.m. Transition to Lunch 12:15 - 1:45 p.m. Lunch/Forum Business Meeting/Election of Officers/ Presentation of Awards 1:45 - 2:00 p.m. Transition to Afternoon Workshops 2:00 - 3:15 p.m. Workshop G Scheduling 201: Tactical Use of Schedules Building on the substance of Workshop E, this program offers advanced training on how schedules can be used most effectively in project management and claim support.Topics will include float manipulation, planned early completion,incorporation of subtrade schedules, effects of owner approval, use of updates, and proof of delay impacts. B B ARRY RAMBLE Knowles, USA Cherry Hill, NJ ALAN E. HARRIS Farella Braun & Martel L.L.P. San Francisco Workshop H Federal Statutes and Regulations in Construction This program will describe the content and application of federal statutes and regulations with special impact on construction contracts.Topics will include the Brooks Act, Contract Disputes Act,Truth in Negotiations Act, Buy American Act, Davis Bacon Act, the Miller Act, the Prompt Payment Act, and others. LARRY HARRIS Piper Rudnick L.L.P. Washington, D.C. CHRISTINE MCANNEY Venable, Baetjer and Howard, L.L.P. Vienna, VA 3:15 - 3:30 p.m. Break 3:30 - 5:00 p.m. Plenary 4 Ethics: Conflicts in Representing Construction Clients This interactive program will use hypotheticals and audience input to explore conflicts that commonly arise in representing construction industry clients. THOMAS E. SPAHN McGuire Woods L.L.P. McLean, VA 5:00 p.m. Adjourn 5:30 - 7:00 p.m. Reception Honoring Women in Construction DRB Foundation Dispute Resolution Board Seminar Dispute Review Boards ("DRBs") are being used increasingly to resolve construction industry disputes. Lawyers should understand the process and their role in it. Many providers of neutrals, including the AAA, require DRB members to complete this kind of Workshop sponsored by the DRB Foundation.The day-long presentation will include lectures, demonstrations, exercises, and suggestions to improve the process. It will also provide information about becoming a DRB member and related ethical issues. Separate registration is required. Registration is $345 for DRB Foundation members and $395 for non-members.To sign up, please contact the DRB Foundation directly at 6100 Southcenter Blvd., Suite 115, Seattle WA 98188-2441, (888) 523-5208. Conference Information Advance Registration Please complete and return the attached registration form with your payment by APRIL 11, 2003. If you wish to have your name appear on the preregistration list distributed at the program, we must receive your registration no later than this date. Conference registrations will only be accepted when accompanied by a check, Visa, American Express, or MasterCard information. Credit card registrations may be FAXED to our registration company,T-REX directly at (630) 262-1520 or you may register online at www.abanet.org/ forums/construction/home.html. Registrations cannot be held without payment. On Site Registration On site registration is available for those persons who missed the registration deadline. If you plan to register at the door, you must call (312) 988-5579 at least 72 hours before the conference to confirm that space is still available. Failure to call in advance may result in not being admitted to a sold out program. On site registration will only be accepted when accompanied by a check, money order, American Express, Visa or MasterCard information. Registrations will not be accepted without payment. Registration Confirmation If you do not receive a written confirmation by APRIL 11, 2003, please call T-Rex directly at (630) 262-1599 to verify that your registration form and check were received. Failure to call in advance of the program may result in not being admitted. Tuition Tuition includes admission to the program, coffee breaks, continental breakfast, lunches, one ticket to Annual Reception at the Museum of Fine Arts, and one set of program course materials. Lunch is limited to registrants, faculty and members of the press. Cancellation Policy No refunds will be granted for cancellations received after APRIL 11, 2003.To receive a refund (less a $50 administrative fee), cancellations must be made IN WRITING and RECEIVED on or before APRIL 11, 2003. Registrants who are unable to attend may send a substitute or receive course materials in lieu of a refund.The ABA reserves the right to cancel any programs, and assumes no responsibility for personal expenses. Hotel The conference will be held at The Sheraton Boston Hotel, 39 Dalton Street, Boston, MA 02199. Reservations can be made by calling the Sheraton Reservation Office at (800) 325-3535.To insure availability please make your reservation by MARCH 28, 2003.The Hotel Reservation Office will assign rooms on a space available basis. Hotel check-in time is 3:00 p.m. and the check-out time is 12:00 p.m. Reservations must be cancelled 48 hours prior to the scheduled day of arrival to avoid a one night's cancellation charge. Conference Rates: $219 single/double. Air Transportation You can fly to ABA meetings with favorable airfares on the following carriers by purchasing your ticket under the ABA Discount Code and using one of two options: Percentage Discounts or Zone Fares. Once your airfare has been determined, the percentage discount can then be applied to produce additional savings to you. By asking the agent to compare the percentage-discounted fare with the carrier's Zone Fares, even greater savings may be achieved. Zone Fares are more flexible and user-friendly than nonrefundable, restricted airfares. While Zone Fare rules and restrictions vary with each airline, most only require a 7-day advance purchase; do not require a Saturday night stay; are changeable and refundable and require only a 2-day minimum stay. The ABA Discounted Meeting Airfares are available on the following airlines through your travel agent, directly from the airlines or from the ABA travel agency,Tower Travel at (800) 921-9190. American Airlines Discount Code # 15794 Delta Air Lines Discount Code # 189408 A US Airways Discount Code # 36632473 CLE Credit Accreditation has been requested for the conference from every state with mandatory continuing legal education (MCLE) requirements for its lawyers. Please be aware that each state has its own rules and regulations, including its definition of "CLE". Check your state agency for confirmation of this program's approval. Attorneys seeking to obtain MCLE credit in Louisiana and Pennsylvania are required to pay state accreditation fees directly to that state. Certificates of attendance will be available at the conclusion of this conference. For questions pertaining to the number of credit hours granted by each state, call (312) 988-6217 two or three weeks before the conference. Membership The membership tuition rate will be available to registrants who join the Forum on or before the first day of the program. For your convenience, you may apply for Forum membership using this Program Registration Form. Membership dues are not deductible as charitable contributions for federal income tax purposes. However, such dues may be deductible as a business expense. Tax Deduction for Educational Expenses In the United States, an income tax deduction may be allowed for educational expenses undertaken to maintain or improve professional skills.This includes registration fees, travel, meals, and lodging expenses. (see Treas. Reg. 1.162-5) (Coughlin vs. Commissioner 203 F 2d 307). Course Materials All registrants will receive the course materials in paper and CD formats. If you are not planning to attend the program and wish to order the course materials, check the appropriate box on the registration form and send it with the appropriate fees. Allow approximately 3-4 weeks after the program for delivery. Services for Persons with Disabilities If special arrangements are required for an individual with a disability to attend this program, please submit your request in writing to Kate Flanagan, Forum on the Construction Industry, American Bar Association, 750 N. Lake Shore Drive, MS 11.2, Chicago, IL 60611, or Fax to (312) 988-5677, no later than APRIL 11, 2003. Forum on the Construction Industry Website www.abanet.org/forums/construction/home.html Cell Phone Policy As a courtesy to speakers and attendees, we request that all cell phones and pagers be turned off in the meeting rooms. Program Registration Form Housing Deadline: March 28, 2003 Registration Deadline: April 11, 2003 Please print or type 1. Registrant Information This form is available online at: www.abanet.org/forums/construction/home.html Last Name First Name M.I. (Name as you wish it to appear on attendee list & name badge) ABA Member ID# Firm/Company/Agency Address City State Zip (Area Code) Business Phone Number (Area Code) Business Fax Number E-mail Address Spouse or Guest (Print as you wish names to appear on badge) If you are an attorney licensed in the state of New York, please check here. 2. Registration Fees __ General Attendees $675 __ Forum Members $595 __ Construction Litigation Members $595 __ Government/Academic/YLD $425 __ Law Students $345 __ New Member, First Time Attendees: $295 __ Forum 20 Year Member: $445 Subtotal $_______________ Please check one if you are: __ Member of BOTH Forum and Construction Litigation Committee __ Past Forum Chair __ Past Governing Committee Member __ I am a New Member and would like a mentor to contact me Event Fee Quantity Total Spouse/Adult Annual Reception $50 _____ $_________ Child Annual Reception (under 12) $30 _____ $_________ Thursday's Spouse Tour $30 _____ $_________ Reception Honoring Women in Construction N/A _____ $_________ Subtotal $_______________ $______________ Please enroll me as a member of the Forum on the Construction Industry. Membership fee ($40 Regular/$5 Law Student). I understand I must be a member of the ABA and at least one Section. I belong to the following Section(s): ____________________________________________. I will not be attending the seminar and wish to order program materials at $150 Subtotal $__________________ Add subtotals 2,3,4 or 5: Total $__________________ __ Check (made payable to ABA) __ MasterCard __ Season Pass Voucher __ American Express __ VISA Credit Card Number Expiration Date Signature 4. Membership Applications 3. Social Event Tickets Educational Registration Thursday, May 8, 2003 7:30 a.m.-8:30 a.m. Breakfast __ Div. 11 – Corporate Counsel (Division Members Only) __ Construction Litigation Committee __ First timers 11:00 a.m.- 12:00 p.m. (Make one choice) __ Workshop A __ Workshop B 2:00 p.m. -3:15 p.m. (Make one choice) __ Workshop C __ Workshop D Friday, May 9, 2003 7:30 a.m. -9:00 a.m. – Division Breakfast Meetings (Make one choice) __ Div. 1 Dispute Avoidance & Resolution __ Div. 2 Contract Design __ Div. 3 Design __ Div. 4 Construction Management, Design/Build & Related Concepts __ Div. 5 Contract Negotiations,Performance & Administration __ Div. 6 Employment Law & Labor Relations __ Div. 7 Bonds, Liens & Insurance __ Div. 8 International Contracting __ Div. 9 Specialty Trade Contractors and Suppliers __ Div. 10 Legislation & Environment __ Div. 12 Owners and Lenders 11:05 a.m.- 12:05 p.m. (Make one choice) __ Workshop E __ Workshop F 2:00 p.m.-3:15 p.m. (Make one choice) __ Workshop G __ Workshop H 5. Materials Only 6. Total Payment 7. Payment Information 3 Ways to Register Online: www.abanet.org/forums/construction/home.html Mail: Technical Registration Experts (T-Rex) Forum on the Construction Industry 13 South 2nd Street, Suite 2 Geneva, IL 60134 Fax: Fax: (630) 262-1520 T-Rex phone: (877) 309-1565 or (630) 262-1599 Nonprofit U.S.Postage PAID American Bar Association American Bar Association 750 North Lake Shore Drive Forum On The Construction Industry, MS 11.2 Chicago, Illinois 60611	<urn:uuid:c167014f-9ced-473e-adb9-94d1aeb731fd>	CC-MAIN-2016-50	http://www.americanbar.org/content/dam/aba/migrated/forums/construction/past_programs/May2003_brochure.authcheckdam.pdf	2016-12-07T10:48:25Z	s3://commoncrawl/crawl-data/CC-MAIN-2016-50/segments/1480698542060.60/warc/CC-MAIN-20161202170902-00461-ip-10-31-129-80.ec2.internal.warc.gz	311,377,254	5,444	eng_Latn	eng_Latn	0.774853	eng_Latn	0.974155	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 333, 3252, 5450, 9591, 13641, 19783, 23208, 23383 ]
Key Figures Issuer Sunborn Finance Oyj Key Figures Operator Sunborn Saga Oy 1 Oct - 31 Dec 1 Oct - 31 Dec 1 Jan - 31 Dec 1 Jan - 31 Dec Chief Executive Director Sunborn Finance Oyj results for Q4 reached our budgeted income and cost targets. The revenue and profitability for the financial year is largely in line with 2017 despite major renovation works being conducted in Naantali. The upgraded facilities have been for most parts finalized in 2018 and will positively impact ADR, occupancy and ratings of the hotels. General Sunborn Finance Oyj owns Naantali Spa hotel located in Naantali by the Baltic Sea and Ruissalo Spa Hotel located in Turku by the scenic archipelago. Both properties have been leased to hotel operator Sunborn Saga Oy. The hotel operations of the spa hotels are run by management company Sunborn Saga Oy under a lease contract. Naantali Spa Resort has 214 rooms and 40 ancillary time share apartments and Ruissalo Spa Hotel 171 rooms. Both hotels also offer various ancillary facilities and services, such as conference and ball room facilities, spa facilities with treatment rooms and a pool complex with saunas, fully equipped fitness center, rehabilitation facilities, restaurants, bars, cafes and lounges. Sunborn Finance was established 1 November, 2017 the company's operations consist of acting as a lessor of the spa hotels and also providing property and IT related facility services. Sunborn Finance has four employees. Sunborn Finance Oyj Financial summary 1 January 2018 – 31 December 2018 Sunborn Finance receives lease income from the operator. Lease income 1/2018 – 12/2018 was 3,338 M€. The other services income refers to personnel costs for facility services and is a cost/income neutral line item. The value of the Spa hotels is at Naantali Spa 54 M€ and at Ruissalo Spa 28,5 M€ (1/3 in Sunborn Finance assets) according the valuation reports. Sunborn Saga Oy Financial summary 1 January – 31 December 2018 Comparable Turnover 1-12/2018 vs 2017 was relatively flat at 25,7 M€ (25,2 M€). In addition, 2017 Turnover included 1,56 M€ income related to divested business. Q4 revenue was 5,64 M€ (5,76 M€) -2% YoY but reached set Q4 budgeted revenue target. Corporate segment demand was lower than expected during Q4 but the Leisure and spa segment increased to compensate for much of it. Room renovations in Naantali Spa were still ongoing in Q4 with some unexpected delays which reduced availability and capacity during busy weekends. F&B sales increased in comparison to 2017 in both properties and treatment and rehabilitation sales increased as well. Growth in health care segment Revenue in Ruissalo Spa was +4.3%. ADR in Q4 was lower than YoY, in Naantali by -3,7% and Ruissalo -1,6%. However, RevPAR in the same period increased in Ruissalo +2,5% and Naantali by +6,7%, although Naantali occupancy was affected by less available capacity due to renovations. Christmas period and new year were successful in both properties and the company Black Friday gift certificate sales in December reached all time record over 1 mil euros. Refurbishment and renovation Overall 2018 sales in Naantali Spa as expected were influenced by the room renovations impacting on the amount of total visitors and capacity during peak seasons. Due to delays and problems in material supplies the renovations program was behind schedule and works continued into the new year. The remaining installations in Naantali are to be fully completed within Q1/2019, thereafter a refurbishment of a number of suites will be undertaken during 2019. Renovations will also continue in 2019 in the public areas eg. in the lobby, but these projects are expected to have little impact in room sales and revenue. Feedback concerning the renovated rooms has been excellent and customer satisfaction figures and NPS score have increased significantly. Management expects and has budgeted for increases in ADR and revenue for 2019 as a result of the completed works. In addition to the ongoing renovations the management team at Sunborn Saga has also worked on the new strategy of the company for 2019-2021. Sunborn Saga focuses on improving customer experience in form of new products and better service. Strategic growth organically is one of the key targets. A goal-oriented responsibility program is a solid part of the strategy. Naantali Spa seeks growth by increasing the number of foreign visitors especially from Scandinavia, Russia and Asia and by attracting more corporate clients, whereas Ruissalo Spa will increase business in the rehabilitation segment. The long-term continued success of the company is enabled by committed employees. The financial target is to reach a higher than five per cent annual average organic net sales growth and comparable EBIT of higher than 10 per cent of net sales. Notable events during and after the reporting period The company completed the listing of the senior secured floating rate bond to NASDAQ Helsinki on 8 th February 2019. Business environment No notable changes in the business environment. Issuer is a SPV with no other purpose than owning the Naantali and Ruissalo spa hotel properties. The hotels are leased out to Sunborn Saga Oy through a lease agreement. Sunborn Saga Oy pays Sunborn Finance Oy a fixed sum of 278 152 € per month in lease. Guest satisfaction continues to be good in Naantali reflected by #1 position in Tripadvisor, Booking.com rating of 8.0/10, Hotels.com rating of 8.2/10, Expedia.com 4.1/5 and in Ruissalo by Booking.com rating of 7.8/10, Hotels.com rating of 7.6/10, Expedia.com 3.7/5. Estimated future development The company estimates that its financial performance and debt service capacity will remain stable. Short-term risks and uncertainties The Company´s financial risks related to business are market risk (including interest rate risk), credit risk, liquidity risk and refinancing risk. Floating interest rate risk has not been hedged. Financial risk management carried out by the management of the Company aims to protect the Company against unfavorable developments in the financial markets and ensure the performance. The management review financial risks on regular basis to manage financial risk position and decide on necessary actions. Sunborn Finance Oy INTERIM REPORT 1 November 2017 - 31 December 2018 CONTENTS CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME The above statement of comprehensive income should be read in conjunction with the accompanying notes. CONSOLIDATED BALANCE SHEET The above balance sheet should be read in conjunction with the accompanying notes. CONSOLIDATED STATEMENT OF CHANGES IN EQUITY CONSOLIDATED STATEMENT OF CASH FLOWS NOTES TO THE FINANCIAL STATEMENTS 1. General information Sunborn Finance Oyj is a public limited liability company ("the Company") incorporated in Finland. The registered address of Sunborn Finance Oyj is Juhana Herttuan puistokatu 23, Turku, Finland. Sunborn Finance Oyj was established on November 1, 2017 through a partial demerger of Sunborn Oy. Sunborn Finance owns spa hotel "Naantali Spa" and approximately 30% ownership of the "Ruissalo Spa" (together "hotels") properties located in south west Finland. Naantali Spa has 218 and Ruissalo Spa 171 hotel rooms with several event rooms, restaurants, bars, café's and lounges, spa facilities, pools and fitness centre. The Company was established for purpose of owning the hotels. The hotel operations of the spa hotels Naantali Spa and Ruissalo Spa, (together "Spa hotels"), are operated by Sunborn Saga Oy ("Sunborn Saga"), a subsidiary of Sunborn Oy, in accordance with a lease contract between Sunborn Finance (and Sunborn Oy prior to the partial demerger) and Sunborn Saga. Sunborn Finance provides also property management and IT support services and has four employees. Two of these employees were transferred to the Company in connection with the partial demerger and two were transferred from Sunborn Saga at the beginning of the year 2018. Sunborn Finance is wholly owned by Pekka Niemi, Ritva Niemi, Hans Niemi and Jari Niemi (together, the "Niemi Family"). As at 27 December Sunborn Finance Oy acquired subsidiary for administrative purposes thus became the parent company of Sunborn Finance Group ("the group"). The financial information presented in the interim financial statements for the 14-month period ended December 31, 2018 and 3-month period ended December 31, 2018and the balance sheet as at December 31, 2018 are based on actual figures of Sunborn Finance Oyj ("the Company") as an independent company after the consummation of the demerger as at November 1, 2017, and carve-out figures prior to the consummation of the demerger. The carve-out financial information presented in interim financial statements reflects the financial performance of the business related to the properties Naantali Spa and new part of Ruissalo Spa (together "spa hotels") within Sunborn Oy ("Sunborn Finance business"). Accordingly, the balance sheet as of December 31, 2018, statement of comprehensive income, statement of changes in equity and statement of cash flows for the 14-month period November 1, 2017 – December 31, 2018 are based on actual figures as an independent company. The financial information for the 10month period January 1 – October 31, 2017 and the balance sheet as at October 31, 2017 is based on carve-out financial information of Sunborn Finance business of Sunborn Oy. These interim financial statements are unaudited. 2. Summary of significant accounting policies Basis of preparation This condensed interim financial report for nine months ended September 30, 2018 have been prepared in accordance with International Financial Reporting Standards (IFRS) and IAS 34 interim Financial Reporting, as adopted by the European Union. The interim financial information is based on the same accounting policies and calculation methods as used in the financial statements for the 10 month period ended October 31, 2017 except for as presented below. In December Sunborn Finance Oyj acquired a subsidiary for administrative purposes thus became the parent company of the group. Sunborn Finance Oyj and its subsidiaries together make up Sunborn Finance Group ("the group"). These are the first consolidated interim financial statements of the group. Subsidiaries are fully consolidated from the date on which control is transferred to the Group. Inter-company transactions, balances and unrealised gains or losses on transactions between Group companies are eliminated, except where there are indications for impairment. Subsidiaries are deconsolidated from the date that control ceases. The establishment of the subsidiary did not have material impact on the interim financial statements. The condensed interim year financial report does not include all the information and notes that are presented in the annual financial statements. As such, the interim financial report should be read in conjunction with the special purpose financial statements for the 10-month period ended 31 October 2017. The financial statements are presented in thousands of euros unless otherwise stated. All figures presented have been rounded and consequently the sum of individual figures may deviate from the presented sum figure. Basis of accounting for the carve-out financial information As the Company was established through demerger on November 1, 2017, the carve-out financial information of Sunborn Finance Oyj for the nine month period ended 30 September 2017 and for the balance sheet as at October 31, 2017 have been prepared on a carve-out basis from Sunborn Oy's standalone financial information. The carve out interim financial information comply with Finnish Accounting Standards, comprising the historical income and expenses, assets and liabilities and cash flows attributable to the business related to the Spa hotels and are adjusted to comply with IFRS as adopted by the EU. As IFRS does not provide guidance for the preparation of carve-out financial statements, certain accounting conventions commonly used for the preparation of historical financial information have been applied in preparing carve-out financial information for the nine month period ended September 30, 2017. The application of these carve-out conventions has been described more closely in the special purpose financial statements for the period ended October 31, 2017. 3. Revenue The Company's revenue consists mainly of rental income from its related party Sunborn Saga. In addition, the Company derives service revenue from property management and IT support services. 4. Investment property The Company presents the Spa hotels as investment property and measures them using the fair value model. The valuation has been prepared by an independent and recognized professional valuator. Based on the valuation report, fair value of the spa hotels is approximately EUR 63.5 million. The fair value measurement is based on nonobservable inputs and accordingly, is classified in Level 3 in the fair value hierarchy. The most significant assumptions used in the calculations have not been changed after the end of the financial period ended October 31, 2017. Spa hotels The Spa hotels have had an ongoing major renovation since before the Company's establishment on 1 November 2017. The renovations will continue in year 2019. The Company decided to change the legal form of the Company from private limited company to public limited liability company in December 2018. At the same time, the Company decided to increase the share capital of the Company to meet the requirements of a public limited liability company under Finnish Companies Act (624/2006). Share capital was increased from reserves of the invested unrestricted equity by EUR 77 500 in December 2018. After this transaction, the Company's share capital amounts to EUR 80 thousand. 5. Borrowings As at February 9, 2018 the Company issued senior secured bonds ("the bonds") with nominal amount of EUR 50 million (less transaction costs of EUR 1,3 million) to certain qualified institutional investors mainly to refinance the existing debt. The remaining proceeds are used for the capital expenditure purposes. The bonds are denominated in euros and mature on 9 February 2023. The bonds shall be fully redeemed on maturity date at nominal amount. The Company has the right to early repayment also. The contractual interest is 4.85 % plus 3-month Euribor. The effective interest rate is 5,45 %. Before the issuance of the bonds the Company had short term bridge financing, which had contractual interest consisting of cash interest 7,0 % plus 3-month Euribor (min 1,0 %) and capitalised interest 3,5 %. The facility, together with the capitalised interest, was repaid when bond was issued. Fair value of the borrowings approximate the carrying amounts as the bonds were withdrawn during the year at market terms and they are all current liabilities. Collaterals and guarantees given The bonds are secured by a 1st lien mortgage in the Spa hotels. Moreover, the Company has pledged all cash flows generated by the lease agreement on the Spa hotels, as well as the lease receivables. Insurance proceeds are also assigned to bond holders. The normal bank accounts of the Company have been pledged to secure the bond repayments, however they can be used by the Company in the ordinary course of business if no event of default occurs. The bond agreement sets some restrictions on the activities of the Company. The Company's obligations of the bonds are secured with an on demand guarantees from the Operator and Sunborn Oy. Sunborn Oy's guarantee is limited to an amount corresponding the paid dividend. Furthermore Operator's and Sunborn Oy's guarantee is limited in the mandatory provisions of the Finnish Companies Act. The bonds are also secured by a 1st lien floating charge (in Finnish: yrityskiinnitys) registered on the Company's and Sunborn Saga's movable assets in accordance with the Floating Charge Act. Sunborn Saga's cash flows, as well as its bank accounts have been pledged and insurance proceeds are assigned to bond holders as security of the bonds. Moreover, Niemi Family has pledged its shares in the Company and Sunborn Oy has pledged its shares in Sunborn Saga to secure the repayment of the bonds. Pekka and Ritva Niemi have pledged all the existing and future lease receivables which they have from Sunborn Saga Oy. The bond terms include an asset cover ratio covenant, which requires the Company to maintain the asset cover ratio of minimum 130.0 %. The covenant is calculated based on the market value of the Spa hotels calculated by approved valuator appointed by the Company and approved by the bond trustee, divided by financial net indebtedness of the Company. The bond terms include also a cash requirement covenant, which requires the Company to maintain the cash minimum of upcoming 3 months interest payment. The bond terms include an interest cover ratio covenant, which requires the Company to generate EBITDA minimum of 1,1 times the interest and a lease payment coverage covenant, which requires the Operator to generate EBITDA minimum of 1,0 times the lease payment. The covenants are tested on a quarterly basis. The Spa hotels have had an ongoing major renovation since before the Company's establishment on 1 November 2017. Since then, the Company relied on the Operator to manage and complete these major renovations. Accordingly, as of the Company's establishment and through Q3 2018, the Company had accrued and waived Sunborn Saga's requirement to make lease payments to the Company in light of Sunborn Saga extending its funds for purposes of this major renovation. Pursuant to the parties' agreement regarding this major renovation, the parties reconciled and set-off their respective payment obligations as of 30 September 2018, which set-off is in an amount equal to the amount due in lease payments as of same date. The set-off structure under FAS may not meet the IFRS requirements and accordingly, management decided to present the bonds as current borrowings as at 30 September 2018. During the period in December 2018, the outstanding obligations of the counterparties in the set-off structure were settled and the bonds reclassified as noncurrent at 2018 year-end. The difference between the carrying amount before and after the reclassification as noncurrent liability is recognized as a finance expense in the income statement (representing the deferred transaction costs). 6. Transactions with related parties The Company is owned by Niemi Family. Company's related parties are entities under the common control of Niemi Family, the board of directors and key management of the Company, together with their close family members, and companies controlled by these individuals. Sunborn Group is controlled by Niemi Family. The following table summarises the Company's transactions and outstanding balances with related parties during or at the end of the years presented: The rental income of the Company arises from a lease contract related to the Spa hotels. Sunborn Finance has leased the Spa hotels to Sunborn Saga with a long term operative non-cancellable lease contract with a maturity date on November 1, 2027. A new 10-year lease contract for the Spa hotels was signed between Sunborn Saga and the Company as at November 1, 2018. The old lease contracts were cancellable by both parties with 3 and 6 months' term of notice for Ruissalo and Naantali spas respectively. The rent in the contracts is set at market level. The Company has paid management fee to Sunborn Oy as presented in the table above. Sunborn Saga has guaranteed the senior unsecured bonds of the Company. Detailed information on the guarantee is given in note 5. Borrowings. Subsequent events The company completed the listing of the senior secured floating rate bond to NASDAQ Helsinki on 8 th February 2019. Sunborn Saga Oy INTERIM REPORT 1 January - 31 December 2018 (FAS) Sunborn Saga's interim financial report has been prepared in accordance with the Finnish Accounting Standards (Finnish Accounting Act and Ordinance and related instructions and statements issued by the Accounting Board operating under the auspices of the Ministry of Economic Affairs and Employment). For the purposes of this interim financial information profit and loss statement, balance sheet and cash flow statement of the Sunborn Saga have been presented as required by the terms of the bond issued by the Sunborn Finance. Sunborn Saga is the guarantor of the bond. SUNBORN SAGA OY INCOME STATEMENT, EUR ============ ============ SUNBORN SAGA OY BALANCE SHEET, EUR SUNBORN SAGA OY CASH FLOW STATEMENT, EUR	<urn:uuid:6d3138ff-5a0b-4db5-985f-d4e8f2e36af8>	CC-MAIN-2019-13	https://www.sunborn.com/wp-content/uploads/2019/02/Sunborn_Finance-Q4-2018-Report.pdf	2019-03-18T22:27:50Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-13/segments/1552912201707.53/warc/CC-MAIN-20190318211849-20190318233849-00320.warc.gz	917,546,004	4,341	eng_Latn	eng_Latn	0.993594	eng_Latn	0.995547	[ "eng_Latn", "eng_Latn", "eng_Latn", "unknown", "unknown", "eng_Latn", "eng_Latn", "unknown", "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "unknown", "unknown", "unknown" ]	false	rolmOCR	[ 1904, 4841, 6281, 6352, 6362, 6514, 6626, 6671, 6709, 10784, 13233, 15552, 19081, 20000, 20640, 20707, 20743, 20785 ]
VOICE NETWORK SERVICES PRICING SHEET COX BUSINESS SERVICES SW450 CARRIER SERVICES PRICING MONTHLY \| Business Access Line \| Waived \| $17.00 \| ICB \| \|---\|---\|---\|---\| \| Direct Inward Dialing (Trunk) \| Waived \| $40.00 \| ICB \| \| Direct Inward Dialing -20 Block \| Waived \| $2.00 \| $2.00 \| \| Direct Inward Dialing -100 Block \| Waived \| $4.00 \| $4.00 \| \| Digital Loop Service \| Waived \| NA \| NA \| \| SmartTrunk \| Waived \| SEE PRI BELOW \| SEE PRI BELOW \| \| Primary Rate Interface \| Waived \| $379.00 \| $499.00 \| \| Primary Rate Interface (3 PRI's or more at one location) \| Waived \| $349.00 \| ICB \| \| Primary Rate Interface (20 PRI's or more at one location) \| Waived \| $329.00 \| ICB \| \| Plexar (CENTREX ANALOG) \| Waived \| $14.00 \| ICB \| \| Plexar (CENTREX DIGITAL) \| Waived \| $16.00 \| ICB \| \| T-1 (24 Channel Voice T-1) \| Waived \| $349.00 \| $463.00 \| \| Dedicated T1(LD Trunk) \| Waived \| $200.00 \| ICB \| \| Dedicated T1(LD Trunk 6 or more at a single location) \| Waived \| $0.00 \| ICB \| \| Features for voice services listed below \| \| \| \| \| Standard features \| Waived \| $3.75 \| ICB \| \| Call Forward on Call Waiting \| Waived \| $4.75 \| ICB \| \| Caller ID \| Waived \| $8.90 \| ICB \| \| Distinctive Ring \| Waived \| $5.50 \| ICB \| \| Remote Call Forwarding \| Waived \| $16.00 \| ICB \| \| Speed Call 8 \| Waived \| $2.75 \| ICB \| \| Speed Call 30 \| Waived \| $4.75 \| ICB \| \| Hunting- Per Line \| Waived \| $1.25 \| ICB \| \| Voice Mail Box- Basic \| Waived \| $9.50 \| ICB \| \| Feature Packages for Voice Products \| Waived \| \| \| \| BusinessID-CallWaiting,Caller ID,3Way,Speed Call 30, Busy Line Redial, Call Transfer \| Waived \| $11.95 \| ICB \| \| BusinessValue- Call Forward, 3Way, Call Waiting, Speed Call 30, Busy Line Redial, Call Transfer \| Waived \| $8.95 \| ICB \| \| Solutions-Call Forwarding, Call Waiting, Speed Calling - 8, Three-Way Calling, Call Return, Busy Line Redial, Selective Call Acceptance, Selective Call Forwarding, Selective Call Rejection, Call Forwarding - Busy, Call Forwarding - No Answer, Call Forwarding of Call Waiting, Caller ID, Priority Ringing, Long Distance Alert, and Call Waiting ID. \| Waived \| $17.50 \| ICB \| \| DIRECTORY ASSISTANCE( Local and Long-Distance) \| \| $1.00 \| \| \| ICB= Individual Case Basis \| \| \| \| \| FEES LISTED IN SEPARATE RATE SHEET \| \| \| \| \| \| \| Page 2 of 13 \| \| COST(ON-NET LONG DISTANCE RATES \| USAGE WORKSHEET \| \| ONE TIME COST \| \| \| Price Per Minute \| \|---\|---\|---\|---\|---\|---\| \| Type Call \| Description \| \| Access Type \| Term Type \| Per Minute Cost \| \| Corp Calling Card \| Intrastate \| Waived \| Switched \| Switched \| $0.35 \| \| Corp Calling Card \| Intrastate \| Waived \| Switched \| Switched \| $0.35 \| \| Dedicated 800 \| Canada \| Waived \| Switched \| Dedicated \| $0.07 \| \| Dedicated 800 \| Interstate \| Waived \| Switched \| Dedicated \| $0.0125 \| \| Dedicated 800 \| Intra IntraLATA \| Waived \| Switched \| Dedicated \| $0.0275 \| \| Dedicated 800 \| Intrastate \| Waived \| Switched \| Dedicated \| $0.0275 \| \| \| \| Waived \| \| \| \| \| Direct Dial \| Inter IntraLATA \| Waived \| Switched \| Switched \| $0.0100 \| \| Direct Dial \| Interstate \| Waived \| Switched \| Switched \| $0.0100 \| \| Direct Dial \| Interstate \| Waived \| Switched \| Dedicated \| $0.0100 \| \| Direct Dial \| Interstate \| Waived \| Dedicated \| Dedicated \| $0.0100 \| \| Direct Dial \| Intra IntraLATA \| Waived \| Switched \| Switched \| $0.0150 \| \| Direct Dial \| Intra IntraLATA \| Waived \| Switched \| Dedicated \| $0.0150 \| \| Direct Dial \| Intra IntraLATA \| Waived \| Dedicated \| Switched \| $0.0150 \| \| Direct Dial \| Intra IntraLATA \| Waived \| Dedicated \| Dedicated \| $0.0150 \| \| Direct Dial \| Intrastate \| Waived \| Switched \| Switched \| $0.0150 \| \| Direct Dial \| Intrastate \| Waived \| Switched \| Dedicated \| $0.0150 \| \| Direct Dial \| Intrastate \| Waived \| Dedicated \| Dedicated \| $0.0150 \| \| Switched 800 \| Canada \| Waived \| Switched \| Switched \| $0.07 \| \| Switched 800 \| Interstate \| Waived \| Switched \| Switched \| $0.0125 \| \| Switched 800 \| Intra IntraLATA \| Waived \| Switched \| Switched \| $0.0275 \| \| Switched 800 \| Intrastate \| Waived \| Switched \| Switched \| $0.0275 \| \| Switched Data \| Interstate \| Waived \| Dedicated \| Switched \| $0.0100 \| \| Switched Data over Dedicated \| Direct Dial \| Waived \| Dedicated \| Dedicated \| $0.0100 \| \| Dedicated T1(LD Trunk) \| \| Waived \| \| $200.00 \| ICB \| \| Dedicated T1(LD Trunk 6 or more at a single location) \| \| Waived \| \| $0.00 \| ICB \| \| FEES LISTED IN SEPARATE RATE SHEET \| \| \| \| \| \| WIRELESS PRICING Wireless 802.11b/g Pricing Base WiFi Management, authentication and security Year 1- $7,050 per month Year 2 to 5- $546 per month Price per Access Point (indoor or outdoor) with coverage up to 300ft. (dependent upon physical location, physical obstructions, and potential rogue wireless interference). Includes maintenance, service and customer support. Year 1- $250 per month Year 2 to 5- $79 per month Backhaul/access to Internet and/or State LAN Pricing is based on standard COI, CBI and MetroE pricing provided in this RFP response and is an additional price to the above costs. In lieu of this the State my elect to use open access or existing Internet or private line connectivity as available whereby eliminating this charge. However in so doing the State acknowledges that Cox has limited abilities to troubleshoot and support APs that do not set behind our network. EXHIBIT C1 SERVICES PRICING DATA NETWORK SERVICES PRICING \| DATA NETWORK SERVICES \| ONETIME COST \| MONTHLY COST(ON-NET) \| MONTHLY COST(OFF-NET) \| PRICE PER CIR MPBS \| AVAILABLE MINIMUM CIR's \| \|---\|---\|---\|---\|---\|---\| \| DS0 \| WAIVED \| NA \| NA \| \| \| \| DS1 \| WAIVED \| $225.00 \| ICB \| \| \| \| DS3 \| WAIVED \| $1,325.00 \| ICB \| \| \| \| Frame Relay \| WAIVED \| NA \| NA \| \| \| \| Fractional T-1 \| WAIVED \| $225.00 \| ICB \| \| \| \| ATM Services \| WAIVED \| ICB \| ICB \| \| \| \| DSL OR CABLE MODEM BUSINESS INTERNET( LISTED BELOW) \| \| \| \| \| \| \| CBI-STARTER 2M/384K DYNAMIC \| WAIVED \| $34.95 \| NA \| \| \| \| CBI BUSINESS 5.0M/1.0M DYNAMIC \| WAIVED \| $64.95 \| NA \| \| \| \| CBI STARTER 2M/384K STATIC \| WAIVED \| $54.95 \| NA \| \| \| \| CBI BUSINESS 5.0M/1.0M STATIC \| WAIVED \| $84.95 \| NA \| \| \| \| CBI ENHANCED 10M/2M STATIC(POWERBOOST 15M/3M) \| WAIVED \| $109.95 \| NA \| \| \| \| CBI PROFESIONAL 15M/3M STATIC(POWERBOOST 20M/2M) \| WAIVED \| $244.95 \| NA \| \| \| \| COX OPTICAL INTERNET ( LISTED BELOW) \| \| \| \| \| \| \| 1.5Mbps \| WAIVED \| $390.00 \| ICB \| \| \| \| 2Mbps \| WAIVED \| $455.00 \| ICB \| \| \| \| 3Mbps \| WAIVED \| $730.00 \| ICB \| \| \| COX BUSINESS SERVICES SW450 CARRIER SERVICES PRICING \| 4Mbps \| WAIVED \| $885.00 \| ICB \| \| \| \|---\|---\|---\|---\|---\|---\| \| 4.5Mbps \| WAIVED \| $965.00 \| ICB \| \| \| \| 5Mbps \| WAIVED \| $1,045.00 \| ICB \| \| \| \| 6Mbps \| WAIVED \| $1,200.00 \| ICB \| \| \| \| 7Mbps \| WAIVED \| $1,355.00 \| ICB \| \| \| \| 8Mbps \| WAIVED \| $1,510.00 \| ICB \| \| \| \| 9Mbps \| WAIVED \| $1,676.00 \| ICB \| \| \| \| 10Mbps \| WAIVED \| $1,830.00 \| ICB \| \| \| \| 15Mbps or Greater \| WAIVED \| ICB \| ICB \| \| \| \| Optical Ethernet Metropolitan Area Network per location (METRO-E w/MPLS)-Best Effort \| \| \| \| \| \| \| 1.5 Ethernet Hardware (must purchase T-1 separate) \| WAIVED \| $100.00 \| ICB \| \| \| \| 3Mbps \| WAIVED \| $550.00 \| ICB \| \| \| \| 10Mbps \| WAIVED \| $800.00 \| ICB \| \| \| \| 50Mbps \| WAIVED \| $1,000.00 \| ICB \| \| \| \| 100Mbps \| WAIVED \| $1,100.00 \| ICB \| \| \| \| 300Mbps \| WAIVED \| $1,800.00 \| ICB \| \| \| \| 500Mbps \| WAIVED \| $2,000.00 \| ICB \| \| \| \| 1 GIG \| WAIVED \| $2,400.00 \| ICB \| \| \| \| 10GIG \| ICB \| ICB \| ICB \| \| \| \| Optical Ethernet Metropolitan Area Network per location (METRO-E w/MPLS)-Real-Time \| \| \| \| \| \| \| 1.5 Ethernet Hardware (must purchase T-1 loop separate) \| WAIVED \| $100.00 \| ICB \| $133.33 \| 1 \| \| 3Mbps \| WAIVED \| $550.00 \| ICB \| $366.67 \| 1 \| \| 10Mbps \| WAIVED \| $800.00 \| ICB \| $160.00 \| 1 \| \| 50Mbps \| WAIVED \| $1,000.00 \| ICB \| $40.00 \| 10 \| COX BUSINESS SERVICES SW450 CARRIER SERVICES PRICING \| 100Mbps \| WAIVED \| $1,100.00 \| ICB \| $22.00 \| 20 \| $1,540.00 \| \|---\|---\|---\|---\|---\|---\|---\| \| 300Mbps \| WAIVED \| $1,800.00 \| ICB \| $12.00 \| 50 \| $2,400.00 \| \| 500Mbps \| WAIVED \| $2,000.00 \| ICB \| $8.00 \| 80 \| $2,640.00 \| \| 1 GIG \| WAIVED \| $2,400.00 \| ICB \| $4.80 \| 100 \| $2,880.00 \| \| 10GIG \| ICB \| ICB \| ICB \| ICB \| ICB \| ICB \| \| Committed Information Rate (Real Time) \| \| \| \| \| \| \| \| This price is for the highest level of Committed Real Time (CIR) with the minimum required level of CIR bandwidth. \| \| \| \| \| \| \| \| Cox has the ability for up to 6 additional classes of service for CIR's, but would need to identify these classes by working with the State for development of ICB Pricing for each class. \| \| \| \| \| \| \| \| Secure Private Network- via HFC \| \| \| \| \| \| \| \| 256K \| WAIVED \| $80.00 \| \| \| \| \| \| 512K \| WAIVED \| $105.00 \| NA \| \| \| \| \| 768K \| WAIVED \| $130.00 \| NA \| \| \| \| \| 1.0Mbps \| WAIVED \| $150.00 \| NA \| \| \| \| \| 1.5Mbps \| WAIVED \| $180.00 \| NA \| \| \| \| \| 2Mbps \| WAIVED \| $205.00 \| NA \| \| \| \| \| 3Mbps \| WAIVED \| $240.00 \| NA \| \| \| \| \| 768K/256K \| WAIVED \| $105.00 \| NA \| \| \| \| \| 1.5M/384K \| WAIVED \| $150.00 \| NA \| \| \| \| \| 3.0M/512K \| WAIVED \| $205.00 \| NA \| \| \| \| \| 6.0M/768K \| WAIVED \| $250.00 \| NA \| \| \| \| COX BUSINESS SERVICES SW450 CARRIER SERVICES PRICING \| 6.0M/2.0M \| WAIVED \| $270.00 \| NA \| \|---\|---\|---\|---\| \| 10M/1.0M \| WAIVED \| $280.00 \| NA \| \| ICB= Individual Case Basis \| \| \| \| \| FEES LISTED IN SEPARATE RATE SHEET \| \| \| \| FEE RATES FOR SERVICES \| \| 65N \| FRF \| BUF \| SUS \| 911 \| EUCL* \| Bulk EUCL* \| \|---\|---\|---\|---\|---\|---\|---\|---\| \| Fee Rates per Dollar \| $0.16 \| $0.02 \| $0.12 \| $0.02 \| $0.03 \| $5.94 \| $29.70 \| \| Table below describes which fee should be applied to each service \| \| \| \| \| \| \| \| \| VOICE NETWORK SERVICES \| \| \| \| \| \| \| \| \| Business Access Line \| N/A \| X \| N/A \| X \| X \| X \| N/A \| \| Direct Inward Dialing (Trunk) \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| Direct Inward Dialing -20 Block \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Direct Inward Dialing -100 Block \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Digital Loop Service \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| SmartTrunk \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| Primary Rate Interface \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| X \| \| Plexar (CENTREX ANALOG) \| N/A \| N/A \| N/A \| X \| N/A \| X (1:8 ratio) \| N/A \| \| Plexar (CENTREX DIGITAL) \| N/A \| N/A \| N/A \| X \| N/A \| X (1:8 ratio) \| N/A \| \| T-1 \| N/A \| N/A \| N/A \| X \| N/A \| (x # of Trunks) \| N/A \| \| Dedicated T1 \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| N/A \| \| Features for voice services listed below \| \| \| \| \| \| \| \| \| Standard features \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Call Forward on Call Waiting \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Caller ID \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Distinctive Ring \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Remote Call Forwarding \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Speed Call 8 \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Speed Call 30 \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Hunting- Per Line \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Voice Mail Box- Basic \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Feature Packages for Voice Products \| \| \| \| \| \| \| \| \| Business ID-CallWaiting,Caller ID,3Way,Speed Call 30, Busy Line Redial, Call Transfer \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Business Value- Call Forward, 3Way, Call Waiting, Speed Call 30, Busy Line Redial, Call Transfer \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \|---\|---\|---\|---\|---\|---\|---\| \| Solutions-Call Forwarding, Call Waiting, Speed Calling - 8, Three-Way Calling, Call Return, Busy Line Redial, Selective Call Acceptance, Selective Call Forwarding, Selective Call Rejection, Call Forwarding - Busy, Call Forwarding - No Answer, Call Forwarding of Call Waiting, Caller ID, Priority Ringing, Long Distance Alert, and Call Waiting ID. \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| USAGE WORKSHEET \| \| \| \| \| \| \| \| Switched Outbound \| \| \| \| \| \| \| \| Intralata/ Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Intralata/ Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Switched 800 \| \| \| \| \| \| \| \| Intralata/ Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Intralata/ Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Dedicated Outbound \| \| \| \| \| \| \| \| Intralata/ Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Intralata/ Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| \| Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Dedicated 800 \| \| \| \| \| \| \| \| \|---\|---\|---\|---\|---\|---\|---\|---\| \| Intralata/ Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Intralata/ Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| N/A \| \| Intrastate \| X \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Interstate \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| N/A \| \| DATA NETWORK SERVICES \| \| \| \| \| \| \| \| \| DS0 \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| DS1 (Interstate) \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| N/A \| \| DS1 (Intrastate) \| N/A \| X \| N/A \| X \| N/A \| N/A \| N/A \| \| DS3 (Interstate) \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| N/A \| \| DS3 (Intrastate \| N/A \| X \| N/A \| X \| N/A \| N/A \| N/A \| \| Frame Relay \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| Ethernet Services \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| DSL OR CABLE MODEM BUSINESS INTERNET( LISTED BELOW) \| \| \| \| \| \| \| \| \| CBI-STARTER 2M/384K DYNAMIC \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| CBI BUSINESS 5.0M/1.0M DYNAMIC \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| CBI STARTER 2M/384K STATIC \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| CBI BUSINESS 5.0M/1.0M STATIC \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| CBI ENHANCED 10M/2M STATIC (POWERBOOST 15M/3M) \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| CBI PROFESIONAL 15M/3M STATIC (POWERBOOST 20M/2M) \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| COX OPTICAL INTERNET ( LISTED BELOW) \| \| \| \| \| \| \| \| \| 1.5Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 2Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 3Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 4Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 4.5Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 5Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \|---\|---\|---\|---\|---\|---\|---\| \| 6Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 7Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 8Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 9Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 10Mbps \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| 15Mbps or Greater \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| T-1 (Interstate) \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| Fractional T-1 (Interstate) \| N/A \| N/A \| X \| N/A \| N/A \| N/A \| \| T-1 (Instrastate) \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| Fractional T-1 (intrastate) \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| Optical Ethernet Metropolitan Area Network Listed Below \| \| \| \| \| \| \| \| 1.5 Ethernet Hardware (must purchase T-1 separate) \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 3Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 10Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 50Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 100Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 300Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \|---\|---\|---\|---\|---\|---\|---\| \| 500Mbps \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 1 GIG \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| 10GIG \| N/A \| X \| N/A \| X \| N/A \| N/A \| \| Secure Private Network- via HFC \| \| \| \| \| \| \| \| 256K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 512K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 768K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 1.0Mbps \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 1.5Mbps \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 2Mbps \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 3Mbps \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 768K/256K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 1.5M/384K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 3.0M/512K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 6.0M/768K \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 6.0M/2.0M \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| 10M/1.0M \| N/A \| N/A \| N/A \| X \| N/A \| N/A \| \| MPLS \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| VPN \| N/A \| N/A \| N/A \| N/A \| N/A \| N/A \| \| Fee Descriptions \| \| \| \| \| \| \| BUF - Federal Universal Service Fund 12.3% FRF - Inspection & Supervision Fee 2% SUS - Oklahoma Universal Se rv ice Fund 1.94% EUCL - End User Fee $5.94 (1:8 Ratio on Centrex) per line or Trunk (2.387% SUS is charged on EUCL or $.77 per EUCL) 911 - E911 Fee 3% Bulk EUCL - Bulk Rate EUCL $29.70 per PRI (2.387% SUS is charged on Bulk EUCL ot $3.83 per Bulk EUCL)	<urn:uuid:23b2d37a-656c-4381-a647-7d2600e9e0ca>	CC-MAIN-2014-10	https://www.ok.gov/dcs/solicit/app/viewAttachment.php?attachmentID=58999	2014-03-10T10:41:49Z	s3://commoncrawl/crawl-data/CC-MAIN-2014-10/segments/1394010746376/warc/CC-MAIN-20140305091226-00053-ip-10-183-142-35.ec2.internal.warc.gz	637,545,149	6,594	eng_Latn	eng_Latn	0.423453	eng_Latn	0.837734	[ "nld_Latn", "unknown", "eng_Latn", "unknown", "unknown", "unknown", "unknown", "unknown", "unknown", "unknown", "unknown", "eng_Latn" ]	false	rolmOCR	[ 2297, 4399, 5327, 6432, 7786, 9129, 9365, 11269, 12616, 14276, 15218, 16570 ]
The images in this file are photographs of the notes of the original surveys of the State of Nebraska on file in the Office of the Nebraska State Surveyor located in Lincoln, Nebraska. The original surveys in Nebraska began in the mid 1850’s and were completed in the mid 1880’s. The Nebraska office of the Surveyor General was closed June 30, 1886. Jovial 5 Range 22W \| \| \| \| \| \| \| \| \|---\|---\|---\|---\|---\|---\|---\| \| 6 \| 54\| 5 \| 40\| H \| 30\| 3 \| \| 53\| \| 39\| 29\| 19\| 10\| \| \| 7 \| 57\| 8 \| 39\| 9 \| 29\| 10\| \| 50\| \| 49\| 28\| 18\| 13\| 8 \| \| 18\| 49\| 17\| 57\| 76\| 27\| 15\| \| 48\| \| 47\| 36\| 26\| 17\| 6 \| \| 19\| 47\| 20\| 55\| 21\| 25\| 22\| \| 46\| \| 45\| 34\| 24\| 16\| 4 \| \| 30\| 44\| 29\| 38\| 23\| 24\| 14\| \| 48\| \| 42\| 32\| 22\| 13\| 2 \| \| 31\| 41\| 32\| 37\| 21\| 34\| 10\| \| \| \| \| \| \| \| \| Sun symbols are present at each corner of the grid. Field Notes of the subdivision lines of Township 5 North of Range 22 West of the 6th Principal Meridian in the State of Nebraska by Philander C. Patterson under his contract No 36 bearing date the 5th day of August 1870 Subdivision Commenced August 30th 1870 Subdivision completed September 6th 1870 List of Names A list of the names of the individuals employed to assist in running, measuring or marking the lines and corners described in the following field notes of Township No. 5 North of Range No. 22 West of the 6th Principal Meridian showing the respective capacities in which they act. William McCartney John R. Tolin David P. Cole Walter C. Dresden Frank Porter, flag man Field Notes of the Subdivision Lines in Township 5 North, Range 22 West 6th P. M. To determine the proper adjustment of my compass for subdividing this township I commence at the corner to section 25 and 36 and run South on a blank line along the East boundary of Section 38. Variation 13° East 40.14 To a point 24 th. West of the ¼ section corner 80.17 To a point 3 ½ th. West of the corner to Townships 5 North Ranges 21 and 22 West. Do retrace this line or run parallel thereto my compass must be adjusted to a variation of 13°01' East Subdivision commenced August 30th 1870 Township 5 N, Range 22 W 6th P.M. North between sections 35 and 36 Na 13° East 40.00 Drove charred stake and set a post in mound with pit for 4th sec. cor. 87.00 Drove charred charred stake and set a post in mound with pit for corner to sections 25, 26, 35 and 36. Land rolling good 2 no Nth. Township 5 N, Range 22 W 6th P.M. East on a random line between sections 25 and 36 Na 13° East 19.30 Turkey creek 20 ft. wide runs South 32.00 S dry creek 5 ft. wide runs S. W. 40.00 Utra post for temporary 4th sec. cor. 79.90 Enterticked the East Boundary 15 ft. South of the corner to sections 25 and 36, from which corner I run 79.90 Won a true line between sections 25 and 36 Na 13° East 39.95 Drove charred stake and set a post in mound with pit for 4th sec cor. 79.90 The corner to sections 25, 26, 35 and 36 Parel rolling, 2 no Nth. Scatting timber along Turkey Creek Elm, ash, and boxelder \| Township 5th N, Range 22 W 6th P.S.M. \| Township 5th N, Range 22 W 6th P.S.M. \| \|-------------------------------------\|-------------------------------------\| \| North between sections 25 and 26 \| East on a random line between \| \| Da 13° East \| sections 24 and 25 \| \| 7.50 Turkey creek 25 lks with runs S.E. \| Da 13° 15' East \| \| 30.54 Lame creek 20 lks with runs S.W. \| Turkey creek 15 lks with runs South \| \| 40.00 Drive a chared stake and set a post in mound with pits for ¼ sec. cor. \| Put a post for temporary ¼ sec. cor. \| \| 43.65 Lame creek 20 lks with runs S.E. \| Intersected the East Boundary 22 lks. \| \| 62.20 Same creek 20 lks with runs West \| South of the corner to sections \| \| 63.90 Game creek 30 lks with runs S.E. \| 24 and 25 from which corner 8 run \| \| 70.80 Same creek 30 lks with runs S.W. \| 389.51 Work a true line between \| \| 80.00 Set a sandstone 12 x 12 x 7 in. for corner to sections 23, 24, 25 and 26 \| sections 24 and 25 \| \| Land broken 3rd knot \| Da 13° 15' East \| \| Featuring timber along creek \| 40.08 Drive a chared stake and set a post in mound with pits for ¼ sec. cor. \| \| Elm, ash and poplars \| 30.06 The corner to sections 23, 24, 25 and 26 \| \| \| Land rolling 2nd knot \| Township 5 N, Range 22 W 6 M P.M North between sections 23 and 24 On 18° East 8.20 A dry creek 10 ft. wide runs East 40.00 O. Ka sand stone 15 x 10 x 5 in., partly seen 44.55 Turkey creek 35 lbs. wide runs S. E., Same creek 50 lbs. wide runs N. W. Oleta sand stone 18 x 12 x 8 in., for corner to section 13, 14, 23 and 24 Land broken 3rd hut Scattering timber along creek Elm, ash and hawthorn East on a random line between sections 13 and 24 On 18° 30' East 4.60 7.70 10.10 40.00 80.08 Turkey creek 40 lbs. wide runs South Same creek 25 lbs. wide runs North Same creek 20 lbs. wide runs South Oleta post for temporary 1/4 sec. cor. Intersected the East Boundary 25 lbs. South of the corner to section 13 and 24 from which corner I run US9049° W on a true line between sections 13 and 24 In 18° 30' East 40.04 From a chareed stone and oleta post in mound with pit for ¼ sec cor. 80.08 The corner to sections 13, 14, 23 and 24 Land broken 3rd hut Scattering elm, ash and hazeldek along creek August 30th 1870 Township 5 N, Range 22 W, 6th P.M. North between sections 13 and 14 Nw 1/8 E East 4.50 Turkey creek 20 ths which runs East 4.70 Enter timber bears S.E. and N.W. 15.50 Same creek 20 ths which runs West 18.60 Leave timber bears E. and W. 40.00 Delta sandstone 15 x 11 x 5 in., for 1/4 sec. cor. 80.00 Delta sandstone 15 x 12 x 9 in., for corner to sections 11, 12, 13 and 14 Land broken and rocky Timber elm, ash and hackberry Township 5 N, Range 22 W, 5th P.M. East on a random line between sections 12 and 13 Nw 1/8 45' East 21.00 Enter timber bears N. and S. 22.40 Turkey creek 10 ths which runs South 11.11 Leave timber bears S.E. and North 40.00 Delta post for temporary 1/4 sec. cor. Intersection the East boundary 16 ths. South of the corner to section 12 and 13 from which corners run S 89° 55' W on a true line between sections 12 and 13 Nw 1/8 45' East 39.92 Drive a hard stake and set a post in Morine Smith pits for 1/4 sec. cor. 79.84 The corner to sections 11, 12, 13 and 14 Land broken and gravelly 5' high Township 5 N, Range 22 W, 6th P.M. North between sections 11 and 12 Nw 1/4 Sec East 40.00 Set a sand stone 16 x 12 x 6 in for corner to sections 11, 12, 11 and 12 from which A Cottonwood 12 in. dia. bears 133° E 19 lbs. dist Land broken 3rd cut 80.00 Set a sand stone 14 x 12 x 6 in for corner to sections 1, 2, 11 and 12 from which A Cottonwood 12 in. dia. bears 133° E 19 lbs. dist Land broken 3rd cut East on a random line between sections 1 and 12 Nw 1/4 Sec East 2.90 Dug a trench 30 lbs. wide row South Enter timber bears N.W. and S.E. Leave timber bears N.E. and S.E Set a post for temporary 1/4 sec. cor. Intersection the East Boundary 28 lbs. South of the corner to sections 1 and 12 from which Corner Brun S 89° 48' W on a true line between sections 1 and 12 Nw 1/4 Sec East 39.83 Drove a chared stake and set a post in Mound with jets for 1/4 sec. cor. The corner to sections 1, 2, 11 and 12 Land broken 3rd cut 79.66 Township 5 N, Range 22 W 6th P.M. North on a random line between sections 1 and 2 In 13° East 3,10 A spring branch 10 lbs. wide runs S.E. 58,20 Creek 15 lbs. 40,00 Set a post for temporary ¼ sec. cor. 58,20 Creek 16 lbs. wide runs S.E. " " Enter timber bears E. & S.W. 65,10 Same creek 15 lbs. wide runs N. W. 71,60 Same creek 16 lbs. wide runs East " " Leave timber bears E. and N. 81,82 Intersected the North Boundary 50 lbs. West of the corner to sections 1 and 2 from which corner S. run Dr. 21 Won a true line between sections 1 and 2 In 18° East 41,82 Drove a charred stake and set a post in a mound with pits for ¼ sec. cor. 81,82 The corner to sections 1, 2, 11 and 12 Land broken 3rd rate Timber Elm, ash, and hickory August 8th 1870 Township 5 N, Range 22 W 6th P.M. North between sections 34 and 35 In 13° East 40,00 Drove a charred stake and set a post in a mound with pits for ¼ sec. cor. 80,00 Drove a charred stake and set a post in a mound with pits for corner to sections 26, 27, 34 and 35 Land gently rolling good 2nd rate Township 5 N, Range 22 W, 6th P.M. East on a random line between sections 26 and 35 79.40 From a charred stake and set a post in a mound with pits for 1/4 sec. cor. North of the corner to sections 25, 26, 35 and 36 from which corner run N89°47' W on a true line between sections 26 and 35 79.40 From a charred stake and set a post in a mound with pits for 1/4 sec. cor. The corner to sections 25, 26, 34 and 35 Land broken 3rd Rate Township 5 N, Range 22 W, 6th P.M. North between sections 26 and 27 79.40 From a charred stake and set a post in a mound with pits for 1/4 sec. cor. To sections 22, 23, 25 and 27 Land Holliger 2nd Rate Township 5 N, Range 22 W 6th P.M. East on a random line between sections 23 and 26 Na 12°45' East 40.00 Beta post for temporary sec. cor., 79.54 Enters to E. and S. line 27 1/8 ks. North of corner to sections 23, 24, 25 and 26 from which earn 8 Prun. 189-48 West true line between sections 23 and 26 Na 12°45' East 39.77 From a charred stake and set a post in mound with pits for sec. cor. 79.54 The corner to sections 22, 23, 24 and 25 Land rolling 2nd knot North between sections 22 and 25 Na 13°15' East 40.00 From a charred stake and set a post in mound with pits for sec. cor. 79.54 From a charred stake and set a post in mound with pits for corner to sections 14, 15, 22 and 23 Land rolling 2nd knot \| Township 5 N, Range 22 W, 6th P.M. \| Township 5 N, Range 22 W, 6th P.M. \| \|----------------------------------\|----------------------------------\| \| East on a random line between sections 14 and 23 \| East on a random line between sections 11 and 14 \| \| Na 12°45' East \| Na 12°30' East \| \| 79.75 Set a post for temporary ¼ sec. cor. \| 79.84 Set a post for temporary ¼ sec. cor. \| \| North of the corner to sections 13, 14, 23 and 24 from which corner run N 89°58' W on a true line between sections 14 and 23 \| North of the corner to sections 11, 12, 13 and 14 from which corner run N 89°58' W on a true line between sections 11 and 14 \| \| 39.83 From a charred stake and set a post in mound with pits for ¼ sec. cor. \| 39.92 From a charred stake and set a post in mound with pits for ¼ sec. cor. \| \| 79.76 The corner to sections 14, 15, 22 and 23 Land broken 3rd Rat. \| 79.84 The corner to sections 10, 11, 14 and 15 Land rolling good 2nd Rat. \| \| North between sections 14 and 13 \| North between sections 10 and 11 \| \| Na 18°15' East \| Na 15° East \| \| 40.00 From a charred stake and set a post in mound with pits for ¼ sec. cor. \| 40.00 From a charred stake and set a post in mound with pits for ¼ sec. cor. \| \| 80.00 From charred stake and set a post in mound with pits for corner to sections 10, 11, 14 and 15 Land gently rolling good 2nd Rat. \| 8.000 From a charred stake and set a post in mound with pits for corner to sections 2, 3, 10 and 11 Land broken 3rd Rat. \| Township 5 N, Range 22 W, 6th P.M. East on a random line between sections 2 and 11 Da 12°30' East 40.00 Set a post for temporary ¼ sec. cor. 80.00 Entersected Kansas D. line 14 lks. north of the corner to sections 1, 2, 11 and 12 from which corner ½ rum N 89°34' W on a true line between sections 2 and 11 Da 12°30' East 40.00 From a charred stake and set a post in mound with pit for ¼ sec. cor. 80.00 The corner to sections 2, 3, 10 and 11 Land broken 3rd plat. North on a random line between sections 2 and 3 Da 18° East 40.00 Set a post for temporary ¼ sec. cor. 81.47 Entersected the North Boundary 48 lks. West of the corner to sections 2 and 3 from which corner ½ rum S 28° W on a true line between sections 2 and 3 Da 18° East 41.47 Drew charred stake and set a post in mound with pit for ¼ sec. cor. 81.47 The corner to sections 2, 3, 10 and 11 Land rolling 2nd plat. September 1st 1870 \| Township 5 N, Range 22 W, 6 T.P.M. \| Township 5 N, Range 22 W, 6 T.P.M. \| \|----------------------------------\|----------------------------------\| \| North between sections 33 and 34 \| East on a random line between \| \| 70.00 From church stake and set a post in Mount. Butt fits for 4 sec. cor. \| sections 27 and 34 \| \| 42.00 Dry creek 15 lks. wide runs West \| 7.65 Dry creek 12 lks. wide runs South \| \| 80.00 From church stake and set a post in Mount. Butt fits for corner to sections 27, 28, 33 and 34 \| 17.30 Dry creek 16 lks. wide runs South \| \| Land broken 3rd knot \| 40.00 Set a post for temporary 4 sec. cor. \| \| \| 79.20 Intersected Ward & line 13 lks. North of the corner to sections 25, 27, 34 and 35 from which corner 6th run \| \| \| 47.89 54' Wona true line between Sections 27 and 34 \| \| \| 39.60 From a church stake and set a post in Mount. Butt fits for 4 sec. cor. \| \| \| 79.20 The corner to sections 27, 28, 33 and 34 \| \| \| Land rolling 2nd knot \| Township 5th N, Range 22 W, 6th P.M. North between sections 27 and 28 Va 15° 15' East 4,000 Drove a charred stake and set a post in mound with pit for ¼ sec cor 90,000 Drove charred stake and set a post in mound with pit for corner to sections 21, 22, 27 and 28 Lanels broken 5th Ruth East on a random line between sections 22 and 27 Va 15° East 4,35 Drove a charred stake and set a post in mound with pit for temporary sec. cor. 28,35 Interscribed cord & line 9 lbs. 70,00 79,45 North of the corona to sections 22, 23, 24 and 27 from which corner P run 1,89,56 Wona true line between sections 22 and 27 Va 15° East 39,78 Drove a charred stake and set a post in mound with pit for ¼ sec. cor. 79,45 The corner to sections 21, 22, 27 and 28 Lanels rolling 2nd Ruth Township 5 N, Range 22 W, 5th P.M. North between sections 21 and 22 On 13° 20' East 40.00 Drove charred stake and set a post in mound with pits for 1/4 sec. cor 45.50 Dr. creek 50 lbs. midcourse S. E., 80.00 From a charred stake and set a post in mound with pits for corner to sections 15, 16, 21 and 22 Land broken 3rd kat Township 5 N, Range 22 W, 5th P.M. East on a random line between sections 15 and 22 On 13° East 37.65 Dr. creek 12 lbs. which runs South 40.00 Set a post for temporary 1/4 sec. cor, Intersected V and V line at the corner to sections 14, 15, 22 and 23 from which corners I run West on a true line between sections 15 and 22 On 13° East 39.70 Drove a charred stake and set a post in mound with pits for 1/4 sec. cor The corner to sections 15, 16, 21 and 22 Land rolling 2nd kat Township 5th, Range 22 W 6th P.M. South between sections 13 and 15 Da 18° 25' East 40.00 Drive a charred stake and set a post in mound with pit for 4 sec. cor. 30.00 Drive a charred stake and set a post in mound with pit for corner to sections 9, 10, 15 and 15 Land South part broken North part gently rolling good 2nd Kat. Township 5th, Range 22 W 6th P.M. East on a random line between sections 10 and 15 Da 18° East Dry creek 15 ft. wide runs South Set a post for temporary sec. cor. Buried tied N. and S. line at the corner to sections 10, 11, 14 and 15 from which corner D. run Weston a true line between sections 10 and 15 Da 15° East 39.71 Drive a charred stake and set a post in mound with pit for 4 sec. cor. The corner to sections 9, 10, 15 and 15 Land rolling good 2nd Kat. Township 5 N, Range 22 W, 6th R.M. North between sections 9 and 10 Nw 13° East 40.00 Drove a charred stake and set a post in mound with pits for 44 sec. cor. 80.00 Drove a charred stake and set a post in mound with pits for corner to sections 3, 4, 9 and 10 Land gently rolling good 2nd R.R. East on a random line between sections 3 and 10 Nw 13° East 11.47 Driven 25 lbs. Nick runs S. E. 40.00 Set a post for temporary 44 sec. cor. 79.46 Unrestricted N. and S. line at the corner to sections 2, 3, 10 and 11 from which corner 45' run West on a true line between sections 3 and 10 Nw 13° East 39.73 Drove a charred stake and set a post in mound with pits for 44 sec. cor. 79.46 The corner to sections 3, 4, 9 and 10 Land rolling 2nd Nat. North on a random line between sections 3 and 4 Nw 13° 10' East 40.00 Set a post for temporary 44 sec. cor. 81.36 Unrestricted N. and S. line at the corner to sections 3 and 4 from which corner 45' run Nw 3° W on a true line between sections 3 and 4 Nw 13° 10' East 41.36 Drove a charred stake and set a post in mound with pits for 44 sec. cor. 81.36 The corner to sections 3, 4, 9 and 10 September 2nd 1870 Township 5 N, Range 22 W, 6th P.M. North between sections 32 and 33 Nw 1/4 Sec East 41.70 Drove a charred stake and set a post in a mound with pit for ¼ sec cor 78.76 Dry creek 10 lbs wide runs East 80.00 Drove charred stake and set a post in mound with pit for corner to sections 23, 29, 32 and 33 Land rolling 2nd hute Township 5 N, Range 22 W, 6th P.M. East on a random line between sections 28 and 33 Nw 1/4 Sec East 11.59 Drove a charred stake and set a post for temporary sec cor 79.58 Intersection N and S line 20 lbs North of the corner to sections 27, 28, 33 and 34 from which corner to run N 89° 51' W on a true line between sections 28 and 33 Nw 1/4 Sec East 39.69 Drove a charred stake and set a post in a mound with pit for ¼ sec cor 79.83 The corner to sections 28, 29, 32 and 33 Land rolling 2nd hute Township 5 N, Range 22 W, 6th P.M. North between sections 28 and 29 Ra 13° East 40.00 Drove a charged stake and set a post in mound with pit for ¼ sec. cor. $5.00 Drove a charged stake and set a post in mound with pit for corner to sections 20, 21, 28 and 29 Land rolling 2nd cut East on a random line between sections 21 and 28 Ra 13° East 11.10 Dr. erah 20 lbs. wire runs N. E. 79.45 Set a post for temporary ¼ sec. cor Dnk section 4 and 8, line 20 lbs. North of the corner to sections 21, 22, 27 and 28 from which corner to run N 89° 57' Wona true line betwen sections 21 and 28 Ra 13° East 39.73 Drove a charged stake and set a post in mound with pit for ¼ sec. cor 79.45 The corner to sections 20, 21, 28 and 29 Land rolling 2nd cut \| Township 5 N, Range 22 W, 6th P.M. \| Township 5 N, Range 22 W, 6th P.M. \| \|----------------------------------\|----------------------------------\| \| North between sections 20 and 21 \| East on a random line between \| \| Na 18°20' East \| sections 16 and 21 \| \| 40.00 Drove a chared stake and set a post in Mount with pit for 4 dec. cor. \| Na 18° East \| \| 69.40 Adry creek 20 lks. wide runs S. E. \| A dry creek 15 lks. wide runs South \| \| 75.70 Jameby creek 15 lks. wide runs S. W. \| Intersected N and S line 14 lks. North of the corner to sections 15, 16, 21 and 22 from which corner I ran \| \| 80.00 Drove a chared stake and set a post in Mount with pit for corner to sections 15, 17, 20 and 21 \| 89.54 Won a true line between sections 15 and 21 \| \| Land broken 3rd kat. \| Na 18° East \| \| \| 39.78 Drove a chared stake and set a post in Mount with pit for 4 dec. cor. \| \| \| 79.46 The corner to sections 16, 17, 20 and 21 \| \| \| Land rolling 2nd kat. \| Township 5 N, Range 22 W, 6th P.M. North between sections 14 and 17 Va 18° 25' East 11.90 A dry creek 15 lbs. with runs S.E. 15.20 Same dry creek 20 lbs. with runs N.W. 18.90 Same dry creek 20 lbs. with runs S.E. 40.00 Drive a charred stake and set a post in mound with pit for 3rd sec. cor. 50.00 Drive a charred stake and set a post in mound with pit for corner to sections 8, 9, 15 and 17 Land broken 3rd cut Township 5 N, Range 22 W, 6th P.M. East on a random line between sections 9 and 15 Va 18° East 40.00 Set a post for temporary sec. cor. drain 20 lbs. with ram 8.6 79.40 Uncharred stake and 3' time 10 lbs. North of corner to sections 9, 10, 15 and 17 from which corner driven 18.90 55' Wana line between sections 9 and 15 Va 18° East 39.70 Drive a charred stake and set a post in mound with pit for 4th sec. cor. 79.40 The corner to sections 8, 9, 15 and 17 Land rolling 2nd cut Or bed of dry creek Township 5 N, Range 22 W, 6th P.M. North between section 8 and 9 On 13° 15' East 40.00 From a charred stake and set a post in mound with pits for sec. cor. 80.00 From a charred stake and set a post in mound with pits for corner to sections 4, 5, 8 and 9 Land rolling 2nd plat East on a random line between sections 4 and 9 On 13° East 24.35 Dry creek 10 lbs. thick runs S. E., 40.00 Set a post for temporary 4th sec. cor. 53.60 Dry creek 12 lbs. thick runs South 79.48 Intersected K and S. line at the corner to sections 3, 4, 9 and 10 from which corner Drun West on a true line between sections 24 and 9 On 13° East 39.74 From a charred stake and set a post in mound with pits for 4th sec. cor. 79.48 The corner to sections 4, 5, 8 and 9 Land rolling 2nd plat September 3rd 1870 Township 5 E, Range 22 W, 6th P.M. North between section 31 and 32 1a 13° 10' East 40.00 Drove a chared stake and set a post in mound with pits for 14 sec. cor. 60.00 Drove a chared stake and set a post in a mound with pits for corner to sections 29, 30, 31 and 32 Land gently rolling good 2nd plat East on a random line between sections 29 and 32 1a 15° East 40.00 Drove a post for temporary sec. cor. 75.30 A Slough 20 lks. which runs South intersected N. and S. line at the corner to section 29, 30, 31 and 32 from which corner I drove West on a true line between sections 29 and 32 80.00 1a 13° East 40.00 Drove a chared stake and set a post in mound with pits for 14 sec. cor. 80.00 The corner to sections 29, 30, 31 and 32 Land rolling good 2nd plat Township 5th N, Range 22 W, 6th P.M. West on a random line between sections 30 and 31 Va 13° East 40.00 Set a post for temporary corner Dry ravine 10 lbs., wide draws South 78.90 Subsided the wet boundary 20 lbs. South of the corner to section 30, and 31 from which corner from S 89° 51' East on a true line between sections 30 and 31 Va 13° East 39.90 Drive a charred stake and set a post in mound with pit for corner to sections 29, 30, 31 and 32 Land broken 5th rate Township 5th N, Range 22 W, 6th P.M. North between sections 29 and 30 On 13° 10' East 40.00 Drive a charred stake and set a post in mound with pit for corner to sections 19, 20, 29, 30 and 31 Land rolling 2nd rate Township 5 N, Range 22 W, 6th P.M. East on a random line between sections 20 and 29 Nw 18° East 30.80 A ram 20 lks. Niche runs South Set a post for temporary loc. cor Intersected N. and S. line 10 lks. North of the corner to sections 20, 21, 28 and 29 from which corner to run N 89° 56' Won a true line between sections 20 and 29 Nw 18° East 39.99 Drove a charel stake and set a post in a mound with pit for 4 sec. cor The corner to sections 19, 20, 29 and 30 Land broken 3rd plat Township 5 N, Range 22 W, 6th P.M. West on a random line between section 19 and 30 Nw 18° East 74.70 Set a post for temporary 4th loc. cor & Slouch 30 lks. while runs N. &. Intersected the most Bonnefay 3 lks. South of the corner to sections 19 and 30 from which corner to run N 89° 59' East on a true line between sections 19 and 30 Nw 18° East 40.10 From a charel stake and set a post in a mound with pit for 4 sec. cor. The corner to sections 19, 20, 29 and 30 Land broken 3rd plat Township 5 N, Range 22 W, 6th P.M. North between section 19 and 20 On 13° 20' East 40.00 Drove a chard stake and set a post in a mound with pit for 4 dec cm 87.00 Drove a chard stake and set a post in a mound with pit for corner to sections 17, 18, 19 and 20 Land rolling 2" Ruth East on a random line between sections 17 and 20 On 13° East 40.00 Set a post for temporary ¼ sec cor 79.98 Intersected Sand & S. line 20 mls North of the corner to sections 15, 17, 20 and 21 from which corner I run N 89° 05' Wona true line between section 17 and 20 On 13° East 39.99 Drove a chard stake and set a post in a mound with pit for 4 dec cm, 78.98 The corner to section 17, 18, 19 and 20 Land broken 3" Ruth West on a random line between sections 18 and 19 On 13° East 40.00 Set a post for temporary ¼ sec cor 79.97 Intersected the West Boundary 12 mls North of the corner to sections 18 and 19 from which corner I run North 89° 33' Eona true line between section 18 and 19 On 13° East 39.97 Drove a chard stake and set a post in a mound with pits for 4 dec cm, 78.97 The corner to section 17, 18, 19 and 20 Land rolling 2" Ruth September 5th 1870 \| North between section 17 and 18 \| \|---------------------------------\| \| 40.00 From a charged stake and set a post in a mound with pits for 1/4 sec, cor \| \| 80.00 From a charged stake and set a post in a mound with pits for corner to sections 7, 8, 17 and 18 \| \| Land rolling, 2nd rate \| \| East on a random line between sections 8 and 17 \| \|-----------------------------------------------\| \| 40.00 Set a post for temporary ¼ sec, cor \| \| 79.90 Intersection Island 3' N, Line 14 ½ hrs, North of the corner to section 8, 9, 16 and 17 from which corner I run \| \| 1/89.534 On a true line between sections 8 and 17 \| \| 1/13° East \| \| West on a random line between sections 7 and 18 \| \|-----------------------------------------------\| \| 40.00 Set a post for temporary ¼ sec, cor \| \| 79.45 Intersection the West Boundary 15 ½ hrs, start of the corner to section 7 and 18 from which corner I run \| \| 1/89.531 On a true line between sections 7 and 18 \| \| 1/13° East \| \| 39.45 From a charged stake and set a post in mound with pits as per instruction for ¼ sec, cor \| \| 79.45 The corner to section 7, 8, 17 and 18 \| \| Land gently rolling good, 2nd rate \| Township 5 N, Range 22 W, 6th P.M. North between section 7 and 8 Via 13° 20' East 40.00 Drop a chared stake and set a post in a mound with pits for ¼ sec. cor. 80.00 Drop a chared stake and hit a post in mound with pits for corner to sections 5, 6, 7 and 8 Lavel rolling 2nd rate Township 5 N, Range 22 W, 6th P.M. East on a random line between section 5 and 8 Via 13° East 40.00 Set a post for temporary ¼ dec. cor. 79.92 Subscribed S and S, line 12 lks. North of the corner to sections 4, 5, 8 and 9 from which corners run N 8° 55' W on a true line between sections 6 and 8 Via 13° East 39.96 Drop a chared stake and set a post for temporary in mound with pits for ¼ sec. cor. 79.92 The corner to sections 5, 6, 7 and 8 Lavel rolling 2nd rate Township 5 N, Range 22 W, 6th P.M. West on a random line between sections 6 and 7 N 13° East 40.00 Set a post for temporary 44 Sec. cor. 79.10 Intersected the West Boundary 18 Mts. North of the corner to sections 6 and 7 from which corner I run N 39° 55' E. on a true line between section 6 and 7 N 13° East 39.10 Draw a chard stake and set a post in Mound with pits for 44 Sec. cor. The corner to section 5, 6, 7 and 8 Land rolling 2nd Kate North between on a random line between sections 5 and 6 N 13° 20' East 40.00 Set a post for temporary 44 Sec. cor. 79.10 Intersect the North Boundary 12 Mts. East of the corner to sections 5 and 6 from which corner I run N 5° E. on a true line between section 5 and 6 N 13° 20' East 40.44 Draw a chard stake and set a post in Mound with pits for 44 Sec. cor. The corner to section 5, 6, 7 and 8 Land rolling 2nd Kate September 6th 1870 General Description The land in this township is generally rolling good 2nd knot prairie. Turkey creek runs through the eastern part of the township on which there is considerable timber, principally elm, ash, hackberry and boxelder. There are some sand stone along the creek. The land along the creek is very broken. We hereby certify that we assisted Philander C. Patterson, deputy surveyor in subdividing Township 5 North of Range 22 West of the 6th Principal Meridian, and that said Township has been in all respects to the best of our knowledge and belief, well and faithfully surveyed, and the boundary monument planted according to the instruction furnished by the Surveyor General. William McLeanty John R. Polin David P. Cole Walter C. Doyden Frank Porter Subscribed and sworn to by the above named persons before me a Justice of the Peace for the County of Cass in the State of Nebraska this 21st day of Oct 1870. G.S. Patterson L.S. F. Philander C. Patterson, Deputy Surveyor, do solemnly swear that in pursuance of a contract with Robert R. Livingston, Surveyor of the public lands of the United States in the State of Nebraska, bearing date the 5th day of August 1870, and in strict conformity to the laws of the United States and the instructions furnished by the said Surveyor General, I have faithfully surveyed the subdivision lines in Township 5 North of Range 22 West of the 6th P.M., and do further solemnly swear that the foregoing are the true and original field notes of such survey. Philander C. Patterson Deputy Surveyor Described by said Philander C. Patterson, Deputy Surveyor, and sworn to before me a Justice of the Peace for Cass County in the State of Nebraska this 21st day of Oct 1870. J. D. Patterson J. P. Surveysor General's Office Plattsmouth, Neb., Feb. 1, 1871. In foregoing field notes of the survey of the subdivision lines of Township No. 5 North of the Base Line, of Range No. 22 West of the Sixth Principal Meridian in the State of Nebraska, executed by Philander C. Patterson under his contract of the 5th day of August 1870, in the months of August and September 1870, having been critically examined, the necessary corrections and explanations made, the said field notes and the surveys they describe are hereby approved. R. R. Livingston Surveyor General. Towel 6 Range 22 W \| \| \| \| \| \| \| \| \| \| \| \|---\|---\|---\|---\|---\|---\|---\|---\|---\|---\| \| 1 \| 2 \| 3 \| 4 \| 5 \| 6 \| 7 \| 8 \| 9 \| 10\| \| 11\| 12\| 13\| 14\| 15\| 16\| 17\| 18\| 19\| 20\| \| 21\| 22\| 23\| 24\| 25\| 26\| 27\| 28\| 29\| 30\| \| 31\| 32\| 33\| 34\| 35\| 36\| 37\| 38\| 39\| 40\| \| 41\| 42\| 43\| 44\| 45\| 46\| 47\| 48\| 49\| 50\| \| 51\| 52\| 53\| 54\| 55\| 56\| 57\| 58\| 59\| 60\| Sub Deputy Justice State Field Notes of the survey of the subdivision lines of Township 6 North of Range 22 West of 6th Principal Meridian in the State of Nebraska by Philander C. Patterson under his contract No. 36 bearing date the 5th day of August 1870. Subdivision commenced August 19th 1870 Subdivision completed August 27th 1870 List of Names A list of the names of the individuals employed to assist in running, measuring or marking the lines and corners described in the following field notes of Township No 6 North of Range No 22 West of the 6th Principal Meridian, showing the respective capacities in which they acted. Walter C. Dryden Chairman William McCartery Chairman David M. Cole Ground Man John R. Polin Ground Man D. T. Porter Flag Man Field notes of the subdivision in Township 6 North, Range 22 W 6th P.M. To determine the proper adjustment of my compass for subdividing this Township I commences at the corner to Townships 5 and 6 North Ranges 21 and 22 West and run North on a blank line along the East Boundary of Section 36. Variation 13° 30' East 40.19 To a point 30 lbs. West of center. 80.27 To a point 75 lbs. West of corner to sections 25 & 36. To retrace this line or run parallel there my compass must be adjusted to a variation of 12° 58' East. Subdivision commenced August 19th 1870 Subdivision complete August 27th 1870 Township 6 N, R 22 W 6th P.M. From the corner to sections 1, 2, 35 and 36 on the South Boundary of the Township from North between sections 35 and 36 N 18°10' East 40.00 Draw a charred stake and set a post in a mound with pits as per instructions for ¼ sec cor $0.00 Township 6 N Range 22 W 6th P.M. East on a random line between sections 25 and 36 N 12° East 40.00 Set a flag for temporary location 79.76 Undertook the East boundary line 6 1/2 ks. South of stone corner to section 25 and 36 from which corner I run N 89°57' W on a true line between sections 25 and 36 N 12° East 39.88 Draw a charred stake and set a post in a mound with pits as per instructions for ¼ sec cor 79.76 The corner to sections 25, 26, 36 and 35 Land broken 3rd rate August 19th 1870 Township 6 N, Range 22 W 6th P.M. North between sections 25 and 26 Va 18°30' East 40.00 Draw a charred stake and set a post in mound with pits as per instructions for 44 sec. cor. 80.00 Draw a charred stake and set a post in mound with pits as per instructions for corner to sections 23, 24, 25 and 26 on the south side of a gully. Land rolling 2nd rate Township 6 N, Range 22 W 6th P.M. East on a random line between sections 24 and 25 Va 12°15' East 40.00 Set a flag for temporary & die, cor. 79.74 Intersected the East Boundary line 10 links North of stone corner to sections 24 and 25 from which corner 36 run 189.56 Won a true line between sections 24 and 25 Va 12°15' East. 39.87 Draw a charred stake and set a post in a mound with pits as per instructions for 44 sec cor. 79.74 The corner to sections 23, 24, 25 and 26 Land broken 3rd rate Township 6 N, Range 22 W 6th P.M. North between sections 23 and 24 Va 15° 30' East 40.00 Drove a charred stake and set a post in a mound with pits as per instructions for ¼ sec. cor. 80.00 Drove a charred stake and set a post in mound with pits as per instructions for corner to sections 13, 14, 23 and 24 Land broken 3rd rate Township 6 N, Range 22 W 6th P.M. East on a random line between sections 18 and 24 Va 12° 15' East 40.00 Let a flag for temporary ty-sec. cor. 79.80 Intersected the East boundary line 51K. South of 1st corner to sections 18 and 24 from which corner to run U 89.58' Wona true line between sections 18 and 24 Va 12° 15' East 39.70 Drove a charred stake and set a post in mound with pits as per instructions for ¼ sec. cor. 79.44 3rd corner to sections 13, 14, 23 and 24 Land East ¾ broken West half rolling 2nd rate Township 6 N, Range 22 W, 6 U.S. S.T.M. North between sections 13 and 14 Via 14° East 40.00 Draw a charred stake and set a post in mound with pits as per instructions for ¼ sec. cor. 80.00 Draw a charred stake and set a post in a mound with pits as per instructions for corner to sections 11, 12, 13 and 14 Land rolling 2nd rate Township 6 N, Range 22 W, 6 U.S. S.T.M. East on a random line between sections 12 and 13 Via 12° 20' East 40.00 Set a post for temporary ¼ sec. cor. 79.74 Intersected the East Boundary 14 lks. North of the corner to sections 12 and 13 from which corner to run N 89° 52' W ran a true line between sections 12 and 13 Via 12° 20' East 39.87 Draw a charred stake and set a post in mound with pits as per instructions for ¼ sec. cor. 79.74 The corner to section 11, 12, 13 and 14 Land broken 8th rate Township 6 N, Range 22 W, 6th P.M. North between Sections 11 and 12 Va. 14° 10' East 40.00 Draw a charred stake and set a post in mound with pits as per instructions for ¼ section 50.00 Draw a charred stake and set a post in mound with pits as per instructions for corner to sections 1, 2, 11 and 12 Land broken & re-kate Township 6 N, Range 22 W, 6th P.M. East on a random line between sections 1 and 12 Va. 12° 20' East 40.00 Set a post for temporary ¼ sec cor Intersected East Boundary 10 lks South of corn to sections 1 and 12 from which corner to run Va. 89° 56' West a true line between sections 1 and 12 Va. 12° 20' East 39.93 Draw charred stake and set a post in mound for both pits as per instructions for ¼ sec cor The corner to sections 1, 2, 11 and 12 Land broken & re-kate Township 6 Range 22 W of the 6th P.M. North on a random line between sections 1 and 2 Na 14°10' East 40,00 celta past for temporary ¼ sec cor 80,44 Intersected the North Boundary 60 lbs west of the corner to sections 1 and 2 from which corner 9 run S 10°26' W on a true line between sections 1 and 2 Na 14°10' East 40,44 Draw a chared stake and set a post in Mound with pits as per instructions for ¼ sec cor 80,44 The corner to sections 1, 2, 11 and 12 Land broken 8 ½ rate August 20th 1870 Township 6 N Range 22 W of the 6th P.M. North between sections 34 and 35 Na 13°30' East 40,00 Draw a chared stake and set a post in Mound with pits as per instructions for ¼ sec cor 69,10 A creek 20 lbs. niche runs S. & E. Draw a chared stake and set a post in Mound with pits as per instructions for corner to secs 26, 27, 34 and 35 Land rolling 2 ½ rate Scattering timber along creek Limb, Elm, and ash \| Township 6 N, Range 22 W, 6th S.T.M \| Township 6 N, Range 22 W, 6th S.T.M \| \|-----------------------------------\|-----------------------------------\| \| East on a random line between sections 26 and 35 Na 18°30' East 40.00 Set a post for temporary ¼ sec. cor 79.80 Intersected N and S line 24 lbs South of the corner to sections 25, 26, 35 and 36 from which corner I ran $89.50 West on a true line between sections 26 and 35 Na 18°30' East 39.90 Drove charred stake and set a post in mound with pits as per instructions for ¼ sec. cor 79.80 The corner to sections 26, 27, 34 and 35 Land rolling 2nd Kata \| North between sections 26 and 27 Na 18°45' East 240.00 Drove a charred stake and set a post in mound with pits as per instructions for ¼ sec. cor 80.00 Drove a charred stake and set a post in mound with pits as per instructions for corner to sections 22, 23, 26 and 27 Land rolling 2nd Kata \| Township 6 N, Range 22 W 6th P.M. East on a random line between sections 23 and 26 Via 18°30' East 40.00 Set a post for temporary 3/4 dec. cor. 79.94 Intersected the N and S line 34 South of the corner to sections 23, 24, 25 and 26 from which corner S run S 89°59' Won a true line between sections 23 and 26 Via 18°30' East 39.97 Drove a charred stake and set a post in a Mound with pits as per instructions for 3/4 dec. cor. 79.94 The corner to sections 22, 23, 26 and 27 Land rolling 2nd Kat. North between sections 22 and 23 Via 18°45' East 40.00 Drove a charred stake and set a post in a Mound with pits as per instructions for 3/4 dec. cor. 80.00 Drove a charred stake and set a post in a Mound with pits as per instructions for 3/4 dec. cor. corner to sections 14, 15, 22 and 23 Land broken 3rd Kat. Township 6 N, Range 22 W 6th P.M. East on a random line between sections 14 and 23 N 13° 30' East 40.00 Set a flag for temporary ¼ sec cor 80.02 Intersected N and S line 28 lks South of the corner to section 13, 14, 23 and 24 from which corner & run S 89° 48' Wona trim line between sections 14 and 23 N 18° 30' East 40.01 Drove a chared stake & set a post in a mound with pits as per instructions for ¼ sec cor 80.02 The corner to sections 14, 15, 22 and 23 Land rolling 2nd flat North between sections 14 and 15 N 14° East 40.00 Drove a chared stake and set a post in a mound with pits as per instructions for ¼ sec cor 80.00 Drove a chared stake and set a post in a mound with pits as per instructions for corner to sections 10, 11, 14 and 15 Land broken 2nd flat Township 6 N, Range 22 W 6th P.M. East on a random line between sections 11 and 14 Ma 13° 30' East 40.00 Oleta flag for temporary sec cor 80.04 Intersect N and S line 24 lbs South of the corner to sections 11, 12, 13 and 14 from which corner to run S 39° 50' W on a true line between sections 11 and 14 Ma 13° 30' East 40.02 Drive a charred stake and set a post in mound with pits as per instructions for 4th sec cor 80.04 The corner to sections 10, 11, 14 and 15 Land broken 5" kat August 22nd 1870 Township 6 N, Range 22 W 6th P.M. North between sections 10 and 11 Ma 14° 10' East 40.00 Drive a charred stake & set a post in mound with pits as per instructions for 4th sec cor 80.04 Drive a charred stake & set a post in mound with pits as per instructions for corner to sections 2, 3, 10 and 11 Land broken 8" kat Township 6 N, Range 22 W, 6 P.M. East on a random line between sections 2 and 11 Na 13°30' East 40.00 Set a post for temporary ¼ sec cor 79.94 Intersected Nana D line 24 lks South of the corner to sections 1, 2, 11 and 12 from which corner I run S89°50' Won a true line between sections 2 and 11 Na 18°30' East 39.97 Drove a charred stake and set a post in Mound with pits as per instructions for ¼ sec cor 79.94 The corner to sections 2, 3, 10 and 11 Land broken 3 rd Kate North on a random line between sections 2 and 3 Na 14°10' East 37.50 A canyon 100 lks wide runs SW 40.00 Set a post for temporary ¼ sec cor 74.10 A canyon 200 lks wide runs West 80.50 Intersected the North Boundary 52 lks West of the corner to sections 2 and 3 from which corner I run S9°24' Won a true line between sections 2 and 3 Na 14°10' East 40.50 Drove a charred stake and set a post in Mound with pits as per instructions for ¼ sec cor 80.50 The corner to sections 2, 3, 10 and 11 Land broken 3 rd Kate August 28th 1870 Township 6 N, Range 22 W 6th P.M. North between sections 38 and 34 Via 13°30' East 40.00 Draw a charred stake and set a post in mound with pits as per instructions for 24 Dec. cor 50.00 Draw a charred stake and set a post for corner to sections 27, 28, 33 and 34 Land rolling 2nd rate East on a random line between sections 27 and 34 Via 13°30' East 40.00 Set a post for temporary ¼ sec. cor 66.70 A dry creek 10 lbs. wide runs N.E. 80.16 Instructions N. and E. line 27 lbs North of corner to sections 25, 27, 34 and 35 from which corner run N89°48' Wona true line between sections 27 and 34 Via 13°30' East 40.08 Draw a charred stake and set a post in mound with pits as per instructions for 24 Dec. cor 80.16 The corner to sections 27, 28, 33 and 34 Land broken 3rd rate Township 6 N. Range 22 W 6th P.M. North between sections 27 and 28 Va 13°45' East 40.00 Draw a charged stake and set a post in a mound with pits as per instructions for ¼ sec cor 45.00 Adry creek 5 lks wide runs East 80.00 Draw a charged stake and set a post in a mound with pits as per instructions for corner to sections 21, 22, 27 and 28 Land broken 3rd Rate Township 6 N. Range 22 W 6th P.M. East on a random line between sections 22 and 27 Va 13°30' East 32.10 40.00 80.10 Adry creek 15 lks wide runs South Set a post for temporary ¼ sec. cor. Intersected N and S. line 17 lks North of the corner to sections 22, 23, 26 and 27 from which cor. no. 5 run N 39°53' W on a true line between sections 22 and 27 Va 13°30' East 40.05 Draw a charged stake and set a post in a mound with pits as per instructions for ¼ sec. cor 80.10 The corner to sections 21, 22, 27 and 28 Land broken 3rd Rate Township 6 N, Range 22 W 5th P.M. North between sections 21 and 22 No 14° East 40.00 From a charged stake and set a post in Mound with pits as per instructions for 14 dec cor 80.00 Draw a charged stake and set a post in Mound with pits as per instructions for corner to section 15, 16, 21 and 22 Rana broken 3rd Nate Township 6 N, Range 22 W 6th P.M. East on a random line between sections 15 and 22 No 18°30' East 40.00 Set a plug for temporary 4s dec cor Aetby creek 15 lks. North run 8, W Instruction 1 and 2S lim 22 lks North of the corner to sections 14, 15, 22 and 28 from which turn 9 run N 89°51' Wona true line between sections 15 and 22 No 18°30' East 40.07 Draw a charged stake and set a post in a Mound with pits as per instructions for 14 dec cor 80.15 The corner to sections 15, 16, 21 and 22 Rana broken 8th Nate Township 6 N, Range 22 W 6 T 3 P M North between sections 15 and 16 Da 14° East 40.00 Draw a chord stake and set a post in a mound with pits as per instructions for ¼ sec cor. From a chord stake and set a post in a mound with pits as per instructions for corrs to sections 9, 10, 15 and 16 Land rolling 2nd kat. Easton random line between sections 10 and 15 Da 18° 30' East 40.00 Set a post for temporary ¼ dec cor S by creek 10 lbs. with runs South Intersected N and S line 13 lbs North of corner to sections 10, 11, 14 and 15 from which corrs to run N 89° 54' W on a true line between sections 10 and 15 Da 18° 30' East 40.06 Draw a chord stake and set a post in a mound with pits as per instructions for ¼ sec cor, The corner to sections 9, 10, 15 and 16 Land rolling 2nd kat. Township 6 N. Range 22 W 6th P.M. North between sections 9 and 10 N 14°15' East 40,00 Draw a chord stake and set a post in a mound with pits as per instructions for ¼ dec cor 62,00 Dig along 100 lks. wide runs East 80,00 Draw a chord stake and set a post in mound with pits as per instructions for corner to section 3, 4, 9 and 10 Land rolling 2nd rate East on a random line between sections 3 and 10 N 13°30' East 40,00 Set a post for temporary ¼ dec cor 62,00 Dig along 25 lks. wide runs South Instruction N and S line at the corner to sections 2, 3, 10 and 11 from which corner S run West on a true line between sections 3 and 10 80,16 N 13°30' East 40,08 Draw a chord stake and set a post in mound with pits as per instructions for ¼ dec cor 80,16 The corn to sections 3, 4, 9 and 10 Land broken 3rd rate Township 6 N Range 22 W 6th R.M. North on a random line between section 3 and 4 Va 14°15' East Set a post for temporary 4th dec cor Draw a chalked stake and set a post in Mound forty dec cor Draw a chalked stake and set a post in Mound with pits as per instructions for corner to sections 28, 29, 32 and 33 Land broken 3rd rate August 24th 1870 \| Township 6 N, Range 22 W \| 6th P.M. \| \|--------------------------\|---------\| \| East on a random line between sections 21 and 28 \| 40.00 \| \| Va 18°30' East \| \| \| 40.00 Set a post for temporary ¼ sec cor \| 53.00 \| \| 53.00 A slough 30 lks wide runs S. E., 79.90 \| \| \| 79.90 Intersected N and S line 5 lks North of the corner to sections 21, 22, 27 and 28 from which corner to run \| \| \| N 89°58' W on a true line between sections 21 and 28 \| 39.95 \| \| Va 18°30' East \| \| \| 39.95 Drive a charred stake and set a post in mound with pits as per instructions for ¼ sec cor. \| 79.90 \| \| 79.90 The corner to sections 20, 21, 28 and 29 \| \| \| Land broken 2 ro rate \| \| \| Township 6 N, Range 22 W \| 6th P.M. \| \|--------------------------\|---------\| \| North between sections 20 and 28 \| 40.00 \| \| Va 14° East \| \| \| 40.00 Drive a charred stake and set a post in mound with pits as per instructions for ¼ sec cor. \| 39.00 \| \| 39.00 Drive a charred stake and set a post in mound with pits as per instructions for Corner to sections 16, 17, 20 and 21 \| \| \| Land rolling 2 ro rate \| \| Township 6 N. Range 22 W 6 M.P.M. East on a random line between sections 16 and 21 Na 13° 30' East 40,000 Set a post for temporary 44 sec cor 79.96 Intersected N and S line 6 lks South of the corner to sections 15, 16, 21 and 22 from which corner I ran N 89° 57' Won a true line between sections 16 and 21 Na 13° 30' East 39.98 Drove a chocked stake and set a post in mound with pits as per instruction for 44 sec cor The corner to section 16, 17, 20 and 21 Land broken 3rd rate North between sections 16 and 17 Na 14° 10' East 40,000 Drove a chocked stake and set a post in mound with pits as per instructions for 44 sec cor 80.08 Drove a chocked stake and set a post in mound with pits as per instructions for corner to sections 8, 9, 16 and 17 Land rolling 2nd rate Township 6 N Range 22 W 6th P.M. East on a random line between sections 9 and 16 Na 13°30' East 40.00 Set a post for temporary ¼ sec cor 80.06 Frustrated N and S line 22 1ks North of corner to sections 9, 10, 15 and 16 from which corner given N 29°51' W on a true line between section 9 and 16 Na 13°30' East 40.09 Drove a chorded stake and set a post in mound with pits as per instruction for ¼ sec cor 80.06 The corner to sections 8, 9, 15 and 17 Land rolling 2nd rate Township 6 N Range 22 W 6th P.M. North between section 8 and 9 Na 14°10' East 40.00 Drove a chorded stake and set a post in mound with pits as per instruction for ¼ sec cor 80.06 Drove a chorded stake and set a post in mound with pits as per instruction for corner to section 4, 5, 8 and 9 Land rolling 2nd rate Township 6 N, Range 22 W 5th P.M. East on a random line between sections 4 and 9 Da 13°30' East 40.00 Set a post for temporary Sec. cor. 44.00 A & through 200 lbs. with runs both 79.90 Intersected N and S line 4 1/2 ks. South of the corner to sections 8, 4, 9 and 10 from which corner I run Da 13°30' East 39.95 Draw a chalked stake and set a post in a mound with pits as per instructions for 4 sec. cor. 79.90 The corner to sections 4, 5, 8 and 9 Land broken 3rd Plat. North on a random line between sections 4 and 5 Da 14°15' East 40.00 Set a post for temporary Sec. cor. 80.70 Intersected the North Boundary 58-1ks. West of the corner to sections 4 and 5 from which corner I run Doesn't Wona true line between sections 4 and 5 Da 14°15' East 40.70 Draw a chalked stake and set a post in a mound with pits as per instructions for 4 sec. cor. 80.70 The corner to sections 4, 5, 8 and 9 Land broken 3rd Plat. August 25th 1870 Township 6 N, Range 22 W 6th P.M. North between sections 31 and 32 Nw 15°30' East 40.00 Drove a charred stake and set a post in mound with pits as per instructions for 1/4 dec. cor. 84.00 Drove a charred stake and set a post in mound with pits as per instructions for corner 4 sections 29, 30, 31 and 32 Land rolling 2nd plat Euston a random line between sections 29 and 32 Nw 15°30' East 40.00 Set a post for temporary 1/4 dec cor. 79.98 Intersected N and S line 16 lbs North of the corner to sections 29, 30, 31 and 32 from which corner I ran N 8°53' Won a true line between sections 29 and 32 Nw 15°30' East 39.99 Drove a charred stake and set a post in mound with pits as per instructions for 1/4 dec. cor. 79.98 3rd corner to sections 29, 30, 31 and 32 Land rolling 2nd plat Township 6 N Range 22 W 6th P.M. West on a random line between sections 30 and 31 Va 15°30' East 40.00 Let a post for temporary 14 dec car 78.79 Intersected the West Boundary line 42 lbs. South of the corner to section 30 and 31 from which corner draw 0°89°28' E on a true line between sections 30 and 31 Va 15°30' East 38.79 Draw a charred stake and let a post in Mound with pits as per instructions for 14 dec car 78.79 The corner to sections 29, 30, 31 and 32 Land rolling 2nd Rat North between sections 29 and 30 Va 15°40' East 32.00 40.00 48.25 45.90 80.00 A dry creek 10 lbs. wide runs West Draw a charred stake and let a post in Mound with pits as per instructions for 14 dec car 78.79 Same creek 15 lbs. wide runs S. E Same creek 10 lbs. wide runs West Draw a charred stake and let a post in a Mound with pits as per instructions for same to sections 19, 20, 29 and 30 Land rolling 2nd Rat Township 6 N, Range 22 W 6th P.M. East on a random line between sections 20 and 29 Na 13°30' East 20.39 Adjacent 10 lbs., which runs south 40.00 Set a post for temporary 1/4 section 80.00 Intersected Nandes line 6 North of the corner to section 20, 21, 28 and 29 from which corner run N89°57' Wona true line between sections 20 and 29 Na 13°30' East 40.00 Draw a charred stake and set a post in mound with pits as per instructions for 1/4 sec. cor. 80.00 The corner to sections 19, 20, 29 and 30 Land rolling 2nd Rate West on a random line between sections 19 and 30 Na 13°30' East Set a post for temporary 1/4 section Intersected the West Boundary 38 lbs. South of the corner to section 19 and 30 from which corner draw S29°24' Eona true line between sections 19 and 30 Na 13°30' East Drive a charred stake and set a post in a mound with pits as per instructions for 1/4 sec. cor. The corner to sections 19, 20, 29 and 30 Land rolling 2nd Rate Township 6 N. Range 22 W. 6th P.M. North between sections 19 and 20 N 18°45' East 4,000 Drove a charred stake and set a post in Mound with pits as per instructions for corner to section 17, 18, 19 and 20 Land level good 2nd Rate East on a random line between sections 17 and 20 N 13°30' East 9,10 4,000 79.90 Addy creek 15 lks. Much runoff S.W. Set a post for temporary 4th sec. corner Intersection of land and line 30 lks. North of corner to return 15, 17, 20 and 21 from which corner to run N 89°47' Won a true line between sections 17 and 20 N 15°30' East 39.95 Drove a charred stake and set a post in Mound with pits as per instructions for corner to section 17, 18, 19 and 20 Land rolling 2nd Rate Township 6 N. Range 22 W. 6 M. S.P.M. West on a random line between sections 18 and 19 N 13°30' East 40.00 Set a post for temporary ¼ sec. cor. Intersection the West Boundary 70 th. South of the corner to Section 18 and 19 from which corner draw S 89°30' E on a true line between section 18 and 19 N 13°30' East 38.54 Draw a chared stake and set a post in mound with pits as per instruction for ¼ sec. cor. The corner to Sections 17, 18, 19 and 20 Land rolling 2nd Rate Township 6 N. Range 22 W. 6 M. S.P.M. North between sections 17 and 18 N 14° East 40.00 Draw a chared stake and set a post in mound with pits as per instruction for ¼ sec. cor. Draw a chared stake and set a post in a mound with pits as per instructions for corner to Sections 7, 8, 17 and 18 Land rolling 2nd Rate Township 6 N, Range 22 W, 6th P.M. East on a random line between sections 8 and 17 N 13°35' E 11.60 Aby cruh 10 lks. with runs South 32.60 Aby cruh 10 lks. with runs South 40.00 Set a post for temporary sec. cor 79.34 Intersected the N and S line at the corner to sections 8, 9, 16 and 17 from which corner I run West on a true line between sections 8 and 17 N 13°35' East 39.92 Drove a charred stake and set a post in a mound with pits as per instructions for ¼ sec. cor 79.84 The corner to sections 7, 8, 17 and 18 Land rolling 2nd flat August 26th 1870 Township 6 N, Range 22 W, 6th P.M. West on a random line between sections 7 and 18 N 13°30' East 40.00 Set a post for temporary ¼ sec. cor 68.96 A along 8 lks. with runs E. W 78.66 Intersected the West Boundary 36 lks. South of the corner to sections 7 and 18 from which corner I run 108°50'45" E on a true line between sections 7 and 18 N 13°30' East 38.66 Drove a charred stake and set a post in a mound with pits as per instructions for ¼ sec. cor 78.66 The corner to sections 7, 8, 17 and 18 Land rolling good 2nd flat Township 6 N, Range 22 W, 5th P.M. North between sections 7 and 8 Nw 14°15' East 40.00 Drive a chared stake and set a post in mound Smith pits as per instructions for 44 sec cor Although 20 lks. mid runs W. E 62.35 Drive a chared stake and set a post in mound Smith pits as per instructions for corner to sections 5, 6, 7 and 8 80.00 Land rolling 2nd plat Township 6 N, Range 22 W, 5th P.M. East on a random line between sections 5 and 8 Nw 18°30' East 40.00 Set a post for temporary 44 sec cor 64.20 A along 10 lks. wide rows South 79.86 Intersection of Sand & S line 42 lks. South of the corner to sections 4, 5, 6 and 9 from which corner driven U 89°42' Wona true line between sections 5 and 8 Nw 18°30' East 38.93 Drive a chared stake and set a post in mound Smith pits as per instructions for 44 sec cor 79.86 The corner to section 5, 6, 7 and 8 Land rolling 2nd plat Township 6 N, Range 22 W, 6th P.M. West on a random line between sections 6 and 7 Via 18°30' East 2.10 A slough 10 lbs. wide runs south Set a post for temporary ¼ sec cor 78.76 Intruded the West boundary 70 lbs. South of the corner to section 6 and 7 from which corner I run 159°30' E on a true line between sections 6 and 7 Via 19°30' East 38.76 Draw a charred stake and set a post in mound with pit as per instructions for ¼ sec cor 78.76 The corner to section 5, 6, 7, and 8 Land rolling 2nd flat North on a random line between sections 5 and 6 Via 14°15' East 39.60 A slough 10 lbs. wide runs West Set a post for temporary ¼ sec cor 78.76 Intruded the North boundary 67 lbs. West of the corner to sections 5 and 6 from which corner I run 150°28' W on a true line between sections 5 and 6 Via 14°15' East 41.07 Drawn a charred stake and set a post for in a mound with pit as per instructions for ¼ sec cor 81.07 The corner of section 5, 6, 7, and 8 Land broken 8th flat August 27th 1870 General Description The land in this township is high rolling 2nd North prairie very good for grazing. Too broken to cultivate. Nearly destitute of timber some sycamore, elm, ash and boxelder along the creek in sections 27, 34 and 35. We hereby certify that we assisted Philavoda La Patterson deputy surveyor in surveying the subdivision lines in Township 6 North of the base line of Range N. & 22 West of the 6th Principal Meridian, and that said township has been in all respects to the best of our knowledge and belief well and faithfully surveyed and the boundary monuments planted according to the instructions furnished by the Surveyor General. Walter G. Doyden William McCarty David P. Coole John R. Tolin Frank Porter Subscribed and sworn to by the above named persons before me a Justice of the Peace for the County of Cass in the State of Nebraska this 21st day of October A.D. 1870. J.B. Patterson J.P. J. Philander C. Patterson, deputy surveyor, do solemnly swear that in pursuance of a contract with Robert R. Livingston, Surveyor of the public lands of the United States in the States of Iowa and Nebraska, bearing date the 5th day of August 1870, and in strict conformity to the laws of the United States and the instructions furnished by the said Surveyor General, I have faithfully surveyed the subdivisions of Township 46 North of Range No. 22 West of the 6th Principal Meridian in the State aforesaid; and do further solemnly swear that the foregoing are the true and original field notes of such survey. Philander C. Patterson Deputy Surveyor Subscribed by said Philander C. Patterson, deputy surveyor, and sworn to before me, a Justice of the Peace for the County of Cass in the State of Nebraska, this 21st day of October 1878. L.B. Patterson J.P. Surveyor General's Office Lincoln, Neb., Feb. 1, 1871 The foregoing field notes of the survey of the subdivision lines of Township No. 6 North of the Base Line, of Range No. 22 West of the 6th Principal Meridian in the State of Nebraska, executed by Philander Patterson, under contract No. 36, dated Aug. 5, 1870, in the month of August 1871 having been critically examined, the necessary corrections and explanations made, the said field notes, and the surveys they describe are hereby approved. Robert B. Simpson Surveyor General. Town 7 Range 22 West \| \| \| \| \| \| \| \| \| \| \| \|---\|---\|---\|---\|---\|---\|---\|---\|---\|---\| \| 1 \| 2 \| 3 \| 4 \| 5 \| 6 \| 7 \| 8 \| 9 \| 10\| \| 11\| 12\| 13\| 14\| 15\| 16\| 17\| 18\| 19\| 20\| \| 21\| 22\| 23\| 24\| 25\| 26\| 27\| 28\| 29\| 30\| \| 31\| 32\| 33\| 34\| 35\| 36\| 37\| 38\| 39\| 40\| \| 41\| 42\| 43\| 44\| 45\| 46\| 47\| 48\| 49\| 50\| \| 51\| 52\| 53\| 54\| 55\| 56\| 57\| 58\| 59\| 60\| Subdivision of Township No 7 North of Range No 22 West of the 6th Principal Meridian Nebraska Commenced September 24th 1869 Finished October 2nd 1869 by James McBride Deputy Surveyor Names of Assistants Henry A Hamilton Chairman Andrew Laugworthy Chairman Andrew Müller Plaquer Edward Racine Wand Builders To determine the proper adjustment of my corners for subdividing this Township I commenced at the corner of Township No 647 North & Ranges 21 & 22 West of the 6th Principal Meridian & run North on a blank line along East boundary of section thirty six. Variation 14°30' E 39.76 Fall twenty eight links West of our fourth section corner 19.68 Fall twenty one links West of corner to sections twenty five & twenty six \| Distance \| Description \| \|----------\|--------------------------------------------------\| \| 12.00 \| Ravine runs S.E. \| \| 30.00 \| Ravine runs S.E. \| \| 40.00 \| Set post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. \| \| 43.00 \| Head of deep Ravine runs N.E. \| \| 57.00 \| Deep ravine runs N.E. \| \| 65.80 \| Deep ravine runs S.E. \| \| 70.00 \| Ravine runs S.E. \| \| 78.00 \| Ravine runs N.E. \| \| 81.00 \| Set post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. \| \| 89.80 \| Corner to sections 25, 26, 35, 36 \| \| Distance \| Description \| \|----------\|--------------------------------------------------\| \| 2.00 \| Deep Ravine runs S.E. \| \| 6.00 \| Deep Ravine runs S.E. \| \| 11.00 \| Deep Ravine runs S.E. \| \| 22.50 \| Deep Ravine runs S.E. \| \| 29.50 \| Deep Ravine runs N.E. \| \| 40.00 \| Set temporary our fourth section post \| \| 48.00 \| Deep ravine runs S.E. \| \| 57.00 \| Ravine runs S.E. \| \| 80.00 \| Intersect range line at corner to sections 25, 26, 35, 36 \| N89.80 from true line between sections 23, 24, 36. Variation 14°25' E: 40.00 ft post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. \| Corner to sections 25, 26, 35, 36 Surface rolling slow rate. Township 10 N. of Range 22 W. North between Sections 25 + 26 Variation 14° 26' E 2,300 deep ravine runs N. E. 28.50 deep ravine runs East 38.00 deep ravine runs N.E. 40.00 set host deposited charge stake raised ground of earth with pits as per instructions for one fourth section corner 48.00 ravine runs N.E. 52.00 ravine runs S. E. 88.30 deep ravine runs East 68.10 deep ravine runs East 73.00 head of deep ravine runs N.E. 80.00 set host deposited charge stake raised ground of earth with pits as per instructions for corners sections 23, 24, 25, 26. surface broken soil third sale. West of the 6th Principal Meridian Out on a Random line between Sects 24 + 25 Variation 14° 26' E 8.00 deep ravine runs N. E. 12.10 Ravine runs S.E. 14.00 deep ravine runs N.E. 24.00 main drain runs S.S. E a few scattering trees. 40.00 set temporary the fourth section first 41.50 deep ravine runs North intersect range line at corner to sections 24 & 25 N. 89° 56' M. on true line between sections 24 & 25. Variation 14° 26' E 39.30 set host deposited charge stake raised ground of earth with pits as per instructions for one fourth section corner 79.80 corner to sections 23, 24, 25 & 26 surface broken soil third sale. Township No. 7 N of Range No. 22 West of the 6th Principal Meridian North between sections 23 & 24 Variation 14° 30' E 2.00 deck Ravine runs S. E. 36.00 deck Ravine runs N. E. 40.00 set frost deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. 58.00 Ravine runs S. E. 78.00 Ravine runs S. W. 80.00 set frost deposited charred stake raised mound of earth with pits as per instructions for corners 23, 24, 25, 26, 13, 14, 23, 24. Surface broken soil third stake. Cottonwood Ravines lie between Sects 13 & 14 Variation 14° 30' E 40.00 set temporary one fourth section first 80.00 intersect section line border lines north of center to sections 13 & 24 on true line between sections 13 & 24. Variation 14° 30' E 40.00 set frost deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. 80.00 corner to sections 13, 14, 23, & 24. Surface sodding soil third stake. Township 6th N. of Range 18-22 North between sections 13 & 14 Variation 14° 35' E 3.00 Ravine runs S. W. 13.00 Ravine runs S. W. 32.50 deep ravine runs S. W. 38.00 deep ravine runs S. W. 40.00 set foot deposited charged plate raised around of earth with pits as per instructions for one fourth section corner 47.00 deep ravine runs S. W. 48.00 deep ravine runs S. W. 52.00 deep ravine runs S. W. 8.0.00 set foot deposited charged plate raised around of earth with pits as per instructions for corners to sections 11, 12, 13, 14. Surface rolling soil second rate Test of the 6th Principal Meridian End of Random line between sects 12 & 13 Variation 14° 35' E 40.00 set temporary one fourth section post 81.00 intersect range line thirty eight links south of corners to sections 12 & 13. 89048' West true line between sections 12 & 13 Variation 14° 35' E 40.00 set foot deposited charged plate raised around of earth with pits as per instructions for one fourth section corner 80.00 corners to sections 11, 12, 13, 14. Surface level soil second rate. Township 10 S. of Range 34 E. North between sections 11 & 12 Variation 14° 55' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 same set post deposited charred stake raised pits as mound of earth with pits as per instructions for corner to sections 1, 2, 11, & 12. Surface leaving soil second rate. West of the 6th Principal Meridian East on a Random line between sects 14 & 15 Variation 14° 30' E 32.00 deck Ravine runs N. E. 40.00 set temporary one fourth section post. 43.00 Ravine runs North 53.00 Ravine runs N. W. 79.90 intersect range line thirty seven links North of corner to sections 1, 2, 11, & 12. N 89° 40' West true line between sections 1 & 12. Variation 14° 30' E 39.95 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 79.90 corner to sections 1, 2, 11, & 12. Surface leaving soil third rate. Township No. 7 N. of Range No. 22. North on a Randon line between 1 & 2. Variation 14° 20' E 37.92 set temporary one fourth section front 52.56 Ravine runs West 79.92 intersect township line at corner to sections 1 & 2. South on true line between sections 1 & 2. Variation 14° 20' E 39.92 set first deposited charred stake raised mound of earth with pits as first instructions for one fourth section corner 79.92 corner to sections our two eleven & twelve. surface rolling soil third date. September 27th, 1869 West of the 6th Principal Meridian North between Sections 34 & 35 Variation 14° 20' E 12.00 Ravine runs S. W. 32.00 Ravine runs S. W. 41.00 set first deposited charred stake raised mound of earth with pits as first instructions for one fourth section corner 76.00 Ravine runs East 18.52 Ravine runs East 80.00 feet first deposited charred stake raised mound of earth with pits as first instructions for corner to sections 26, 27, 34, 35 surface broken soil third date. Township 15 N. of Range 12 E. East on a Baseline between Sections 26 & 35 Variation 14° 20' E 4.00 deep variance runs S. W. 40.00 set first deposited charge stake raised mound of earth with suits as per instructions 55.50 deep Ravius runs N. E. 15.00 deep Ravius runs S. E. 80.00 intersect section line eleven liks North of corner sections 26, 27, 24, 25 N. 89° 51' W. on base line between sections 26, 35 Variation 14° 20' E 40.00 set first deposited charge stake raised mound of earth with suits as per instructions for our fourth section corner 80.00 set first deposited charge stake raised mound of earth with suits as per instructions for our fourth section corner North Section Sections 26 & 2 Variation 14° 23' E 11.00 deep variance runs S. W. 23.00 deep variance runs S. E. 40.00 set first deposited charge stake raised mound of earth with suits as per instructions For our fourth section corner 80.00 set first deposited charge stake, raised mound of earth with suits as per instructions for corner to sections 22, 23, 26, 32, 37 Surface rolling soil third rate. Township 15 S. of Range 22 East and Raudens line between Sects 23 & 26 8.8936° Variation 14°30' E 21.00 deep ravine runs N.E. 40.00 set post for temporary our fourth section corner 42.00 deep ravine runs N.E. 48.00 deep ravine runs N.E. 80.12 mill direct section line at corner to sections 23, 24, 25, & 26. N. 89°36' W on true line between sections 23 & 26. Variation 14°30' E 40.06 set post defrosted chased stake raised mound of earth with futs as per instructions for one fourth section corner 80.12 corner to sections 22, 23, 26, & 27. surface rolling soil third rate. West of the 6th Principal Meridian North between sections 22 & 23 Variation 14°37' E 40.00 set frost defrosted chased stake raised mound of earth with futs as per instructions for one fourth section corner 68.00 deep Ravine runs N.E. 74.00 deep Ravine runs S.E. 86.00 set post defrosted chased stake raised mound of earth with futs as per instructions for corner to sections 14, 15, 22, 23. surface rolling soil third rate. Township No. 7 N. of Roanoke, Va. East of a Random line between Sacts 14 & 23 Variation 14° 30' E Ravine runs S. E. Ravine runs S. E. 40.00 set temporary one fourth section post 45.30 Ravine runs S. E. 57.00 Ravine runs S. E. 79.00 Ravine runs S. E. 80.00 intersect section line nineteen lines North of corner to sections 13, 14, 23, & 24. N 89° 48' W on true line between sections 14 & 23 Variation 14° 30' E 40.00 set post deposited charred stake raised mound of earth with suits as per instructions for our fourth section corner 80.00 corner to sections 22, 23, 14, & 15 surface broken soil third date West of the 6th Principal Meridian North between sections 14 & 15 Variation 14° 20' E 13.00 Ravine runs N. E. 18.00 Ravine runs N. E. 20.00 Ravine runs N. E. 28.00 Ravine runs S. E. 40.00 set post deposited charred stake raised mound of earth with suits as per instructions for our fourth section corner 40.10 Ravine Runs N. E. 58.00 Ravine runs N. E. 79.00 Ravine runs N. E. 80.00 set post deposited charred stake raised mound of earth with suits as per instructions for corners to sections 10, 11, 14, 15. Surface rolling soil third date Township No. 7, N. of Range No. 22 East on a Roadway line between sections 14 & 15 889056E Variation 14°30'E 40.00 set temporary one-fourth section post 55.00 deep ravine runs S.E. 58.00 deep ravine runs S.E. 65.30 deep ravine runs S.E. $80.46 intersect section line thirty-eight-tenths north of corner to sections 11, 12, 13, & 14. N89°40'W on true line between sections 11 & 14 Variation 14°30'E 40.23 set post deposited chareed stake raised mound of earth with pits as per instructions for one-fourth section corner 80.46 corner to sections 10, 11, 14, & 15 surface rolling soil third sale West of the 6th Principal Meridian North between Sections 10 & 11 Variation 14°11'E 31.50 Ravine runs S.E. 40.00 set post deposited chareed stake raised mound of earth with pits as per instructions for one-fourth section corner 50.50 Ravine runs N.W. 80.00 set post deposited chareed stake raised mound of earth with pits as per instructions for corner to sections 2, 3, 10, & 11 surface level soil second sale Township No. 7 N. of Range No. 22 East on a Random line between Sects. 2 & 11 8.89056°E Variation 14°30' E 18.00 Ravine runs N. E. 29.00 Ravine runs N. W. 40.00 set temporary one fourth section post 5.50 Ravine runs S. E. E. 58.00 Intersect section line at corner to sections 1, 2, 3, 10, *11, 4, 12 N. 89°56'W. on true line between sections 2 & 11. Variation 14°30' E 40.00 set post deposited chaser stake, raised mound of earth with pits as per instructions for fourth section corner. 80.00 corner to sections 2, 3, 10, & 11. West of the 6th Principal Meridian North on a Random line between Sects. 2 & 3 Variation 14°20' E 31.00 Ravine runs N. W. 40.00 set temporary one fourth section post 58.00 Ravine runs N. E. 80.38 intersect township line forty two links west of corner to section 2 & 3 818.96 on true line between sections 2 & 3. Variation 14°20' E 40.38 set post deposited chaser stake raised mound of earth with pits as per instructions for one fourth section corner. 80.38 corner to sections 2, 3, 10, & 11. surface rolling soil third rate. September 28 to 1869 Township No 7 N. of Roanoke No 22 West of the 6th Principal Meridian North between Sections 33 & 34 Variation 14° 10' E 12.20 Ravine runs S. E. 40.00 set frost deposited claved stake raised mound of earth with pins as per instructions for our fourth section corners. 62.00 Ravine runs S. E. 80.00 set frost deposited claved stake raised mound of earth with pins as per instructions for corners sections 27, 28, 33, 34. surface rolling poor third rate. East on a Random line between Sects 27 & 34 8.8956 E Variation 14° 120' E 40.00 set temporary on fourth section frost 47.58 main drain runs S. 49.86 intersect section line at corners to sections 26, 27, 33 & 34. N. 8956 W on true line between sections 27 & 34. Variation 14° 30' E 39.93 set frost deposited claved stake raised mound of earth with pins as per instructions for our fourth section corners. 79.86 corners to sections 27, 28, 33, 34 surface broken soil third rate. Township No. 7 N. of Range 30 W. North between Sections 24 & 28 Variation 14° 16' E 4.00 Ravine runs S. W. 34.50 deep ravine runs E. 4.00 feet frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 84.00 feet frost deposited charred stake raised mound of earth with pits as per instructions for corner to sections 21, 22, 27, T28 Surface broken soil third date. West of the 6th Principal Meridian East of a Random line between Sects 22 & 23 Variation 14° 20' E 8.9956' E 8.00 Ravine runs S. E. 23.00 Main drain runs south 37.00 Ravine runs S. W. 40.00 set temporary one fourth section front 43.00 Ravine runs W. W. 51.5 deep Ravine runs S. W. 64.00 Ravine runs W. W. 81.00 intersected section line at corner to sections 22, 23, 26, T28 N. 9956' W. our true line between sections 22 & 23 Variation 14° 20' E 40.00 feet frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 84.00 feet frost deposited charred stake raised mound of earth with pits as per instructions for corner to sections 21, 22, 27, T28 Surface broken soil third date Township 14-7 N. of Range 22 W. of the 6th Principal Meridian North between Sections 21 & 22 Variation 14°30' E 8.00 deep Ravine runs S. W. 12.00 deep Ravine runs S. E. 29.00 Main drain runs S. S. E. 40.00 set frost deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. 80.00 set frost deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner to sections 15, 16, 21, & 22. Surface broken soil third rate. Eastonia Roadline line between Sects 15 & 22 Variation 14°20' E 9.50 Ravine runs South 26.00 deep Ravine runs S. W. 40.00 set temporary on fourth section frost. 40.50 Ravine runs South 50.00 deep ravine runs South 61.00 deep ravine runs South 71.50 deep ravine runs South 81.50 intersect section line corner to sections 14, 15, 22 & 23. N89°56'W. on line line between sections 15 & 22. Variation 14°20' E 41.25 set frost deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner to sections 15, 16, 21, & 22. Surface broken soil third rate. Township 4th T. & Range No. 22 West of the 6th Principal Meridian Eastona Raudoz line between Sects. 10 + 15 Variation 14° 20' E 2.00 Ravine runs N. W. 37.00 Ravine runs N. E 40.00 set post defrosted chased stake raised mound of earth with fits as per instructions for our fourth section corner 143.00 Ravine runs N. E 63.00 Ravine runs N. E 74.00 deep ravine runs North 80.00 intersect section line at corner to sections 10 + 15 N. 89° 56' W on true line between sections 10 + 15 Variation 14° 20' E 40.00 set post defrosted chased stake raised mound of earth with fits as per instructions for our fourth section corner 80.00 corner to sections 9, 10, 13, 16 surface broken soil third rate. Township 5° 7' T. of Range 16° 22' North between Sections 9 & 10 Variation 14° 25' E 6.50 Ravine runs S. E. 40.00 set frost defrosted charred stakes raised mound of earth with pits as per instructions for our fourth section corner. 81.00 set frost defrosted charred stakes raised mound of earth with pits as per instructions for corners to sections 3, 4, 9, & 10. Surface rolling soil third rate. West of the 6th Principal Meridian East on a random line between Dects 3 & 10 Variation 14° 20' E 3.00 Ravine runs N. W. 40.00 set temporary one fourth section post 49.50 Ravine runs S. E. 61.00 Ravine runs N. E. 80.12 intersect section line thirty one links North of corners to sections 2, 3, 10, & 11. 15.89° 43' N. on true line between sections 3 & 10 Variation 14° 20' E 40.06 set frost defrosted charred stakes raised mound of earth, with pits as per instructions for our first section corner. 80.08 corners to sections 3, 4, 9, & 10. Surface rolling soil third rate. Township 12 S. of Range 22 North on a Random line between Sects 34 & 4 Variation 15°40' E 20.00 Ravine runs N. E. def. 34.00 deep Ravine runs N. W. W. 40.00 set temporary one point section frost 66.00 Ravine runs N. E. 80.42 intersect township line twelve links west of corner to sections 35 & 4 8.51 W. on true line between sections 35 & 4 Variation 14°40' E 40.42 pet frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section frost 80.42 corner to sections 34, 9, 8, 10, surface rolling soil second rate. September 29th, 1867 West of the 6th Principal Meridian North between Sections 32 & 33 Variation 14°10' E 40.00 pet frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 52.00 deep Ravine runs S. W. E. 64.00 deep Ravine runs S. E. 80.00 set frost deposited charred stake raised mound of earth with pits as per instruction for one fourth section corner, corners to sections 28, 29, 32, & 33. Surface rolling soil third rate Townships N° 7, N. of Range N° 22 East of Ravine, five between sections 28 + 33 - 889'56" E. Variation 140'10" E. 28.50 Ravine owns S.E. 40.00 set temporary one fourth section post 55.00 Ravine owns N.E. 70.00 Ravine owns S.E. 75.50 Ravine owns S.W. 80.00 intersect section line Corners to sections 24, 28, 83, 534. N89'56" West, on true line between sections 28, 733. Variation 140'W 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 80.00 corners to sections 28, 29, 32, 33 Surface rolling soil second rate. West of the 6th Principal Meridian North between sections 28 + 29 Variation 140'10" E. 32.00 Ravine owns S.W. 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 24, 28, 83, 534. 62.00 Ravine owns S.E. 80.00 set post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 24, 28, 83, 529. Surface rolling soil second rate. Township No. 7 N. of Range No. 22 West of the 6th Principal Meridian East and Roadway line between Sects. 21 & 28 Variation 14° 20' E 899568 23.00 deep Ravine runs S. E 31.50 deep Ravine runs S. E 37.50 deep Ravine runs S. E 40.00 set temporary one fourth section front 52.00 deep ravine runs N. E 54.00 deep ravine runs N. E 59.50 deep ravine runs S. E 76.00 deep ravine runs S. E 80.00 intersect section line at corner to sections 21, 22, 27, 28 N. 899568 W on true line between section 28 & 28 Variation 14° 20' E 8140.00 set front deposited cleared stake raised mound of earth with pits as per instructions for one fourth section corner 80.00 set front deposited cleared stake raised mound of earth with pits as per instructions for corner to sections 16, 17, 20, 21. Surface rolling soil second rate. North between Sections 20 & 21 Variation 14° 20' E, 22.00 Ravine runs S. E 32.00 Ravine runs S. E 40.00 set front deposited cleared stake raised mound with pits as per instructions for one fourth section corner 80.00 set front deposited cleared stake raised mound of earth with pits as per instructions for corner to sections 16, 17, 20, 21. Surface rolling soil second rate. Township No. 7 N. of Range 26 E. 22 East on a boundary line between sections 16 & 21 S.89°36' E Variation 140°20' E 40.00 set temporary one fourth section frost 40.25 Ravine deep, runs S.E. 47.50 Ravine runs S.E. 60.00 Deep ravine, S.E. 66.00 Ravine deep, runs N.E. 74.00 Main drain runs S.W. 80.10 Intersect section line at corners to sections 15, 16, 21, & 22 N.89°36' W true line between sections 16 & 21 Variation 140°20' E 40.05 Set deposited charred stake raised mound of earth with pits as per instructions of one fourth section corner. 80.10 Corner to sections 16, 17, 20, & 21 Surface broken soil third order West of the 6th Principal Meridian North between sections 16 & 17 Variation 140°30' E 40.00 Set deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 Set frost deposited charred stake raised mound of earth with pits as per instructions for corner to sections 8, 9, 16, & 17. Surface rolling soil second order Township 15-7 N. of Range 23 East on a Random line 9+16 Variation 14°35' E 12.00 Bairn runs N. E. 37.50 Deer running runs North 40.00 set temporary one fourth section post 80.46 intersect section line at corner to sections 9, 10, 15 & 16. $89.56 Water line delivers sections 4+9+16 Variation 14°35' E 40.23 set foot deposited charred stake raised around of earth with pits as per instructions for one fourth section corner 80.46 corner to sections 8, 9, 16 & 17 surface rolling soil second oate. West of the 6th Principal Meridian North between Sections 8 + 9 Variation 14°20' E 40.00 set foot deposited charred stake raised around of earth with pits as per instructions for one fourth section corner 80.00 set post deposited charred stake raised around of earth with pits as per instructions for corner to sections 4, 5, 8, & 9. Surface rolling soil second oate. Township No. 7 N. of Range No. 22 East on a Random line between Sects. 4 & 9 8°9056' E. Variation 14°30' E. 40.00 set temporary one fourth section post. 80.10 intersect section line at corner to sections 3, 4, 9, & 10. North 8N in a Random line between Sects. 4 & 5 8°9056' E. Variation 14°30' E. 40.00 set temporary one fourth section post. 5.00 Ravine runs N. E. 63.00 Ravine deck runs N. E. 79.40 intersect township line sixty two links east of corner to sections 4, 5, & 6 326' E. on true line between sections 4 & 5. Variation 14°30' E. 39.46 set post deposited charged stake raised around of earth with suits as per instructions for one fourth section corner. 79.46 corners to sections 4, 5, & 9. Surface rolling soil third oate. September 30th, 1869 Township No. 7 N. of Range No. 22 North between sections 31 & 32. Variation 14° 35' E 40.00 set post deposited charred stake raised around of earth with pits as per instructions for one fourth section corner. 80.00 set post deposited charred stake raised around of earth with pits as per instructions for corners sections 29, 30, 31, 32. Surface level soil second rate. West of the 6th Principal Meridian East on a Random line between Sects 29 & 32. 889.568 E. Variation 14° 10' E 15.00 Rennie ovens 8. 1/4 27.50 Rennie ovens 8. 1/4 40.00 set temporary one fourth section post 53.50 Rennie ovens 8. 1/4 80.00 intersect section line at corner to sections 28, 29, 32, 33. N89.567 W. on true line between sections 29, 32. Variation 14° 10' E. 40.00 set post deposited charred stake raised around of earth with pits as per instructions for one fourth section corner. 80.00 corner to sections 29, 30, 31, 32. Surface rolling soil third rate. Township No. 7 N. of Range No. 22 West of the 6th Principal Meridian North between sections 29 & 30 Variation 14° 39' E 38.00 Ravine runs S. W. 40.00 set post deposited charred stake raised mound of earth with suits as per instructions for one fourth section corner. $20.00 Ravine runs S. W. $10.00 set post deposited charred stake raised mound of earth with suits as per instructions for corner to sections 19, 20, 29, 30. Surface rolling soil third rate. West or a Random line between Sects 30 & 31 Variation 14° 16' E 11.00 Ravine runs S. W. 15.30 Ravine runs S. W. 37.00 Ravine runs South. 40.00 set temporary our fourth section post. 79.92 intersect Range line at corner to sections 30 & 31 8° 39' 16" E, on true line between sections 30 & 31. Variation 14° 16' E 39.92 set post deposited charred stake raised mound of earth with suits as per instructions for one fourth section corner. 79.92 corner to sections 29, 30, 31, 32. Surface rolling soil third rate. Township No. 7 N. of Range No. 22 East on a Random line between Secs. 20 & 29 Variation 14° East 2.00 Ravine runs S. E. 19.00 Ravine runs E. N. E. 26.50 Ravine runs S. E. 37.00 Ravine runs S. E. 40.00 set temporary four fourth section post 42.00 Ravine runs S. E. 48.00 Ravine runs S. E. 80.52 intersect Range line fourteen links South of corner to sections 20, 21, 28, 29. West of the 6th Principal Meridian West on a Random line between Secs. 19 & 30 Variation 14° 30' E 10.00 Ravine runs S. E. set temporary 14 sections posts 40.00 set deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 47.00 Ravine runs S. E. 53.80 Ravine runs S. E. 79.40 intersect Range line at corner to sections 19 & 30 $89.56 E. on true line between sections 19 & 30 Variation 14° 30' E 39.40 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 79.40 corners to sections 19, 20, 29, 30 surface rolling soil third rate! Township 15 N. of Ranges No. 22 North between sections 19 & 20 — Variation 14° 20' E 3.00 Ravine runs S. E. 14.00 Ravine runs S. E. 20.58 Ravine runs S. E. 35.00 Ravine runs S. E. 40.00 set foot deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner 43.00 Ravine runs S. E. 48.00 def. Ravine runs S. E. 57.00 Ravine runs S. E. 62.00 def. Ravine runs N. W. 67.50 def. Ravine runs S. E. 70.00 set deposited charred stake raised mound of earth with pits as per instructions for corners to sections 17, 18, 19, & 20 surface broken soil third stake. West of the 6th Principal Meridian East on a Random line between Sects 17 + 20 6 8956 E. Variation 14° 10' E. 17.00 Ravine runs N. E. 32.00 Ravine runs S. E. 40.00 set temporary one fourth at section post 80.00 intersect section line thirty eight links South of corner to sections 16, 17, 20, & 21. 89048 West line between sections 17 & 20. Variation 14° 10' E. 40.00 set foot deposited charred stake raised ground of earth with pits as per instructions for our fourth section corner 80.00 corners to sections 17, 18, 19, & 20. surface rolling coil record date. September 2 October 1st, 1869. Township N° 7, N. of Range N° 22 West of the 6th Principal Meridian, Hold on a Random line between Secs 18 & 19 N. 89° 56' W. Variation 14° 30' E. 8.00 Ravius bears S.E. 18.00 Ravius bears S.E. 36.00 Ravius bears South. 40.00 set temporary one fourth section corner 44.00 Ravius bears South 52.00 Ravius bears N.E. 67.00 Ravius bears S.E. 79.60 intersect Range line fifty-two hicks North of corner to sections 18, 19 & 9 North between Sections 17 & 18 Variation, 14° 04' E. 40.00 set post deposited charred stake raised around of earth with pits as per instructions for quarter section corners. 80.00 set post deposited charred stake raised around of earth with pits as per instructions for corners to sections 7, 8, 17, & 18. Surface rolling soil second rate. N 89° 42' E on true line between sections 18 & 19. Variation 14° 30' E 39.60 set post deposited charred stake raised around of earth with pits as per instructions for quarter section corners. 79.60 corner to sections 17, 18, 19, & 20 surface broken, poor third rate. Township N. 7 N. of Range N. 22 East on a Random line between Sects 8 & 17 Variation 14°30' E 40.00 set temporary one fourth section post 80.00 intersect section line nineteen links North of corner to sections 8, 9, 16, & 17. 189048 ft. on true line between sections 8, & 17. Variation 14°30' E 40.00 set first deposited chard stake raised mound of earth with pits as per instructions for quarter section corner. 80.00 corners to sections 7, 8, 17, & 18 surface level soil second stake. West of the 6th Principal Meridian West on a Random line between Sects 7 & 18 Variation 14°30' E 40.00 set temporary one fourth section post 79.52 intersect Range line tenet links South of corner to sections 7, 8, 17, & 18. 18952 ft. East, on true line between sections 7 & 18 Variation 14°30' E $89.52 set post, deposited chard stake raised mound of earth with pits as per instructions for quarter section corners. 79.52 corners to sections 7, 8, 17, & 18. Surface level soil second stake. Township No. 7 N. of Range No. 22 North between sections 5 & 8 Variation 14°30' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 set post deposited charred stake raised mound of earth with pits as per instructions for corners to sections 5, 6, 7, & 8. Surface level soil second rate. West of the 6th Principal Meridian East of Boundary line between sections 5 & 8 Variation 14°25' E 40.00 set temporary one fourth section post 80.00 intersect section line at corner to sections 4, 5, 8 & 9. N. 89.50 W. on true line between sections 5 & 8. Variation 14°25' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 corner to sections 5, 6, 7 & 8. Surface level soil second rate. Township N. T.N. of Range No. 22 West on a Random line between Sects 6 & 7 Variation 14° 20' E 40.00 set temporary one fourth section front 60.00 deep saving ours N. & E. 78.50 saving ours N. & E. 79.25 intersect Range line at corner to sections 6 & 7 $89.56 on true line between sections 6 & 7 Variation 14° 20' E 39.25 set post deposited chard stake raised mound of earth with pits as per instructions for one fourth section corner 79.25 corner to sections 5, 6, 7, & 8 surface level soil second stake North on a Random line between Sects 5 & 6 Variation 14° 20' E 40.00 set temporary one fourth section corner 79.76 intersect township line at corner to sections 5, 6, & 7 Southern true line between sections 5 & 6 Variation 14° 20' E 39.76 set post deposited chard stake raised mound of earth with pits as per instructions for one fourth section corner 79.76 corner to sections 5, 6, 7, & 8 surface level soil second stake (October 2nd 1869) General Descriptive This Township contains but very little land adapted to farming purposes, as the soil consists of Lara clay extremely dry & cannot be cultivated without irrigation. The Township is extremely full of boulders which also renders it unfit for farming purposes. Plum Creek runs through the N.E. corner of section 1. water standing in pools & scattering Ash & Elm trees on margin there is no improvement in the Township. I hereby certify that we assisted James M. Bodele deputy Surveyor in subdividing Township No. N. of Range No. 22 West of the 6th Principal Meridian Nebraska & that said Township has been in all respects to the best of our knowledge & belief well & faithfully surveyed and the boundary monuments planted according to the instructions furnished by the Surveyor General. Wm. A. Hamilton, Examiner H. Langworthy, Chairman Allies Eva & Racine "Mound Builders" The above abstracts sworn to by the above named persons before Donnel County, p. 3, and by them respectively subscribed Donnel County, p. 3, on my personal oath, this 17th day of November, 1849. C. A. Baldwin Notary Public Douglas County Astronker James M. Bride, deputy surveyor, do solemnly swear that in pursuance of a contract with Robert D.C. Livingston, Surveyor General, of the public lands of the United States in the state of Nebraska, bearing date the 21st day of April, 1869, and strict conformity to the laws of the United States and the instructions furnished by the said Surveyor General, I have faithfully surveyed and subdivided into sections Township No. T.N. of Range No. 22 West of the 4th Principal Meridian, Nebraska, and do further solemnly swear that the foregoing are the true and complete field notes of such Township. James M. Bride Deputy The State of Nebraska Douglas County Subscribed by said James M. Bride, deputy surveyor and sworn to before me this 11th day of November, 1869. Cleburne Douglas County Nebraska Sol. Probler Surveyor-General's Office Plattsmouth Neb., March 30th, 1870. The foregoing field notes of the survey of the Sub-Divisions of Township No. 7 North of the Baseline of Range No. 22 West of the 9th Principal Meridian in the State of Nebraska, Executed by James McBride under his Contract No. 26, dated June 21st, 1869, in the Months of September & October 1869, having been critically examined, the necessary corrections and explanations made to said field notes and the surveys they describe are hereby approved. Ralph R. Kimball Surveyor General. Subdivision of Township No 8 North of Range No 22 West of the 6th Principal Meridian Nebraska Commenced September 9th, 1869 Finished September 23rd, 1869 by James M. Pride Deputy Surveyor Names of Assistants. Ch. A. Hamilton, chairman Ashmore Longworth, chairman Andrew Miller, Flagmen Edward Racine, Wood Builder Town & Range 22 W To determine the proper adjustment of any contract job subdividing this Township, I commenced at the corner of Townships No. 1 $8 North of Ranges 21 $22 West of the 16th Principal Meridian & run North on a blank line along East boundary of Section thirty six. Variation $40 50' E 39.80 fall twenty seven links West of one fourth section corner. 79.72 fall eighty-seven links West of corner to sections 25 & 36. Township No. 8, N of Range No. 22 North between Sections 35 & 36. By Variation, 14° 30' E 25.00 Plum Creek runs N.E. water standing in holes scattering timber 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 64.00 Ravine runs N.E. 80.00 set post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 25, 26, 35 & 36. surface level soil second rate. East on Random line between Sects 25 & 36 N 89° 5' E Variation, 14° 30' E 40.00 set temporary one fourth section post. 80.00 intersect Range line at corner to sections 25 & 36 88905' W. on true line between sections 25 & 36. Variation: 14° 30' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 84.00 corners to sections 25, 26, 35, & 36. surface level soil second rate. Township No 8 N. of Range No 22 Fourth between sections 25 & 26 Variation 14°30' E 40.00 pet frost deposited charged stake raised around of earth with pits as per instructions for one fourth section corner. 81.00 set frost deposited charged stake raised around of earth with pits as per instructions for corner to sections 23, 24, 25 & 26. surface level soil second rate. West of the 6th Principal Meridian East on a Random line between sections 24 & 25 N. 89°57' E. (Variation 14°30' E) 1.00 Ravine runs S. E. 2.00 Ravine runs South 36.50 Ravine runs South 41.00 set temporary one fourth section post 53.00 deep Ravine runs S. E. 59.00 deep Ravine runs S. E. 62.00 deep Ravine runs South 80.20 intersect Range line seventeen links North of corner to sections 24 & 25 N. 89°56' W. on true line between sections 24 & 25 Variation 14°30' E 40.10 pet frost in ground deposited charged stake raised around of earth with pits as per instructions for one fourth section corner 80.20 corner to sections 23, 24, 25 & 26 surface broken soil third rate Township No. 8 N. of Range No. 22 North between sections 23 & 24 Variation 14° 30' E. 9.00 deep Ravine runs S. E. 40.00 set first deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 80.00 feet post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 13, 14, 23 & 24 Surface rolling soil second rate. East on a Random line to sections 13 & 24 Variation 14° 30' E. 5.60 Ravine runs N. W. 38.80 Ravine runs S. W. 40.00 set temporary one fourth section post 57.80 Ravine runs S. W. 69.73 deep Ravine runs S. W. 43.00 deep Ravine runs South intersect Range line forty seven links North of corner to sections 13 & 24 589043'N. on true line between sections 13 & 24 Variation 14° 30' E. 40.10 set first deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 80.20 corner to sections 13, 14, 23 & 24 Surface broken soil third rate. Township No. 8 N. of Range No. 22 North between sections 13+14 Variation, 14° 30' E 40.00 set post deposited chased stake raised mound of earth with pits as per instructions for one fourth section corner 80.00 set post deposited chased stake raised mound of earth with pits as per instructions for corners to sections 11, 12, 13, & 14. surface level soil second rate. East on a Random line between sections 12+13 Variation, 14° 30' E 18905' E 1/3-3 deep Ravine runs North 21.00 deep Ravine runs N. E. 31.00 deep Ravine runs North 40.00 set temporary one fourth section post 35.80 Ravine runs N. N. W. 61.50 deep Ravine runs N. E. 72.00 deep Ravine runs North 80.10 intersect Range line forty links North of corner 45 sections 12+13 N89°46'W. on true line between sections 12+13 Variation 14° 30' E 40.05 set post deposited chased stake raised mound of earth with pits as per in- structions for one fourth section corner 80.10 corners to sections 11, 12, 13+14 surface broken soil third rate. Township N. 8 N. of Range W. 22 North between sections 11 & 12 Variation 14°30' E 17.00 feet deep Ravine runs N.W. 40.00 feet frost defrosted cleared, stake raised around of earth with pits as per instructions for one fourth section corner 80.00 feet frost defrosted cleared stake raised around of earth with pits as per instructions for one fourth section corner Surface rolling soil second rate. West of the 6th Principal Meridian East on a Random line betw sects 1 & 12 N89°57' E Variation 14°40' E 1.50 feet deep Ravine runs S.E. 40.00 feet temporary one fourth section frost 46.00 feet deep Ravine runs North 53.50 feet deep Ravine runs N. 62.00 feet deep Ravine runs N. 65.50 feet deep Ravine runs N.W. 80.00 feet intersect corners to sections 1 & 12, thirty links North of Frost. N89°57' N. on true line between sections 1 & 12 Variation 14°40' E 40.00 feet frost defrosted cleared stake raised around of earth with pits as per instructions for one fourth section corner 80.00 feet corner to sections 1, 2, 11, 12 Surface broken soil third rate. Township N. S. N. of Range 12 North on a Random line between sections 1 & 2 Variation, 14° 30' E 40.00 set, southward one fourth section front 85.20 intersect second standard parallel line twenty-eight chains Station 88 links North of corner to section 1 Use of corner to section 1 Set front deposited charred stake raised ground of earth with pits as per instructions for corners to sections 1 & 2. NW 5.8 N. R. 22 W. South on true line between sections 1 & 2 Variation, 14° 30' E 45.20 set front deposited charred stake raised ground of earth with pits as per instructions for quarter section corners (Cross this connection) 85.20 corner to sections 1, 2, N.W. 1/4 West of the 6th Principal Meridian North between sections 34 & 35 Variation 14° 30' Plum Creek runs East Dry vacating timber 80.00 set front deposited charred stake raised ground of earth with pits as per instructions for corner to sections 26, 27, 34, & 35. Surface rolling soil second date. Township No. 8 N. of Range No. 23 Easton a Random line thru sects 26, 35, 1890578. Variation 14°30' E $5.00 Ravine owns S. E. $4.00 set temporary northeast section post $1.50 Ravine owns South $1.986 intersect section line thirty two links North of corner to sections 25, 26, 35 & 36. West of the 6th Principal Meridian North Delaware Sections 26, 35, 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner $3.50 Ravine owns S. E. W. $80.00 set first deposited charred stake raised mound of earth with pits as per instructions for corner to sections 22, 23, 26, 35, 36. Surface rolling soil second rate. West of the 6th Principal Meridian North between sections 22 & 23 Variation 14°33'8" 1.00 deep Ravine runs S. 31° E. 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 set first deposited charred stake raised mound of earth with pits as per instructions for corner to sections 14, 15, 22 & 23. Surface rolling soil second stake. East on a Random line between sects 23 & 26 Variation 14°30'8" 6.00 Ravine runs South 40.00 set temporary one fourth section post. 80.00 intersect section line at corner to sections 23, 24, 26 & 27. 89.05 W. on line between sections 23 & 26. Variation 14°30'8" 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section post. 80.00 orders to sections 22, 23, 26, 27. Surface rolling soil second stake. West of the 6th Principal Meridian North between sections 14 & 15 Variation 14°30' E. 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 set front deposited charred stake raised mound of earth with pits as per instructions for corners to sections 10, 11, 14, & 15. Surface level soil second date. Township N° 8 T. of Range N° 22 East on a Random line sects 11, 5 & 14 N. 8905 76' Variation 14° 30' E. 40,00 set temporary corner section post 80. 60 intersect section line forty links South of corner to sections 61, 12. 13 714 89 88904 0' on true line between sections 11, 5 & 14 Variation 14° 30' E. 40.30 set post deposited hard stake raised ground of earth with pits as per instructions for our fourth section corner 80.00 set post deposited hard stake raised ground of earth with pits as per instructions for corner to sections 2, 8, 10 & 11 Surface rolling soil second rate. West of the 6th Principal Meridian North. Between sections 10 & 11 Variation 14° 20' E. 4000 set post deposited hard stake raised ground of earth with pits as per instructions for our fourth section corner 88.00 set post deposited hard stake raised ground of earth with pits as per instructions for corner to sections 2, 8, 10 & 11 Surface rolling soil second rate. Township N. D. N. of Range No. 22 East on a Random line from sects. 2 + 11 6. N89°57'0" - Variation 14°30' E. 40. 2.00 head of Ravine runs N. W. 80. 0 23.50 Ravine runs North. 33. 00 Ravine runs North. 40. 00 set temporary one fourth section frost Ravine runs S. E. intersect section line at corner to sections 1, 2, 11, & 12. 889°57'0" on line between sections 2 + 11. Variation 14°30' E set frost deposited charred stake raised ground of earth with pits as per instructions for one fourth section corner corner to sections 2, 3, 10, + 11 surface rolling soil third rates. West of the 8th Principal Meridian North on a Random line from sects. 2 + 13. Variation 14°30' E 33.50 Ravine deep runs East 40. 00 set temporary one fourth section corner. 85. 00 intersect second standard parallel line twenty eight chains and ten links Westal Se corner to section 35 + 26 + 2d frost raised mound of earth with pits as per instructions for corner to sections 2, 3, 10, + 11. South on true line between sections 2 + 13. Variation 14°30' E 45. 00 set frost deposited charred stake raised ground of earth with pits as per instructions for one fourth section corner (write this name above) 85. 00 corner to sections 2, 3, 10, + 11, surface rolling soil second date. September 16th, 1869. Township No. 8 N. of Range No. 22 North between section 33 & 34 Variation 14°30' E Ravine runs S. & A. set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. Ravine runs West set post deposited charred stake raised mound of earth with pits as per instructions for corners to sections 27, 28, 33 & 34 surface broken soil third rate. Section 27 Variation 14°35' E 20.00 Ravine runs North 40.00 set temporary one fourth section post 46.00 Plum Creek runs S. & standing water & scattering timber Plum Creek runs N. & E Plum Creek runs S. & E scattering timber 80.00 intersect section line at corner to sections 26, 27, 34 & 35 8895 From true line between sections 27 & 34 Variation 14°35' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for 1/4 section corner. 80.00 Corner to sections 27, 28, 33 & 34 surface rolling soil third rate. \| North between Sections 2, 7, 128 \| \| Variation 14050' E \| \| 30.00 Plum Creek runs East standing water & scattered timber at margins \| \| 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner \| \| 11.00 Ravine runs S. E. \| \| 00.00 set post deposited charred stake raised mound of earth with pits as per instructions for corners to sections 26, 22, 2, 7, 128 surface rolling soil recorded salt. \| \| Eastern & Random line from Sects 22, 72 \| \| N. 8957' E. Variation 14030' E. \| \| 2.00 Ravine runs E. S. \| \| 24.50 Ravine runs South \| \| 30.00 Ravine runs South \| \| 40.00 set temporary one fourth section front \| \| 45.00 Ravine runs South \| \| 57.00 Ravine runs South \| \| 69.00 Ravine runs S. E. \| \| 81.00 intersect section line forty links North of corner to sections 22, 23, 26, 72. \| \| 2.89' W. \| \| 29946' N. on true line between sections 22, 72. \| \| Variation 14030' E. \| \| 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner \| \| 80.20 corner to sections 21, 22, 2, 7, 128 surface broken soil third salt. \| Township N. 8 N. of Ranges N. 22 North between sections 21, 22 Variation 14°30' E 6. 35.50 Ravier runs S. W. 40. 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner. East & Random line from sections 15, 22 N 89°57' E Variation 14°20' E 40.00 set temporary on a fourth section first intersect section line at corner to sections 14, 15, 22 & 23. 889057 W. on true line between sections 15, 22. Variation 14°20' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner corner to sections 15, 16, 21, & 22. surface rolling oak second date. Township N. 8 W. of Range N. 22. North between sections 15 & 16. Variation 14° 30' E 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. West Surface rolling soil second rate. East on a Random line between sections 10 & 15. Variation 14° 30' E 40.00 set temporary one fourth section post. 79.90 intersect section line forty links North of corner sections ten eleven fourteen fifteen. 5894467. on true line between sections 10 & 15. Variation 14° 30' E 30.95 set post deposited charred stake raised mound of earth with pits as per instruction for one fourth section corner. 79.90 corner to sections 9, 10, 15 & 16. Surface rolling soil second rate. Township N. 2 T. W. of Range 15 E. North between sections 9 & 10. Variation 14° 10' E. 40.00 set post deposited charged stake raised mound of earth with pits as first instructions for our fourth section corner. 80.00 set post deposited charged stake raised mound of earth with pits as first instructions for corner to sections 3, 4, 9, & 10. Surface rolling soil second rate. East over Random line thru sections 8 & 10. Variation 14° 20' E. 2.50 deep ravine runs S. E. 8.00 Ravine runs N. E. 22.50 Ravine runs N. E. 40.00 set temporary our fourth section post. 50.00 Ravine runs N. E. 62.00 Ravine runs N. E. $7.00 Narrative across S. E. 80.00 intersect section line at corner to sections two, three, ten eleven. $8905.74 on true line between sections 8 & 10 Variation 14° 20' E. 40.00 set post deposited charged stake raised mound of earth with pits as her instructions for our fourth section corner. 80.00 corners to sections 3, 4, 9, & 10 Surface rolling soil third rate. Township No. 8 N. of Range No. 22 North on Raudens line stone cicks 304 Variation 14° 20' E. 18.00 Ravine runs N. 90 22.50 Ravine runs N. 8 44.00 set post temporary for our fourth section front sixty-two chains 62.00 Ravine runs N. E. 67.00 Ravine runs N. E. 84.80 intersect second standard parallel line twenty-eight chains West of corners of sections 34 & 35. Set post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 34 & 35. J.87. R.22 W. North on true line stone cicks 304 Variation 14° 20' E. 44.84 set post deposited charred stake raised mound of earth with pits as per instructions for our fourth section corner to sections 34 & 35. J.87. R.22 W. Surface broken soil third rate. September 11th, 1869 Township No. 8 N. of Range No. 23 East on a random line between sections 28 and 33 Variation 14° 30' E. 21.50 deep ravine runs S. E. 40.00 set temporary one fourth section post 52.50 Ravine runs North 63.50 Ravine runs North 80.80 intersect section line sixty-two links North of corners to sections 27, 28, 33, & 34 $89.36 W. m bar line between sections 32 & 33. Variation 14° 30' E 40.00 set post defaced charred stake raised mound of earth with pits as per instructions for one fourth section corner. 80.00 corner to sections 28, 29, 32, & 33. West of the 6th Principal Meridian North between sections 28 & 29 Variation 14° East 40.00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 61.00 Plum Creek runs S. E. 69.00 Plum Creek runs S. W. 77.00 Plum Creek runs S. E. 86.00 set post defaced charred stake raised mound of earth with pits as per instructions for corners to sections 20, 21, 28, & 29. Surface rolling soil third rate. Township No. 8 N. of Range No. 22. East of a Random line drawn Facts 21+28 N. 89°57' E. Variation 14°35' E 38.50 Ravine runs S. E. 40.00 set temporary one fourth section post. 46.50 Ravine runs South 57.00 Ravine runs South 71.00 Ravine runs South 80.00 intersect section line at corner to sections 21, 22. 27.128 8.89057' N. on true line between sections 21+28. Variation 14°35' E 40.00 set post deposited charred plate raised mound of earth with pits as per instructions for one fourth section corner. 80.00 corner to sections 20, 21. 28.29 surface broken soil third rate. West of the 6th Principal Meridian North between Sections 20 & 21— Variation 14°30' E 40.00 set first deposited charred plate raised mound of earth with pits as per instructions for one fourth section corner. 45.50 Ravine runs S. E. 67.00 Ravine runs S. E. 80.00 set post deposited charred slate raised mound of earth with pits as per instructions for corners to sections 16, 17, 20, 21. Surface broken soil third rate. Township, N. E. D.T. of Range No. 23 Easton's Random line drawn Rects 16 & 21 N. 89°57' E. Variation 14°40' E 2.50 Ravius spurs S. W. 10.50 head of same spurs S. W. 40.00 set temporary one fourth section post, $1.80 intersect section line at corner to sections 15, 16, 21, & 22. 889°57' N on true line between sections 16 & 21. Variation 14°40' E 39.90 set first deposited charged stake raised mound of earth with suits as per instructions for one fourth section corner. $9.80 corner to sections 16, 17, 21, & 22. Surface rolling soil second rate. West of the 6th Principal Meridian North between sections 16, 21 & Variation 14°40' E 2.00 Ravius spurs S. E. 6.00 Ravius spurs S. E. 40.00 set first deposited charged stake raised mound of earth with suits as per instructions for one fourth section corner. 80.00 set post deposited charged stake raised mound of earth with suits as per instructions for corner to sections 8, 9, 16, & 17. Surface rolling soil second rate. Township N. 8 N. of Range N. 22. Eastona Random line from Sects 9+16 N. 890578. Variation 14° 45' 16" 40.00 set temporary one fourth section corner 80.00 intersect section line at corner to sections 9, 10, 15, +16. 8.8957% on true line between sections 9+16. Variation 14° 45' 16" 40.00 set post deposited charged stake raised around of earth with pits as per instructions for one fourth section corner 80.00 set post deposited charged stake raised around of earth with pits as per instructions for corner to sections 2, 3, 8, +9. Surface rolling coil second rate. West of the 6th Principal Meridian North Britzene Sections 8+9. Variation 14° 35' 35" 40.00 set post deposited charged stake raised around of earth with pits as per instructions for one fourth section corner 80.00 set post deposited charged stake raised around of earth with pits as per instructions for corner to sections 2, 3, 8, +9. Surface rolling coil second rate. Township No. 8 N. of Range No. 23 East on a Random line between sections 4 and 9 N. 89°57' E. Variation 14°26' E. 40.00 set temporary one fourth section post 80.08 intersect section line at corner to sections 3, 4, 9 $10 89°57' N. on true line between sections 4 & 9. Variation 14°26' E. 40.04 set post deposited charred lake raised mound of earth with pits as first instructions for me. 80.08 corner to sections 4, 5, 8, & 9. Surface rolling soil second rate. West of the 6th Principal Meridian North on a Random line between sections 4 and 9 Variation 14°30' E. 40.00 set temporary one fourth section post $4.50 intersect second W standard parallel line twenty-eight chains East of corner to sections 3, 4, 8, & 9 set post deposited charred lake raised mound of earth with pits as first instructions for me. 40.08 corner to sections 4, 5, 8, & 9. Surface level soil second rate. September 12th 1869 North between sections 31 & 32 Variation 14° 10' E 5.00 Ravine runs E. E. 29. 00 Ravine runs West 40. 00 set post deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner 43. 00 Ravine runs North 50. 00 Ravine runs North 65. 10 Ravine runs N. W. 72. 00 Ravine runs N. W. 76. 00 Ravine runs N. W. 80. 00 set post deposited charred stake raised mound of earth with pits as per instructions for corner to sections 29, 30, 31, 32. Surface broken soil third rate. East on a Random line between 29 & 32 N. 95° 10' E. Variation 14° 20' E 2. 00 Ravine runs N. E. 8. 00 Ravine runs N. W. 15. 00 30. 00 37. 00 40. 00 set post deposited charred stake raised mound of earth 7. 00 Ravine runs North 75. 00 intersect section line polyone links South of corner to sections twenty-eight twenty-nine thirty-one thirty-two 89. 00 Th on true line between sections 29 & 32 Variation 14° 20' E. 40. 00 set post deposited charred stake raised mound of earth, with pits as per instructions for one fourth section corner 86. 00 Corners to sections 29, 30, 31, 32 surface broken soil third rate. Township N° 81. of Range No. 22 West of the 6th Principal Meridian North between Sections 29 & 30 Variation 14° 40' E 12.00 Ravine runs N. W. 37.50 Main drain runs N. E. 40.00 Set post deflected charred stake raised around of earth with pits as per instructions for one fourth section corner. 38.00 Ravine runs S. E. 80.00 Set post deflected charred stake raised around of earth with pits as per instructions for corner to sections 19, 26, 29, & 30. Surface broken soil third rate Variation 14° 40' E 39.12 Set post deflected charred stake raised around of earth with pits as per instructions for one fourth section corner. 79.12 Corner to sections 29, 30, 31, & 32 Surface broken soil third rate Variation 14° 40' E 47.00 Ravine runs North 36.00 Ravine runs S. E. 19.12 Intersect Range line seventeen links South of corner to sections 30 & 31. Variation 14° 40' E 889.57 E. 79.80 Variation 14° 40' E 39.12 Set post deflected charred stake raised around of earth with pits as per instructions for one fourth section corner. 79.12 Corner to sections 29, 30, 31, & 32 Surface broken soil third rate Township No. 8 N. of Range No. 23 East on a Random line between sections 20 and 29 N.89°57'W Variation 140°30'E Ravine runs South 26.50 deep ravine runs N.E. 40.00 set post for temporary 1/4 section corner 13.50 Plum Creek runs S.E. 71.00 Plum Creek runs N.E. 18.50 Plum Creek runs S.E. 80.86 intersect section line at corner to sections 20, 21, 28 $29 889°57'W on true line between sections 20 and 29 Variation 140°30'E 40.15 set post deposited chanel stake saired around earth with suits as per instructions for one fourth section corner. 87.30 corner to sections 19, 20, 29, 30 Surface rolling soil second rate. West of the 6th Principal Meridian West on a Random line between sections 19 and 30 N.89°57'W Variation 140°40'E 12.00 Ravine runs S.E. 40.00 set temporary one fourth section corner 50.50 Ravine runs S.E. 65.00 Ravine runs S.E. 99.00 intersect range line at corner to sections 18, 19, 20, 29, 30 N.89°57'W on true line between sections 19 and 30 Variation 140°40'E 39.00 set post deposited chanel stake saired around earth with suits as per instructions for one fourth section corner. 79.00 corner to sections 19, 20, 29, 30 Surface rolling soil third rate! Township No. 8 N. of Range 12 E. North between Sections 19 & 20. Variation 14° 30' E 35.00 7.00 25.00 32.50 37.50 40.00 Deep Ravine runs East Deep Ravine runs East Ravine runs S. E. Ravine runs N. E. Ravine runs East set post deposited charred stake raised mound of earth with futs as per instructions for our fourth section corner 55.50 Ravine runs East, 66.50 Ravine runs East, 80.00 set post deposited charred stake raised mound of earth with futs as per instructions for corner to sections 17, 18, 19 & 20. Surface broken soil third rate. Gatona Random line between Sections 17 & 20 N. 89° 57' E Variation 14° 30' E 1.00 Plum Creek runs East dry 30.00 Ravine runs South 48.00 set temporary one fourth section post fifty six 56.00 Ravine runs South 62.00 Ravine runs S. W. 69.00 Ravine runs N. 17 75.00 Ravine runs S. E. 80.00 intersect section line eighty two lines South of corner to sections 16, 17 & 20 & 21. on true line between sections 17 & 20. Variation 14° 30' E 40.00 set post deposited charred stake raised mound of earth with futs as per instructions for 1/4 section corner 80.00 corner to sections 17, 18, 19 & 20 surface broken soil third rate. Township No. 8, Rang No. 22 West on a Random line 100 feet 18+1/9 Variation 14°45' E. 0.25 Plum Creek runs N. E. 12.00 Plum Creek runs S. E. 7.37.00 Ravine runs N. E. 40.00 set temporary one fourth section corner. 58.50 Ravine runs North 72.00 Ravine runs N. E. 76.48 intersect Range line sixty two units South of corners to sections 18, 19 on true line between sections 18 & 19. Variation 14°45' E. 36.48 set frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 76.48 corner to sections 17, 18 19, 20. surface broken soil third rate. West of the 6th Principal Meridian North between Sections 17, 18 Variation 14°40' E. 0.25 Plum Creek runs N. E. 40.00 set frost deposited charred stake raised mound of earth with pits as per instructions for one fourth section corner. 71.58 Ravine runs N. W. 80.00 set frost deposited charred stake raised mound of earth with pits as per instructions for corners to sections 17, 18, 19, 20. surface rolling soil third rate. Township No. 8 N. of Range No. 22 East on a Random line 039°17' N. 89°57' E. Variation 14°40' E. 40.00 set temporary one fourth section post. 79.96 built intersect section line at corner to sections 8, 9, 16 & 17. 8.89. S. 89.057 then true line between sections 8, 9, 17. Variation 14°40' E. 39.9 39.98 set first deposited charred stake raised mound of earth with suits as per instructions for one fourth section corner. 19.80 79.96 corner to sections 7, 8, 17, 16 & 18. Surface rolling soil second rate. West of the 6th Principal Meridian West on a Random line 039°17' N. 89°57' E. Variation 14°40' E. 12.00 Ramire runs S. W. 14.00 Ramire runs S. W. 40.00 set temporary one fourth section post. 64.00 Plum creek runs S. E. 66.00 Plum creek runs S. E. 76.20 intersect Range line at corner to sections 7, 8. N. 89°57' E. true true line between sections 7, 8, 16 & 18. Variation 14°40' E. 76.20 set first deposited charred stake raised mound of earth with suits as per instructions for ¼ section corner. 16.20 corner to sections 7, 8, 17, 18. Surface broken soil third rate. Township N. 8 S. N. of Range No. 23 North between Sections 7 & 8 Variation 10°35' E 40.00 feet post deposited chased stake raised mound of earth with pits as per instructions for one fourth section corners 80.00 set post deposited chased stake raised mound of earth with pits as per instructions for corners to sections 5, 6, 7, & 8. Surface level soil second rate. West of the 6th Principal Meridian East on a Random line between Sections 5 & 8 Variation 14°30' E 40.00 set temporary one fourth section first. 80.00 intersect section line at corners to sections 4, 5, 8, & 9. 889057th. on true line between Sections 5 & 8 Variation 10°30' E 40.00 feet post deposited chased stake raised mound of earth with pits as per instructions for corners 80.00 corners to sections 5, 6, 7, & 8 Surface rolling soil second rate. Township No. 8, N. of Range No. 2 East on a Random line between sections 6 & 7 Variation 14°20' E 40.00 set temporary one fourth section frost 71.57 Ravine runs 8 3/4 75.26 intersect Range line at corner to sections 6 & 7. North on true line between sections 6 & 7 Variation 14°20' E 40.00 set temporary one fourth section frost intersect second stand and parallel line N. twenty eight chains East west of corner & sections 32 1/8 first deposited charred stake raised around of earth with pits as per instructions for one fourth section corner 75.26 corner to sections 6 & 7 surface rolling soil record date. West of the 9th Principal Meridian North on a Random line between sections 5 & 6 Variation 14°20' E 40.00 set temporary one fourth section frost intersect second stand and parallel line N. twenty eight chains East west of corner & sections 32 1/8 first deposited charred stake raised around of earth with pits as per instructions for one fourth section corner 78.22 W. surface rolling soil record date. South on true line between sections 5 & 6 Variation 14°20' E 44.80 set post deposited charred stake raised around of earth with pits as per instructions for one fourth section corner 84.80 corner to sections 5 & 6 surface level soil record date September 13th 1869 General Description. This Township has no land adapted to farming purposes as the country is high and cannot be cultivated without irrigation, and know of no one who ever tried it can be done, as the country is high and no streams feed it, so a large number of canyons in the North East & S.W. frontiers of the Township which obstruct the land south east. Plum Creek runs through the South Western part of the Township that is under all along the margin in most places standing water, there is no improvement in the township. We hereby certify that we assisted James W. Bride deputy surveyor in subdividing Township No. 8 North of Range No. 22 West of the 6th Principal Meridian Nebraska, and that Township has been in all respects, to the best of our knowledge, belief, and faithfully surveyed and the boundary monuments planted according to the instructions furnished by the Surveyor General. A. Hamilton, Chairman J. Ludgeroth, Flagman E. Racie, Wood builder The State of Nebraska, sworn to by the above named persons before Douglas County, and subscribed in my presence this 17th day of November 1869. O. C. Baldwin Wm. Robb Levi A. Martin James McBride, deputy surveyor, do solemnly swear that, in pursuance of a contract with Robert P.R. Livingston, surveyor of the public lands of the United States in the State of Nebraska, bearing date the 21st day of June 1869, and in strict conformity to the laws of the United States and the instructions furnished by the said Surveyor General, I have faithfully surveyed and divided into sections Township No. 8 North of Range No. 22 West of the 6th Principal Meridian, Nebraska, and do further solemnly swear that the foregoing are the true original field notes of such survey. The State of Nebraska Douglas County Subscribed by said James McBride, deputy surveyor, and proven to be true on this 15th day of November 1869. Cleb Baldwin Notary Public Douglas County Nebraska Surveyor General's Office, Plattsmouth, Neb., Mar. 30, 1870 The foregoing field notes of the survey of the subdivision line of township No. 8 North of the Base Line, Range No. 22 West of the 6th Principal Meridian in the State of Nebraska. Executed by James McCorde, Deputy Surveyor under his contract No. 26, dated June 11, 1869, in the month of Sept. 1869. Having been critically examined, the necessary corrections and explanations made to said field notes and the drawings they describe are hereby approved. Robert R. Simpson, Surveyor General. The images in this file are photographs of the notes of the original surveys of the State of Nebraska on file in the Office of the Nebraska State Surveyor located in Lincoln, Nebraska. The original surveys in Nebraska began in the mid 1850’s and were completed in the mid 1880’s. 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Leadership Accountability and Team Approach Delivers a 90% Improvement in Overall Metrics at Saint Michael's Medical Center Hospital Profile Hospital Challenges Saint Michael's Medical Center, located in Newark, New Jersey, operates a 27,000-squarefoot modern Emergency Department, which treats more than 47,000 patients annually. NES Health has been in partnership with Saint Michael's for emergency medicine management and staffing for two years. Saint Michael's Medical Center's (SMMC) goal was to improve the overall delivery of care in the ED and serve their patients in a more timely manner. To do that, SMMC needed a clinical leader to implement best practices and identify departmental opportunities to improve throughput metrics and increase patient satisfaction. SUCCESS & IMPROVEMENTS PARTNERING WITH NES HEALTH 71% 80% 36% 80% Reduction in door to provider time 16% 71% Improvement in overall care score 36% Increase patient satisfaction scores 16% Reduction LWBS rates SOLUTIONS In December 2018, NES Health partnered with SMMC, one of Prime Healthcare's 43 facilities. Immediately, NES placed Dr. Ramy Yakobi as the Site Medical Director. There is no substitute for the right SMD. This role is the cornerstone of every successful ED program. One major issue confronting SMMC was their front end process. Saint Michael's ED would commonly experience large numbers of unoccupied beds attended by available physicians and a chaotic waiting room full of patients and family members. Dr. Yakobi quickly identified the operational flow issues and worked to eliminate the factors contributing to the bottleneck. Moving patients from the waiting room immediately to a bed (pull to full) greatly improved patient satisfaction and throughput metrics. The traditional triage and registration system was replaced by improved bedside triage. Now patients are asked fewer questions and the focus is on vitals, history and clinical focused questions. Although this new triage system was a cultural change for the ED staff, Dr. Yakobi supported the team and helped make it the new normal. RESULTS In partnership with SMMC leadership team, NES' clinical and operational team helped transform, and sustain improved patient care over the last two years. Some highlights of progress included the following: 71% improvement in overall care score in less than 1 year. From 20th out of 43 Prime facilities to 4th overall, 80% percent reduction in door to provider times, from 57 minutes to 11 minutes. 16% reduction in LWBS rates, from 2.44% to 2%, and a 36% increase in patient satisfaction from 52% to 71%.	<urn:uuid:4387914e-b94d-46f6-bcdf-7f6784210556>	CC-MAIN-2020-40	http://www.neshealth-care.com/wp-content/uploads/2020/04/Case-Study_SaintMichaels_NJ.pdf	2020-09-22T11:28:20+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2020-40/subset=warc/part-00200-50bb8e61-7c5b-4d2c-bd34-dad6ca92b697.c000.gz.parquet	210,431,753	551	eng_Latn	eng_Latn	0.998403	eng_Latn	0.998403	[ "eng_Latn" ]	false	rolmOCR	[ 2630 ]
Grade 6 – Integrated Curriculum Language Arts, Math, Science, Social Studies, The Arts, and World Languages LANGUAGE ARTS OAC 210:15-3-17 Reading/Literature: The student will apply a wide range of strategies to comprehend, interpret, evaluate, appreciate, and respond to a wide variety of texts. Standard 1: Vocabulary - The student will develop and expand knowledge of words and word meanings to increase vocabulary. 1. Words in Context a. Use knowledge of word parts and word relationships, as well as context clues (the meaning of the text around a word), to determine the meaning of technical and specialized vocabulary and to understand the precise meaning of grade-level-appropriate words in fiction and nonfiction texts. b. Use prior experience and context to analyze and explain the figurative use of words, similes (comparisons that use like or as: The Snowplow Reared Up Like a Stallion), metaphors (implied comparisons: Peace is a Sunrise), and multiple meaning words. 2. Word Origins a. Recognize the origins and meanings of foreign words frequently used in English. Example: Understand foreign words that are often used in English such as spaghetti (Italian) and rodeo (Spanish). b. Apply knowledge of root words to determine the meaning of unknown words within a passage. c. Use word origins, including knowledge of less common roots (graph = writing, logos = the study of) and word parts (auto = self, bio = life) from Greek and Latin to analyze the meaning of complex words (autograph, autobiography, biology). 1 3. Using Resource Materials and Aids a. Determine the meanings, pronunciation, and derivations of unknown words by using a glossary, dictionary, and/or thesaurus. b. Relate dictionary definitions to context of the reading in order to aid understanding. Standard 2: Fluency - The student will identify words rapidly so that attention is directed at the meaning of the text. 1. Read regularly in independent-level texts (texts in which no more than approximately 1 in 10 words is difficult for the reader) fluently and accurately, and with appropriate timing, change in voice, and expression. 2. Read regularly in instructional-level texts (texts in which no more than approximately 1 in 10 words is difficult for the reader; a "typical" sixth grader reads approximately 120 words per minute). 3. Increase silent reading speed through daily independent reading. 4. Read silently for increased periods of time. Standard 3: Comprehension/Critical Literacy - The student will interact with the words and concepts in the text to construct an appropriate meaning. Read and understand grade-level-appropriate material. Describe and connect the essential ideas, arguments, and perspectives of the text by using the knowledge of text structure, organization, and purpose. At Grade 6, in addition to regular classroom reading, students read a variety of grade-levelappropriate narrative (story) and expository (informational and technical) texts, including classic and contemporary literature, poetry, magazines, newspapers, reference materials, and online information as well as expository (informational and technical) text. 1. Literal Understanding a. Use prereading strategies independently (to preview, activate prior knowledge, predict content of text, formulate questions that might be answered by the text, establish purpose for reading). b. Read and comprehend both fiction and nonfiction that is appropriately designed for sixth grade. c. Recognize main ideas presented in a particular segment of text; identify and assess evidence that supports those ideas. Example: Use a graphic organizer to compare an advertisement to the actual product label. d. Use the text's structure or progression of ideas, such as cause and effect or chronology to locate or recall information. 2. Inferences and Interpretation a. Draw inferences and conclusions about text and support them with textual evidence and prior knowledge. b. Make inferences or draw conclusions about characters' qualities and actions (i.e., based on knowledge of plot, setting, characters' motives, characters' appearances, other characters' responses to a character). c. Interpret and respond creatively to literature (e.g., art, drama, oral presentations, and Reader's Theater). 3. Summary and Generalization a. Summarize and paraphrase information including the main idea and significant supporting details of a reading selection. b. Make generalizations based on information gleaned from text. c. Support reasonable statements and conclusions by reference to relevant aspects of text and examples. d. Clarify understanding of text information in different ways (e.g., timelines, outlines, graphic organizer) to support and explain ideas. 4. Analysis and Evaluation a. Evaluate the believability of a character and the impact they have on the plot. b. Analyze the main problem or conflict of the plot; the effect of the qualities of the characters and explain how the conflict is resolved. c. Contrast the actions, motives, and appearances of characters in a work of fiction and discuss the importance of the contrasts to the plot or theme. d. Make observations, connections, and react, speculate, interpret, and raise questions in analysis of texts. e. Recognize and evaluate structural patterns found in a literary work (e.g., cause/effect, problem/solution, sequential order). f. Distinguish among stated facts, inferences supported by evidence, and opinions in text. 5. Monitoring and Correction Strategies a. Monitor own reading and modify strategies as needed when understanding breaks down (e.g., rereading a portion aloud, using reference aids, trying an alternate pronunciation, searching for clues, and asking questions). b. Clarify meaning by questioning and rereading; confirm and revise predictions as needed when reading. c. Adjust reading rate and determine appropriate strategies according to the purpose for reading, the difficulty of the text, and characteristics of the text. Standard 4: Literature - The student will read, construct meaning, and respond to a wide variety of literary forms. Read and respond to grade-level-appropriate historically or culturally significant works of literature that reflect and enhance a study of history and social science. Clarify ideas and connect them to other literary works. Participate productively in self-directed work teams to create observable products. 1. Literary Genres - The student will demonstrate a knowledge of and an appreciation for various forms of literature. a. Analyze the characteristics of genres, including short story, novel, drama, poetry, and nonfiction. b. Analyze characteristics of subgenres, including autobiography, biography, fable, folk tale, mystery, and myth. 2. Literary Elements - The student will demonstrate knowledge of literary elements and techniques and how they affect the development of a literary work. a. Identify and explain elements of fiction, including plot, conflict, character, setting, and theme. b. Identify and explain internal and external conflict in the development of a story. c. Determine the author's purpose (persuade, inform, entertain) and point of view, whether explicitly or implicitly stated and how it affects the text. d. Connect, compare, and contrast ideas, themes, and issues across texts. 3. Figurative Language and Sound Devices - The student will identify figurative language and sound devices and will analyze how they affect the development of a literary work. a. Identify and explain figurative language, including symbolism, imagery, metaphor, personification, simile, and idioms. b. Identify and explain sound devices, including alliteration, onomatopoeia, and rhyme. c. Interpret poetry and recognize poetic styles (e.g., rhymed, free verse, and patterned [cinquain, diamante]). d. Identify and describe the function and effect of common literary devices, such as imagery and symbolism. * Imagery: the use of language to create vivid pictures in the reader's mind. * Symbolism: the use of an object to represent something else; for example, a dove might symbolize peace. 4. Literary Works - The student will read and respond to historically and culturally significant works of literature. a. Analyze and evaluate works of literature and the historical context in which they were written. b. Analyze and evaluate literature from various cultures to broaden cultural awareness. c. Compare similar characters, settings, and themes from varied literary traditions. Standard 5: Research and Information - The student will conduct research and organize information. 1. Accessing Information - The student will select the best source for a given purpose. a. Use library catalogs and computer databases to locate sources for research topics. b. Access information from a variety of primary and secondary sources to gather information for research topics c. Use organizational strategies as an aid to comprehend increasingly difficult content material. d. Note instances of persuasion, propaganda, faulty reasoning, or misleading information in text. e. Use reference features of printed text, such as citations, endnotes, and bibliographies, to locate relevant information about a topic. 2. Interpreting Information - The student will analyze and evaluate information from a variety of sources. a. Record, organize, and display relevant information from multiple sources in systemic ways (e.g., outlines, graphic organizers, or note cards). b. Identify and credit the reference sources used to gain information. c. Determine the appropriateness of an information source for a research topic. d. Summarize information from multiple sources into a research paper. Writing/Grammar/Usage and Mechanics. The student will express ideas effectively in written modes for a variety of purposes and audiences, discuss and keep a list of writing ideas, and use graphic organizers to plan writing. The student will write clear, coherent, and focused papers, and progress through the stages of the writing process. The student will work independently and in selfdirected writing teams to edit and revise. Standard 1: Writing Process. The student will use the writing process to write coherently. 1. Use a variety of prewriting strategies such as brainstorming, webbing, or using other graphic organizers to develop an idea appropriate for the intended audience, purpose, and topic. 2. Add details, examples, reasons, and evidence to develop and support an idea. 3.Use organizational patterns such as spatial, chronological/sequential, cause and effect or climactic as appropriate to purpose. 4. Use effective transitions for effective blending of sentences and paragraphs. 5. Use precise and vivid word choices, including figurative language, that convey specific meaning and tone. 6. Use a variety of sentence types and lengths to contribute to fluency and interest. 7. Using standard editing marks, edit for errors in Standard English usage, sentence structure, mechanics, and spelling. 8. Publish and present to peers and adults. Standard 2: Modes and forms of writing. The student will write for a variety of purposes and audiences using narrative, descriptive, expository, persuasive, and reflective modes. At Grade 6, write narrative, expository, persuasive, argumentative, reflective, and descriptive modes of at least 500 to 700 words, demonstrating a command of Standard English and the research, organization, and drafting strategies outlined in the writing process. Writing demonstrates an awareness of the audience (intended reader) and purpose for writing. 1. Compose fictional, biographical, and autobiographical narratives that: a. establish and develop a plot and setting with a distinct beginning, middle, and ending. b. establish and develop a setting, characters, and point of view appropriate for the narrative. c. use a range of narrative devices, such as dialogue or suspense. d. adjust tone and style as necessary to make writing interesting and engaging to the audience. 2. Compose expository test including descriptions, explanations, comparison and contrast, and problem and solution compositions that: a. state the thesis (position on the topic), main idea, or purpose. b. explain the situation including supporting paragraphs with facts, details, and explanations. c. organize the composition clearly and appropriately for the purpose of the writing. d. include evidence and supporting details by paraphrasing from speakers, newspapers, magazines, media sources, or reference books to support arguments and conclusions. Example: Write successive drafts of a one or two page newspaper article about school carnival activities, including details to support the main topic and allow the reader to compare and contrast the different carnival activities described or a description of a school event including details to support the main idea.) 3. Compose persuasive/argumentative compositions that: a. state a clear position on a proposition or proposal. b. support the position with organized and relevant evidence and effective emotional appeals. c. predict, identify, and address reader concerns and counterarguments. Example: Write a persuasive paper on how the class should celebrate the end of the school year, including adequate reasons for why the class should participate in the activity described. d. Create an advertisement for a product to try to convince readers to buy the product. 4. Compose reflective papers that may address one of the following purposes: a. express the individual's insight into conditions or situations. b. compare a scene from a work of fiction with a lesson learned from experience. c. complete a self-evaluation. Example: Write a self-evaluation on a personal strength. 5. Write responses to literature, including poetry, that: a. include an interpretation that shows careful reading, understanding, and insight. b. organize the interpretation around several clear ideas. c. develop and justify the interpretation through the use of examples and evidence from the text. Example: After reading a novel, write a final chapter to the book describing what happens to the main character after the point where the book ends and how it is supported by the rest of the narrative. 6. Write for different purposes and to a specific audience or person, adjusting tone and style as necessary to make writing interesting. Example: Write stories, reports, and letters showing a variety of word choices, or review a favorite book or film. 7. Compose summaries of reading material that: a. include the main idea and most significant details. b. use the student's own words except for direct quotations. 8. Compose friendly and formal letters, and emails; continue to produce other writing forms introduced in earlier grades. Example: Write a formal letter requesting a catalog. 9. Use appropriate essay test-taking and time-writing strategies that: a. address and analyze the question (prompt). b. use organizational methods required by the prompt. 9 c. utilize an editing checklist or assessment rubric, if provided. 10. Use handwriting/penmanship to copy and/or compose text, in manuscript or cursive, using correct spacing and formation of letters. Standard 3: Grammar/Usage and Mechanics. The student will demonstrate appropriate practices in writing by applying Standard English conventions to the revising and editing stages of writing. 1. Standard English Usage - Demonstrate correct use of Standard English in speaking and writing as appropriate to sixth grade. a. Identify concrete, abstract, and collective nouns. b. Identify the principal parts of verbs to form verb tenses. c. Identify linking, transitive, and intransitive verbs. d. Identify nominative, objective, and possessive pronouns correctly. e. Correctly use pronoun reference, and make pronouns agree with their antecedents. f. Correctly form and use the positive, comparative, and superlative forms of adjectives. g. Correctly form and use adverb clauses. h. Identify and correctly use appositives, restrictive (essential) and nonrestrictive (nonessential) clauses and phrases. i. Identify direct objects, indirect objects, objects of prepositions, predicate nominatives and predicate adjectives. j. Use prepositional phrases to elaborate written ideas. k. Correctly use all conjunctions. l. Correctly identify and use interjections m. Distinguish commonly confused words (e.g., there, their, they're; two, to, too; accept, except; affect, effect). n. Form regular and irregular plurals correctly. o. Make subjects and verbs agree. 2. Sentence Structure - Demonstrate appropriate sentence structure in writing all forms of sentences (declarative, imperative, exclamatory and interrogative). a. Correct sentence run-ons and fragments. b. Correct dangling and misplaced modifiers. c. Differentiate between dependent, independent, restrictive (essential), and nonrestrictive (nonessential) clauses. d. Write simple and compound sentences. e. compose sentences with simple, complete, and compound predicate. f. Indent paragraphs as needed for specified format. 3. Mechanics and Spelling - Demonstrate appropriate language mechanics in writing. a. Apply the capitalization rules appropriately in writing. b. Punctuate correctly in writing including: * end punctuation. * commas to separate words in a series, city and state, quotation and sentence, and to set off nonrestrictive phrases. * quotation marks. * colon and semicolon. * apostrophes in contractions and possessives. * hyphens and dashes. * conventions of letter writing. Oral Language/Listening and Speaking: The student will demonstrate thinking skills in listening and speaking. Deliver focused, coherent presentations that convey ideas and relate to the background and interests of the audience. Evaluate the content of oral communication. Deliver well-organized formal presentations using traditional speech strategies including narration, exposition, persuasion, and description. Use the same Standard English conventions for oral speech that are used in writing. Participate independently and in groups to create oral presentations. Standard 1: Listening - The student will listen for information and for pleasure. 1. Identify the major ideas and supporting evidence in informative and persuasive messages. 2. Determine the purpose for listening (i.e., gaining information, solving problems; or for enjoying, appreciating, recalling, interpreting, applying, analyzing, evaluating, receiving directions, or learning concepts). 3. Recognize and understand barriers to effective listening (i.e., internal and external distractions, personal biases, and conflicting demands). 4. Evaluate the spoken message in terms of content, credibility, and delivery. Standard 2: Speaking - The student will express ideas and opinions in group or individual situations. 1. Analyze purpose, audience, and occasion and consider this information in planning an effective presentation or response. 2. Compose a presentation with a well-organized introduction, body, and conclusion that is appropriate for different purposes, audiences, and occasions. 3. Communicate using appropriate delivery (volume, rate, enunciation, and movement). Visual Literacy: The student will interpret, evaluate, and compose visual messages. Standard 1: Interpret Meaning - The student will interpret and evaluate the various ways visual image-makers, including graphic artists, illustrators, and news photographers, represent meaning. 1. Interpret a variety of messages conveyed by visual images (e.g., main concept, details, themes, lessons, or viewpoints). 2. Identify film and television features that characterize different style of dress and genres (e.g., setting in a western or a drama). Standard 2: Evaluate Media - The student will evaluate visual and electronic media, such as film, as compared with print messages. 1. Identify the different ways in which people are stereotyped in visual media and consider alternative representations (e.g., clever people wear glasses, super heroes wear capes, scientists wear white coats). 2. Identify basic elements of advertising in visual media (e.g., sales approaches and techniques aimed at children). 3. Evaluate how different media forms influence and inform viewers. 4. Assess how language, medium, and presentation contribute to the message. Standard 3: Compose Visual Messages - The student will create a visual message that effectively communicates an idea and produces communication using technology or appropriate media, such as developing a class newspaper, multimedia reports, or video reports. Blueprints for each Criterion-Referenced Test reflect the degree of representation given on the test to each PASS standard and objective. To access the current blueprint (when available) go to the State Department of Education Web site at <http://sde.state.ok.us>, click on site index, then click "s" to go to student assessment, then click on "Student Tests & Materials" then scroll down to "alignment blueprints." MATHEMATICS OAC 210:15-3-46.1 MATHEMATICS PROCESS STANDARDS Grades 6 - 8 The National Council of Teachers of Mathematics (NCTM) has identified five process standards: Problem Solving, Reasoning and Proof, Communication, Connections, and Representation. Active involvement by students using these processes is likely to broaden mathematical understandings and lead to increasingly sophisticated abilities required to meet mathematical challenges in meaningful ways. Process Standard 1: Problem Solving 1. Develop and test strategies to solve practical, everyday problems which may have single or multiple answers. 2. Use technology to generate and analyze data to solve problems. 3. Formulate problems from situations within and outside of mathematics and generalize solutions and strategies to new problem situations. 4. Evaluate results to determine their reasonableness. 5. Apply a variety of strategies (e.g., restate the problem, look for a pattern, diagrams, solve a simpler problem, work backwards, trial and error) to solve problems, with emphasis on multistep and non-routine problems. 6. Use oral, written, concrete, pictorial, graphical, and/or algebraic methods to model mathematical situations. Process Standard 2: Communication 1. Discuss, interpret, translate (from one to another) and evaluate mathematical ideas (e.g., oral, written, pictorial, concrete, graphical, algebraic). 2. Reflect on and justify reasoning in mathematical problem solving (e.g., convince, demonstrate, formulate). 14 3. Select and use appropriate terminology when discussing mathematical concepts and ideas. Process Standard 3: Reasoning 1. Identify and extend patterns and use experiences and observations to make suppositions. 2. Use counter examples to disprove suppositions (e.g., all squares are rectangles, but are all rectangles squares?). 3. Develop and evaluate mathematical arguments (e.g., agree or disagree with the reasoning of other classmates and explain why). 4. Select and use various types of reasoning (e.g., recursive [loops], inductive [specific to general], deductive [general to specific], spatial, and proportional). Process Standard 4: Connections 1. Apply mathematical strategies to solve problems that arise from other disciplines and the real world. 2. Connect one area or idea of mathematics to another (e.g., relates equivalent number representations to each other, relate experiences with geometric shapes to understanding ratio and proportion). Process Standard 5: Representation 1. Use a variety of representations to organize and record data (e.g., use concrete, pictorial, and symbolic representations). 2. Use representations to promote the communication of mathematical ideas (e.g., number lines, rectangular coordinate systems, scales to illustrate the balance of equations). 3. Develop a variety of mathematical representations that can be used flexibly and appropriately (e.g., base-10 blocks to represent fractions and decimals, appropriate graphs to represent data). 4. Use a variety of representations to model and solve physical, social, and mathematical problems (e.g., geometric objects, pictures, charts, tables, graphs). MATHEMATICS CONTENT STANDARDS OAC 210:15-3-47 The following concepts and skills should be mastered by all students upon completion of sixth grade. The Major Concepts should be taught in depth using a variety of methods, applications, and connections to other concepts when possible so that all students have accessibility to and an understanding of these concepts. MAJOR CONCEPTS Develop an understanding of and fluency with multiplication and division of fractions and decimals. * Write, interpret, use, simplify, and solve mathematical expressions and equations. * Develop a basic understanding of integer operations. Standard 1: Algebraic Reasoning: Patterns and Relationships – The student will use algebraic methods to describe patterns, simplify and write algebraic expressions and equations, and solve simple equations in a variety of contexts. 1. Generalize and extend patterns and functions using tables, graphs, and number properties (e.g., number sequences, prime and composite numbers, recursive patters like the Fibonacci numbers). 2. Write algebraic expressions and simple equations that correspond to a given situation. 3. Use substitution to simplify and evaluate algebraic expressions (e.g., if x = 5 evaluate 3 - 5x). 4. Write and solve one-step equations with one variable using number sense, the properties of operations, and the properties of equality (e.g., 1/3x = 9). Standard 2: Number Sense and Operation – The student will use numbers and number relationships to solve a variety of problems. The student will estimate and compute with integers, fractions, and decimals. 1. Number Sense: Convert compare, and order decimals, fractions, and percents using a variety of methods. 2. Number Operations a. Multiply and divide fractions and mixed numbers to solve problems using a variety of methods. b. Multiply and divide decimals with one- or two-digit multipliers or divisors to solve problems. c. Estimate and find solutions to single and multi-step problems using whole numbers, decimals, fractions, and percents (e.g., 7/8 + 8/9 is about 2, 3.9 + 5.3 is about 9). d. Use the basic operations on integers to solve problems. e. Build and recognize models of multiples to develop the concept of exponents and simplify numerical expressions with exponents and parentheses using order of operations. Standard 3: Geometry - The student will use geometric properties and relationships to recognize, describe, and analyze shapes and representations in a variety of contexts. 1. Compare and contrast the basic characteristics of three-dimensional figures (pyramids, prisms, cones, and cylinders). 2. Compare and contrast congruent and similar figures. 3. Identify the characteristics of the rectangular coordinate system and use them to locate points and describe shapes drawn in all four quadrants. Standard 4: Measurement - The student will use measurements within the metric and customary systems to solve problems in a variety of contexts. 1. Use formulas to find the circumference and area of circles in terms of pi. 2. Convert, add, or subtract measurements within the same system to solve problems (e.g., 9' 8" + 3' 6, 150 minutes = __ hours and __ minutes, 6 square inches = __ square feet). Standard 5: Data Analysis - The student will use data analysis, probability, and statistics to interpret data in a variety of contexts. 1. Data Analysis: Organize, construct displays, and interpret data to solve problems (e.g., data from student experiments, tables, diagrams, charts, graphs). 2. Probability: Use the fundamental counting principle on sets with up to five items to determine the number of possible combinations. 3. Central Tendency: Find the measures of central tendency (mean, median, mode, and range) of a set of data (with and without outliers) and understand why a specific measure provides the most useful information in a given context. Note: Asterisks () have been used to identify standards and objectives that must be assessed by the local school district. All other skills may be assessed by the Oklahoma School Testing Program (OSTP). SCIENCE OAC 210:15-3-76 Standards for Inquiry, Physical, Life, and Earth/Space Science The Priority Academic Student Skills (PASS) should be taught by investigating content, concepts, and principles of major themes in Physical, Life, and Earth/Space Sciences. SCIENCE PROCESSES AND INQUIRY Process Standard 1: Observe and Measure - Observing is the first action taken by the learner to acquire new information about an object, organism, or event. Opportunities for observation are developed through the use of a variety of scientific tools. Measurement allows observations to be quantified. The student will accomplish these objectives to meet this process standard. 1. Identify qualitative and/or quantitative changes given conditions (e.g., temperature, mass, volume, time, position, length) before, during, and after an event. 2. Use appropriate tools (e.g., metric ruler, graduated cylinder, thermometer, balances, spring scales, stopwatches, computers and hand held data collection devices) to measure objects, organisms, and/or events. 3. Use appropriate International System of Units (SI) (i.e., grams, meters, liters, degrees Celsius, and seconds); and SI prefixes (i.e. milli-, centi-, and kilo-) when measuring objects, organisms and/or events. Process Standard 2: Classify - Classifying establishes order. Objects, organisms, and events are classified based on similarities, differences, and interrelationships. The student will accomplish these objectives to meet this process standard. 1. Using observable properties, place an object, organism, and/or event into a classification system (e.g., dichotomous keys, periodic table, biological hierarchy). 2. Identify properties by which a set of objects, organisms, or events could be ordered. Process Standard 3: Experimental design - Understanding experimental designs requires that students recognize the components of a valid experiment. The student will accomplish these objectives to meet this process standard. 1. Ask questions about the world and design investigations that lead to scientific inquiry. Identify testable questions based on prior knowledge, background research, or observations. 2. Evaluate the design of a scientific investigation. 3. Identify variables and/or controls in an experimental setup: independent variable and dependent variable. 4. Identify a testable hypothesis for an experiment. 5. Follow a multistep procedure when carrying out experiments, taking measurements, or performing technical tasks. 6. Recognize potential hazards and practice safety procedures in all science activities. Process Standard 4: Interpret and Communicate - Interpreting is the process of recognizing patterns in collected data by making inferences, predictions, or conclusions. Communicating is the process of describing, recording, and reporting experimental procedures and results to others. Communication may be oral, written, or mathematical and includes organizing ideas, using appropriate vocabulary, graphs, other visual representations, and mathematical equations. The student will accomplish these objectives to meet this process standard. 1. Report and record both quantitative/qualitative data in an appropriate method when given an experimental procedure or data. 2. Interpret data tables, line, bar, trend, and/or circle graphs. 3. Evaluate data to develop reasonable explanation, and/or predictions. 4. Determine if results of investigations support or do not support hypotheses. 5. Communicate scientific processes, procedures, and conclusions (e.g., model, poster, diagram, journal entry, lab report, scientific paper, oral presentation, and digital presentation). Process Standard 5: Inquiry - Inquiry can be defined as the skills necessary to carry out the process of scientific thinking. In order for inquiry to occur students must have the opportunity to make observations, pose questions, formulate testable hypotheses, carry out experiments, and make conclusions based on evidence. The student will accomplish these objectives to meet this process standard. 1. Ask questions that can be answered through scientific investigation. 2. Design and conduct experiments utilizing scientific processes. 3. Use the engineering design process to address a problem or need (e.g., identify a need, conduct background research, prepare preliminary designs, build and test a prototype, test and revise design, communicate results). 4. Understand the value of, and use technology to gather data and analyze results of investigations (e.g., probes, hand-held digital devices, digital cameras, software). 5. Develop a logical relationship between evidence and explanation to form and communicate a valid conclusion, and suggest alternative explanations. PHYSICAL SCIENCE Standard 1: Physical Properties in Matter - Physical characteristics of objects can be described using shape, size, and mass whereas the materials from which objects are made can be described using color and texture. The student will engage in investigations that integrate the process standards and lead to the discovery of the following objectives: 1. Matter has physical properties that can be measured (i.e., mass, volume, temperature, color, and texture). Changes in physical properties of objects can be observed, described, and measured using tools such as simple microscopes, gram spring scales, metric rulers, metric balances, and Celsius thermometers. 2. The mass of an object is not altered due to changes in shape. Standard 2: Transfer of Energy - Change from one form of energy to another. The student will engage in investigations that integrate the process standards and lead to the discovery of the following objectives: 1. Energy exists in many forms such as, heat, light, electricity, mechanical motion, and sound. Energy can be transferred in various ways (e.g., potential to kinetic, electrical to light, chemical to electrical, mechanical to electrical). 2. Electrical circuits provide a means of transferring electrical energy when heat, light, and sound are a. produced (e.g., open and closed circuits, parallel and series circuits). 3. Electric currents and magnets can exert a force on each other (e.g., direct and alternating currents). LIFE SCIENCE Standard 3: Structure and Function in Living Systems - Living systems at all levels of organization demonstrate the complementary nature of structure and function. The student will engage in investigations that integrate the process standards and lead to the discovery of the following objectives: 1. Cells are the building blocks of all organisms (both plants and animals). a. Plant and animal cells have similarities and differences (i.e., nucleus, mitochondria, cell wall, plasma membrane, chloroplast, and vacuole). 2. Living systems are organized by levels of complexity (i.e., cells, organisms, and ecosystems). Standard 4: Populations and Ecosystems - Populations consist of individuals of a species that occur together at a given place and time. All populations living together and the physical factors with which they interact compose an ecosystem. The student will engage in investigations that integrate the process standards and lead to the discovery of the following objectives: 1. Organisms within an ecosystem are dependent on one another and on nonliving components of the environment. Some source of energy is needed for all organisms to stay alive and grow. Energy transfer can be followed in food chains and webs. 2. In all environments, organisms with similar needs may compete with one another for resources, including food, space, water, air, and shelter. Other relationships may be beneficial (e.g., producers/autotrophs, consumers/heterotrophs, symbiosis). EARTH/SPACE SCIENCE Standard 5: Structures of the Earth and the Solar System - The earth is mostly rock, threefourths of its surface is covered by a relatively thin layer of water, and the entire planet is surrounded by a relatively thin blanket of air, and is able to support life. The student will engage in investigations that integrate the process standards and lead to the discovery of the following objectives: 1. Earth has four main systems that interact: the geosphere, the hydrosphere, the atmosphere, and the biosphere. a. The geosphere is the portion of the Earth system that includes the Earth's interior, rocks and minerals, landforms and the processes that shape the Earth's surface. b. The hydrosphere is the liquid water component of the Earth. Water, which covers the majority of the Earth's surface and circulates through the crust, oceans and atmosphere in what is known as the water cycle. c. The atmosphere is a mixture of nitrogen, oxygen, and trace gases that include water vapor. The atmosphere has a different physical and chemical composition at different elevations. d. The biosphere is made up of all that is living on the Earth. It is a life-supporting global ecosystem, where living things depend on other organisms and the environment. 2. The sun provides the light and heat necessary to maintain life on Earth and is the ultimate source of energy (i.e., producers receive their energy from the sun). SOCIAL STUDIES OAC 210:15-3-96 WORLD STUDIES World Studies is designed to offer students the opportunity to begin a more global study of the earth's people and environments, concentrating on the understanding of basic concepts and characteristics common in the political and economic development of human populations. Standard 1: The student will develop and practice the process skills of social studies. 1. Locate, gather, and analyze information from primary and secondary sources, such as artifacts, diaries, letters, art, music, literature, newspapers, and contemporary media. 2. Identify, evaluate, and draw conclusions from different kinds of maps, graphs, charts, diagrams, timelines, and other representations such as photographs and satellite-produced images or computer-based technologies. 3. Interpret information from a broad selection of research materials such as encyclopedias, almanacs, dictionaries, atlases and cartoons. Standard 2: The student will use geographic representations to draw conclusions. 1. Apply the concepts of scale, orientation, latitude and longitude, and physical regions. 2. Compare political, physical, and thematic maps, 3. Define, recognize, and locate basic landforms and bodies of water on appropriate maps and globes. Standard 3: The student will analyze selected cultures which have affected our history. 1. Define the characteristics of culture and the role culture played on the development of the world's peoples. 2. Compare and contrast common characteristics of culture, such as language, customs, shelter, diet, traditional occupations, belief systems, and folk traditions. 3. Evaluate the impact of selected civilizations (such as Egypt, Greece, Rome, Mayan, Incan, and Chinese) on migration and settlement patterns. Standard 4: The student will compare and contrast political and economic systems. 1. Identify and describe major world political systems and the role of governmental involvement in such systems (such as dictatorships, constitutional monarchies, and representative democracies). 2. Identify and describe major economic systems and the role of governmental involvement and individual decision-making within such systems (such as traditional, command, and market economies). NOTE: Asterisks () have been used to identify standards and objectives that must be assessed by the local school district. All other skills may be assessed by the Oklahoma School Testing Program (OSTP). Book icons () identify Information Literacy skills. Students are best served when these are taught in collaboration and cooperation between the classroom teacher and the library media specialist. THE ARTS OAC 210:15-3-120 VISUAL ART Standard 1: Language of Visual Art - The student will identify Visual Art terms (i.e., still life, contour, composition, foreshortening, foreground, perspective). 1. Describe and apply knowledge of the principles of design: rhythm, balance (symmetrical, asymmetrical, radial) contrast, movement, variety, center of interest (emphasis), and repetition in his/her own art work, and the art works of others. 2. Describe and use the elements of art: line, color, form, shape, texture, value (light and dark), and space in works of art. Identify and discriminate between types of shape (geometric and organic), colors (primary, secondary, complementary, intermediates, neutrals, tints, tones, shades, and values), lines (characteristics, quality), textures (tactile and visual), and space (background, middleground, foreground, placement, perspective, overlap, negative, positive, size, color) in his/her own artwork, and the artworks of others. 3. Compare works which are similar or different in expressive quality, composition, and style. () 4. Discuss works of art of different media and styles beyond statements of mere preference. () Standard 2: Visual Art History and Culture - The student will recognize the development of visual art from an historical and cultural perspective. 1. Recognize and describe the cultural and ethnic traditions which have influenced the visual arts including European, American, Native American, African American, Hispanic, and Asian traditions. () 2. Describe and place a variety of specific significant art objects by artist, style and historical and cultural context. () 3. Identify the variety of art forms used in business and industry, including advertising, television, and film. () School Improvement 4. Discuss the relationship that exists between visual art and other art forms such as music, dance, and drama. 5. Communicate in-depth knowledge gained through integrated study of a visual art theme, historical period, or event. () Standard 3: Visual Art Expression - The student will observe, select, and utilize a variety of ideas and subject matter in creating original works of art. 1. Make original works of art using a variety of materials (media), and techniques (skills), and sources for ideas. 2. Use observation, memory and imagination in making original works of art. 3. Demonstrate safe and proper use, care, and storage of media, materials, and equipment. 4. Apply knowledge of a basic art vocabulary through experiences in making original works of art. 5. Demonstrate a basic knowledge of media, techniques and processes in: Painting media: tempera, watercolor, oil, and acrylic. processes: wet-on-wet, wet-on-dry, wash, resist, sponge. Sculpture or media: paper, papier-mâché, clay, plaster, cardboard, wood Architecture found objects, beads, sand, wire. processes: carving, constructing, and assembling. Drawing media: pencils, colored pencils, markers, chalks, crayons, oil-pastels. processes: sketching, contour line, hatching, crosshatching. Printmaking media: printing ink, styrofoam, stencil, found objects. processes: relief, silkscreen, and monoprint. Fiber Arts media: cloth, yarn, ribbon, found objects, paper, and rope. processes: weaving, stitchery, braiding, and basketry. Standard 4: Visual Art Appreciation - The student will appreciate visual art as a vehicle of human expression. 1. Demonstrate appropriate behavior while attending a visual art exhibition in a museum or art gallery. 2. Demonstrate respect for personal artwork and the artwork of others. 3. Demonstrate thoughtfulness and care in completion of artworks. GENERAL MUSIC Standard 1: Language of Music - The student will read, notate and interpret music. 1. Define and use correct terminology to identify and discuss the elements of music including: a. Melody (steps, wide and narrow leaps, repeated tones, phrases, pentatonic scale [five-tone scale]). b. Rhythm (steady beat, back beat, syncopation, triplets, dotted rhythms, 2/2 meter). c. Harmony (partner songs, rounds, descants, countermelody, major and minor chords). d. Form (AB, ABA, round, rondo, theme and variations, introduction, coda, interlude, verse and refrain, prelude). e. Tone color (opera, musical theater, duet, trio, quartet, chorus, voice ranges and instrument ranges). f. Pitch (range and register). g. Tempo - allegro (fast), lento (slow), andante (walking), moderato (moderate). h. Dynamics - forte (loud), piano (soft), mezzo forte (medium loud), mezzo piano (medium soft). 2. Identify basic notational symbols (written representation of music), including: treble and bass clef, time signatures; (2/4, 3/4, 4/4, and 6/8); note values (whole note, half note, quarter note, eighth note, dotted half note, dotted quarter note, and the corresponding rests). 3. Experiment with variations in and demonstrate understanding of tempo (speed), tone quality (sound quality), dynamics (degree of loudness) and phrasing for expressive purpose in performing music. 4. Identify visually and aurally: a. instrumental ensembles (marching band, symphony orchestra, jazz band). b. families of orchestral instruments (strings, woodwinds, brass, and percussion). c. classification of voice ranges (soprano, alto, tenor, bass). 5. Notate (written representation of music) simple pitch and rhythm patterns presented aurally (listening). Standard 2: Music History and Culture - The student will recognize the development of music from an historical and cultural perspective. 1. Sing or play a variety of folk, ethnic, classical, and contemporary musical compositions. 2. Recognize, describe and listen to music from a variety of: a. Styles (jazz, mariachi band, opera, musical, call-response). b. Periods (Baroque, Classical, Romantic, Impressionism and Contemporary). c. Cultures including European, Native American, African American, Hispanic, and Asian. 3. Identify and differentiate the use of musical elements and instruments from other parts of the world and compare them to the use of musical elements in American music (patriotic, orchestral, band and folk). ( ) 4. Identify and describe the roles of musicians in various music setting and cultures. Standard 3: Music Expression - The student will perform, compose, improvise and arrange a variety of music within specified guidelines. 1. Perform basic tonal patterns and rhythm patterns on classroom instruments (autoharp, recorder, percussion instruments, and guitar). 2. Demonstrate the ability to read music from basic notation in treble or bass clef (e.g., folk songs, patriotic songs). 3. Sing with an acceptable tone quality throughout his/her singing ranges or play an instrument with an acceptable tone quality throughout an appropriate range. 4. Compose music using a variety of sound sources, including electronic and computer. 5. Respond physically or using classroom instruments to basic rhythm patterns (including triplets, dotted rhythms, syncopation). 6. Perform and create melodies and accompaniments in solo or group ensembles through singing and playing instruments (e.g. four-chord songs on autoharp). 7. Sing or play musical compositions demonstrating knowledge of tonal and rhythmic elements (including syncopated patterns, beats and offbeats). 8. Use a system for counting beat and rhythm patterns (rhythm syllables and body movement) to demonstrate knowledge of rhythms found in musical compositions. 9. Identify uses of music in everyday life (film, television, background music, and commercials). 10. Recognize and identify the appropriate ways to use the following elements of musical style: a. Dynamics - (piano, forte). b. Tempo - (Allegro, Lento, Andante, Moderato). c. Conducting patterns of simple meters (2/4, 3/4, 4/4, 6/8). d. Articulation (staccato, legato, accent). Standard 4: Music Appreciation - The student will learn to appreciate music and extend their listening beyond music currently familiar to the student. 1. Recognize and practice appropriate audience or performer behavior appropriate for the context and style of music performed. 2. Demonstrate respect for music performed by the student and by other students and professional performers. 3. Use appropriate terms to explain preferences for musical works and styles. 4. Identify criteria for evaluating a musical composition or a musical performance. NOTE: Book icons () identify Information Literacy skills. Students are best served when these are taught in collaboration and cooperation between the classroom teacher and the library media specialist. WORLD LANGUAGES OAC 210:15-3-135 OVERVIEW OF ESSENTIAL SKILLS AND KNOWLEDGE Grade 6 is the third year of a required sequential language program in Oklahoma schools through which all students begin to develop skill in a language other than English. At the end of the Grade 4-8 program sequence, students should demonstrate skill at the novice level. They will be able to understand and produce memorized phrases, but they will be limited to familiar topics practiced in the classroom. Much more study will be needed to gain fluency. Students who began study at an earlier level or who have been in an immersion setting will demonstrate higher levels of skill if that study is uninterrupted. As stated in the profession's national goals, communication is at the heart of second language study, whether the communication takes place face-to-face, in writing, or across centuries through reading of literature. Through the study of other languages, students gain a knowledge and understanding of the cultures that use that language; in fact, students cannot truly master the language until they have also mastered the cultural contexts in which the language occurs. Learning languages provides connections to additional bodies of knowledge that are unavailable to monolingual English speakers. Through comparisons and contrasts with the language studied, students develop greater insight into their own language and culture and realize that multiple ways of viewing the world exist. Together, these elements enable the student of languages to participate in multilingual communities at home and around the world in a variety of contexts and in culturally appropriate ways. As is apparent, none of these goals can be separated from the other (National Standards in Foreign Language Education Project, 2006, p. 31). Please note that Priority Academic Student Skills (PASS) are organized around these five goals: communication, culture, connections, comparisons , and 32 communities. Novice Level Range Grades 4-12 Goal 1: Communication Communicate in Languages Other Than English Communication occurring in the Novice Level Range often includes some combination of the following topics: the self: family, friends, home, rooms, health, school, schedules, leisure activities, likes and dislikes, shopping, clothes, prices, size and quantity, and pets and animals * beyond self: geography, directions, buildings and monuments, weather and seasons, cultural and historical figures, places and events, calendar, time, food and customs, transportation, travel, professions, and work Novice Level learners are typically in Levels I-II (see descriptions in the Overview). Standard 1.1: Interpretive Communication - Listening/Reading/Viewing Students will understand and interpret written and spoken language on a variety of topics. Progress Indicators: What will Novice Level learners be able to do in the target language? By the end of the Novice Level, students will be able to handle the following language tasks in a consistent, comfortable, and spontaneous manner. When listening, reading, and viewing, learners in the Novice Level Range will: 1. Comprehend simple daily communications on familiar topics, including simple instructions such as classroom procedures. 2. Understand key words in written material such as advertisements, schedules, and menus. 3. Comprehend the main idea of selected, age-appropriate authentic recordings and broadcasts and videos. 4. Comprehend the main idea of selected, short, authentic written materials that use familiar vocabulary and language structures. 5. Respond to simple commands, familiar vocabulary, and language structures. Performance Guidelines: What characterizes Novice Level learners' performance in listening, reading and viewing? Learners in the Novice Level Range: A. Understand short, simple conversations and narratives (live or recorded), within highly predictable and familiar contexts. B. Recognize highly predictable key words and phrases and familiar structures by using contextual clues with strong visual support. C. Rely on personal background experience to assist in comprehension. D. Rely on repetition for understanding. E. Determine meaning by recognition of cognates, prefixes, suffixes, and thematic vocabulary. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? Interpretive Tasks * Recognize key words on store fronts and identify the type of store or services provided (e.g., book store, bakery, video store). * Read and understand simple official forms (e.g., hotel registration, passport and visa applications). * Listen to your teacher tell you to place certain items in different parts of the classroom, and respond accordingly. * Listen to a patient explaining his/her symptoms of illness, including mention of various body parts, to a doctor and take simple notes listing what problems the patient is having. * Read advertisements from authentic magazines and list all of the cognates found in the ads. * Listen to authentic songs and write the main ideas expressed. * Listen to a conversation of two native speakers. Answer simple comprehension questions in English. * Listen to a simple story several times. Then draw what happened in the story. Standard 1.2: Interpersonal Communication - Speaking/Writing Students will engage in conversations and/or written correspondence in which they provide and obtain information, express feelings and emotions, and exchange opinions. By the end of the Novice Level, students will be able to handle the following language tasks in a consistent, comfortable, and spontaneous manner. Progress Indicators: What will Novice Level learners be able to do in the target language? When speaking and/or writing in person-to-person communication, learners in the Novice Level Range will: 1. Initiate greetings, introductions, and leave-taking. 2. Ask and answer basic questions based on self and familiar material such as family members, personal belongings, school and leisure activities, location of people and objects, time, and weather. 3. Express personal needs, preferences, and feelings. 4. Initiate simple commands. Performance Guidelines: What characterizes Novice Level learners' performance in person-toperson speaking and writing? Learners in the Novice Level Range: A. Use memorized phrases and short sentences when communicating. B. Use words and phrases primarily as lexical items without awareness of grammatical structure. 35 C. Comprehend and produce vocabulary that is related to everyday objects and actions on a limited number of familiar topics. D. Rely on visual aids, gestures and repetitions to enhance communication. E. Imitate modeled words and phrases using intonation and pronunciation similar to that of the model. Communicate with pauses, false starts, some recourse to their native language and make frequent errors when taking risks with the language. G. Are understood primarily by those very accustomed to interacting with language learners. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? Interpersonal Tasks * Make five statements about yourself to a partner who must then agree or disagree with your self-perception. Rank sports by preference and using highly practiced language, tell a friend why you like or * dislike certain sports, and ask him/her what sports he/she likes. * Ask/Answer questions with a partner about the age and names of family members. * Write an e-mail to a friend listing the items in your school backpack, and then ask what is in his/her backpack. Ask/answer questions with a friend about what you want to do this weekend, and at what * time you want to do this. * Introduce friends and family members to others. Standard 1.3: Presentational Communication - Speaking/Writing Students will present information, concepts, and ideas to an audience of listeners or readers on a variety of topics. Progress Indicators: What will Novice Level learners be able to do in the target language? 36 F. By the end of the Novice Level, students will be able to handle the following language tasks in a consistent, comfortable, and spontaneous manner. When presenting information by speaking or writing, learners in the Novice Level Range will: 1. Describe in written or spoken format basic information, such as self, family members and friends, events, interests, school activities, and personal belongings. 2. Give simple commands and make requests of another person or group. 3. Retell a simple story using familiar vocabulary and language structures. 4. Write personal journals and send brief messages to friends. 5. Dramatize student-created and/or authentic songs, short poems, skits or dialogues. Performance Guidelines: What characterizes Novice Level learners' performance in spoken and written presentations? Novice Level learners will: A. Use memorized, short phrases and sentences in oral and written presentations based on familiar material. B. Demonstrate some accuracy in pronunciation and intonation when presenting well-rehearsed material on familiar topics. C. Rely heavily on repetition, gestures, facial expressions and visual aids to communicate their message orally. D. Reproduce familiar material in written presentations. E. Communicate with pauses, false starts, some recourse to their native language, and make frequent errors when taking risks with the language and attempting to produce language beyond the memorized. F. Are understood primarily by those very accustomed to interacting with language learners. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? Presentational Tasks * Give short, simple directions to a person about how to get to the grocery store from your school parking lot. * Write a thank-you postcard to your grandmother/aunt/brother for a birthday gift that you received. * Prepare short messages in video or audio formats to be sent to your peers in the target culture on the things that you like to do. * Design a poster for a nutrition class showing foods that should and should not be eaten. Present it to the class in the target language. * Use a highly practiced vocabulary and visuals; retell a children's story to the class or group. Goal 2: Cultures Gain Knowledge and Understanding of Other Cultures Standard 2.1: Practices of Culture Students will demonstrate an understanding of the relationship between the practices and perspectives of the culture(s) studied. Progress Indicators: What are Novice Level learners able to do in the target language? Learners in the Novice Level Range will: 1. Imitate patterns of behavior such as greetings or gestures used in formal and informal settings in the target culture. 2. Identify some customs and traditions such as celebrations and holiday practices of the target culture. 3. Participate in cultural activities such as games, songs, and dances of the target culture. 38 4. Identify some viewpoints of the target culture, such as those relating to time, school, transportation, pastimes, and the roles of family members. 5. Recognize and explore the process of stereotyping other cultures. Performance Guidelines: What characterizes the Novice Level learners' performance in communicating about cultural practices in the target language? Learners at the Novice Level: A. Imitate the use of culturally appropriate vocabulary, idiomatic expressions, and nonverbal behaviors modeled by the teacher. B. Use memorized phrases and short sentences when communicating in spoken or written formats. C. Rely on visual aids, gestures, and repetition to enhance comprehensibility. D. Comprehend written and spoken language better when content has been previously presented in an oral and/or visual context. E. Understand a story line or event in written or oral contexts that reflect a cultural background similar to their own. F. Use the student's native language only when the investigation of cultural perspectives extends beyond the novice proficiency range. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Collaborate in creating a class book with illustrations and written descriptions of various aspects of daily life in the target cultures. * Write your key-pal with lists of personal interests (the contents of your backpack, the programs you watch on TV, or a list of your school holidays) and ask your key-pal to respond with lists of personal interests. * Identify and illustrate or perform a traditional custom or celebration. * Initiate and respond to formal and informal telephone calls. 39 Standard 2.2: Products of Culture Students will demonstrate an understanding of the relationship between the products and perspectives of the culture(s) studied. Progress Indicators: What are Novice Level learners able to do in the target language? 1. Identify objects, images and symbols, such as flags, currency, food, dress, and toys, that are commonly used in the target culture. 2. Identify some major contributions and historical figures from the target culture, including contributions in science, mathematics, government, and fine arts. 3. Identify some historical and contemporary influences from the target culture that are significant in the U.S. culture, such as explorers and settlers, music and sports. 4. Identify countries, regions, and geographic features where the target language is spoken. 5. Extract samples of the culture's perspectives from popular media in the target culture. Performance Guidelines: What characterizes the Novice Level learners' performance in communicating about cultural products in the target language? Learners at the Novice Level Range will: A. Use memorized phrases and short sentences when communicating in spoken or written formats about cultural products. B. Rely on visual aids, gestures, and repetition to enhance comprehensibility about cultural products. C. Comprehend written and spoken language about cultural products better when content has been previously presented in an oral and/or visual context. D. Understand a story line or event in written or oral contexts that reflects a cultural background similar to their own. E. Use the student's native language only when the investigation of cultural perspectives extends beyond the novice proficiency range. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Recite a poem/sing a song of the target language. * Demonstrate understanding of a story, folk tale, or legend by answering questions or retelling the story with or without visuals. * Listen to the teacher's description of the physical attributes and/or contributions of a famous person of the target culture and identify who it is. Goal 3: Connections Connect with Other Disciplines and Acquire Information Standard 3.1: Interdisciplinary Studies Students will reinforce and further their knowledge of other content areas through the Progress Indicators: What will Novice Level learners be able to do in the target language? foreign language. 1. Identify and/or use selected information and skills from other content areas (such as the arts, health, social studies, sciences, mathematics, and English) in the target language classroom. 2. Using authentic target language resources, (such as the Internet, books, magazines), identify and/or use selected information to reinforce or expand learning in other content-area classrooms (such as the arts, health, social studies, sciences, mathematics, English). Performance Guidelines: What characterizes the performance of Novice Level learners? Learners in the Novice Level Range will: A. Use memorized phrases and short sentences when communicating about selected content areas. B. Rely on visual aids, gestures and repetitions to enhance communication about other content areas. Understand short, simple conversations and narratives about other content areas (live or recorded), within highly predictable and familiar contexts. 41 C. D. Recognize highly predictable key words and phrases and familiar structures by using contextual clues with strong visual support. E. Rely on personal background experience to assist in comprehension. F. Rely on repetition for understanding. G. Determine meaning by recognition of cognates, prefixes, suffixes and thematic vocabulary. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Use currency of the target culture to make change using bills and coins. * Prepare a healthy menu using typical foods of the target culture. * Use authentic instruments of the target culture to explore music and rhythms. * Learn the solar system, parts of a plant, life cycle of a butterfly. Standard 3.2: Distinctive Viewpoints Students will acquire information and recognize the distinctive viewpoints that are only available through the foreign language and its cultures. Progress Indicators: What will Novice Level learners be able to do in the target language? Learners in the Novice Level Range will: 1. Extract information about the target culture from selected authentic sources (such as the Internet, books, magazines). 2. Use authentic target language sources to gain insight about the distinctive perspectives of the target culture. Performance Guidelines: What characterizes the performance of Novice Level learners? Learners in the Novice Level Range will: A. Understand general oral and written information when enhanced by illustrations within highly predictable contexts. B. Increase their comprehension by looking for and recognizing key words or phrases. C. Rely on personal background information to help in understanding something they read or hear. D. Rely on memorized phrases and short sentences to describe distinctive viewpoints of the target culture. E. Use the student's native language only when the discussion of distinctive viewpoints extends beyond the novice proficiency range. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * With several other students, act out familiar folktales, fables, or legends known to children of the target culture while another student reads the story aloud. * Use the target language to describe an animal or plant that is indigenous to a particular region or country of the target culture. * Use authentic sources to identify the current popular products of the target culture. Goal 4: Comparisons Develop Insight into the Nature of Language and Culture Standard 4.1: Language Comparisons Students demonstrate understanding of the nature of language through comparisons of the language studied with their own. Progress Indicators: What will Novice Level learners be able to do in the target language? Learners in the Novice Level Range will: 1. Recognize cognates and borrowed words and be aware of their usefulness in comprehending language. 2. Identify and compare the sound and writing systems of the target language with their own, including stress, intonation, punctuation. 43 3. Identify basic grammatical structures of the language studied and compare these structures to their own language, including word order, gender, agreement. 4. Recognize identified idiomatic expressions that cannot be directly translated into their own language. Performance Guidelines: What characterizes Novice Level learners' performance? Learners in the Novice Level Range will: A. Rely primarily on memorized phrases or short sentences when describing language structure comparisons between cultures. Rely heavily on visuals to get ideas across to the audience. Rely on personal background information to help in understanding similarities and B. C. differences of grammatical structures between the cultures. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Create a graphic organizer to compare language structures in English and the target language. * Discuss the variations in vocabulary in English (apartment/flat, elevator/lift) as well as the variations in vocabulary among target language countries. Listen as the teacher models how to express language structures (e.g., word order, number and gender agreement, question formation) in the target language and identify how it is different from English. Standard 4.2: Culture Comparisons Students demonstrate understanding of the concept of culture through comparisons of the cultures studied and their own. Progress Indicators: What will Novice Level learners be able to do in the target language? Learners in the Novice Level Range will: 1. Identify similarities and differences in verbal and nonverbal behavior between cultures. 2. Recognize cross-cultural similarities and differences in the practices of the culture studied. 3. Identify cross-cultural similarities and differences in the products of the culture studied. 44 * 4. Recognize cross-cultural similarities and differences in the perspectives within the target culture. Performance Guidelines: What characterizes Novice Level learners' performance? Learners in the Novice Level Range: A. Rely primarily on memorized phrases or short sentences when describing comparisons between cultures. B. Rely heavily on visuals to get ideas across to the audience. C. Rely on personal background information to help in understanding cultural similarities and differences between the culture studied and their own. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Follow the teacher's model to practice the table manners of the target culture and compare them with the student's own culture. * Identify the significance of signs and symbols in the target culture. * Make a Venn diagram comparing a celebration in the U.S. with the same or equivalent celebration in the target culture. * Compare the greetings, leave takings, and the use of personal space in the target culture and in the U.S. * Looking at pictures of restaurant scenes in the U.S. and the target country, compare similarities and differences of the scenes. Goal 5: Communities Participate in Multilingual Communities at Home and Around the World Standard 5.1: School and Community Students will use the language both within and beyond the school setting. Progress Indicators: What will Novice Level learners be able to do in the target language? Learners in the Novice Level Range will: 1. Identify professions/occupations which are enhanced by proficiency in another language. 2. Practice oral or written use of the foreign language with people outside the classrooms. 3. Communicate on a personal level with speakers of the language via short letters, e-mail, audio, and videotapes. Produce short skits, stories, poems, multimedia shows, and present their works at school 4. and/or in the community. Performance Guidelines: What characterizes Novice Level learners' performance? Learners in the Novice Level Range will: A. Use memorized phrases or short sentences with very familiar topics. B. Write simple tasks, such as short messages or notes. C. Be accurate in pronunciation when presenting well-rehearsed materials. D. Understand general information when enhanced by visuals or gestures. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Keep an in-class log or chart of personal encounters with the target language outside of the school. * Establish a pen-pal/key-pal correspondence with someone from the target culture. * Locate/visit stores within the community that cater to the target culture. * Listen to radio broadcasts and list recognizable words from the target culture. * Teach basic expressions and level-appropriate songs and games from the target culture to children in a neighboring elementary or preschool or at home to members of the family. Standard 5.2: Personal Enrichment Students will show evidence of becoming lifelong learners by using the language for personal enjoyment and enrichment. Progress Indicators: What will Novice Level learners be able to do in the target language? Learners in the Novice Level Range will: 1. Demonstrate a willingness to interact with native speakers. 2. Discover and explore a variety of entertainment sources representative of the target culture. 3. Identify current issues of interest within the target culture. 4. Discover and explore samples of art, literature, music, representative of the target culture. Performance Guidelines: What characterizes Novice Level learners' performance? Learners in the Novice Level Range will: A. Be understood primarily by those very accustomed to interacting with language learners. B. Exhibit increased comprehension when constructing meaning through recognition of key words or phrases embedded in familiar contexts. C. Rely heavily on visuals to enhance comprehensibility in both oral and written presentations. D. Use primarily memorized phrases and short sentences during highly predictable interactions on very familiar topics. Classroom Examples: What types of tasks are appropriate for the Novice Level Range classroom? * Use Web sites in the target language to make plans for a vacation in the target culture. * Select an audio clip of favorite music in the target language and share it with other members of the class. * Attend cultural events of the target culture within the community. * Visit art exhibits of artists from the target culture. * Learn a dance of the target culture and host a dance with music only from the target culture. NOTE: Book icons () identify Information Literacy skills. 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Rural Citizens Access to Telehealth EXPLORE TELEHEALTH FOR YOUR ORGANIZATION Providing equipment, education, & technical assistance to providers and Medicaid participants in rural Missouri counties. Funding opportunities are available for eligible partners. The Rural Citizens Access to Telehealth (RCAT) project is a partnership between the Missouri Telehealth Network and the Department of Social Services, MO HealthNet Division. Together, we will provide funding, education, and training opportunities to introduce or enhance existing telehealth services for rural providers accepting Medicaid patients. - Increase Access Reduce barriers to care such as time and distance - Better Outcomes Patients receive consistent, timely, appropriate care - Patient Recruitment and Retention** Increase patient volume while maintaining existing patients READY TO GET STARTED? Telemedicine services provide an opportunity for citizens living in rural areas with unique rural healthcare challenges to access services in the comfort of their home and/or community. - Are you serving primarily rural populations in Missouri? - Do you participate in MO HealthNet? - Are you looking to introduce or expand both Primary Care and Behavioral Health telehealth services? SCAN or CLICK to TAKE OUR SURVEY FOR MORE INFO! Questions? [email protected] Missouri Telehealth Network University of Missouri MoHealthNet	87761ad4-fe50-40d2-8f83-b34287b1eb58	CC-MAIN-2024-30	https://www.medicine.missouri.edu/sites/default/files/MTN/RCAT_flyer.pdf	2024-07-15T11:34:51+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-30/subset=warc/part-00113-65338ae2-db7f-48fa-a620-71777c40d854.c000.gz.parquet	771,494,166	270	eng_Latn	eng_Latn	0.980564	eng_Latn	0.980564	[ "eng_Latn" ]	true	docling	[ 1432 ]
Greetings from Vietnam - With gratitude, love and best wishes for a Happy New Year! Dear D.O.V.E. Fund members and donors! As we approach this festive season, I want to take a moment to extend my warmest wishes for a Merry Christmas and a joyful New Year to each of you. This year has been truly remarkable, as your dedication and unwavering generosity have led to the highest funding results in the history of the D.O.V.E. Fund. This extraordinary achievement is a testament to your commitment to uplifting impoverished children in Vietnam and transforming their lives in profound ways. Your compassion and tireless efforts have provided countless vulnerable children with essential resources, education, and support. In doing so, you have given them the tools for a brighter future and instilled in them a sense of dignity, hope, and possibility. On behalf of all the lives you have touched through your incredible humanitarian work, I extend my deepest gratitude. May your holiday season be filled with love, laughter, and cherished moments, and may the new year bring continued blessings to you and your loved ones. Thank you for making 2024 a truly historic year for the D.O.V.E. Fund and the communities we serve. Warm regards, Cam Nhung Bui Thi Cam Nhung (Ms) D.O.V.E Fund Project Coordinator Web: http://dovefund.org/ Dong Ha City, Quang Tri Province Thanks to all those who attended the annual Christmas dinner last month to benefit elementary school children in Vietnam. Pictured above is D.O.V.E. Fund Secretary and Web Master, Roland Southard, with wife Celeste at the Christmas celebration held at Stone Oak Country Club in Holland, Ohio Tet is the Vietnamese New Year, a nationwide celebration that marks the start of the lunar new year and the beginning of Festival falls on January 29th 2025. Tet is based on the lunar calendar and is generally celebrated on the same day as the Chinese New Year. The date changes annually but falls between mid-January and late February. Most Vietnamese people will have five days off for Tet. Tet celebrations can last three days or up to one week. The festival is split into the day before New Year's Eve, New Year's Eve, and New Year's Day. All of these days correspond to the Vietnamese or lunar calendar, so they occur on a different date every year. The Tet Tet is a time of renewal and family, and it’s considered a key part of Vietnamese cultural identity. It’s a time to celebrate a fresh start with loved ones and strengthen family ties. Tet celebrations include decorating homes, buying new clothes, visiting pagodas, making offerings to deceased family members, playing drums, bells, and gongs, and eating special foods. CHÚC MỪNG NĂM MỚI!! Happy New Year! In the Lunar New Year, 2025 is the Year of the Wood Snake 25th Anniversary Celebration in Vietnam On March 16, 2025, the members and guests traveling with the D.O.V.E Fund will be part of the organization’s 25th anniversary celebration in Ho Chi Minh City. Held on the campus of Ho Chi Minh Technical University, the event will feature a cocktail reception along with a pictorial and video review of the D.O.V.E. Fund’s 25 years in Vietnam. The event will also host guest speakers, scholarship presentations, and live music featuring “DOVE” songwriter and recording artist Dan May, who will perform a new song he wrote just for the celebration. If you’re in HCMC in mid-March, please join us! The D.O.V.E. Fund remains committed to providing academic assistance to students who demonstrate financial need, scholastic potential, initiative, and a solid work ethic. Our scholarship program enhances the academic lives of 180 high school students and 50 University students annually. Thirty of our scholarship recipients are students at the prestigious Ho Chi Minh University of Technology. Each year, when members of the D.O.V.E. Fund visit Vietnam to award scholarships, they witness the profound impact of our program on the lives of the students. These students, all struggling financially, share their stories of how the scholarship has made their education possible. For nearly 25 years, the D.O.V.E. Fund has assisted over 5,700 students, enabling them to continue their education and preparing them for a more hopeful future. Support a brighter future. Donate to a D.O.V.E. Scholar! For more than a decade, the D.O.V.E. Fund has supported the sisters of St. Paul de Chartres in Vietnam. In addition to managing the D.O.V.E. Fund scholarship program for students from leper families, the sisters also operate a school and orphanage near Pleiku. The sisters bring medical and humanitarian relief to leper families in the rural villages of the Central Highlands. A few years ago, the D.O.V.E. Fund partnered with the Bandage Brigade and the sisters to provide fresh, reusable dressings to bind the wounds of the lepers. Today, we provide food, blankets and clothing to ease the suffering of those banished to the remote villages of Vietnam. Tax Tip: Use your RMD to make a QCD to the D.O.V.E. Fund A qualified charitable distribution is an IRA withdrawal that is paid directly from your IRA to a qualifying charity. While income tax is normally due on each traditional IRA distribution, the account owner does not need to pay taxes on the amount transferred to charity. To learn more, check with your CPA or Financial Advisor. The D.O.V.E. Fund \| P.O. Box 350741 \| Toledo, OH 43635 US Unsubscribe \| Update Profile \| Constant Contact Data Notice	1ef9afe4-2194-4d94-a1ce-a80477594a6f	CC-MAIN-2025-08	https://dovefund.org/Newsletters/DOVE%20Diligence%20-%20PDF%20Format/2025/January%202025%20DOVE%20Diligence.pdf	2025-02-11T08:36:55+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2025-08/subset=warc/part-00214-b184e832-acd1-425a-bab7-895830f2748a.c000.gz.parquet	192,639,143	1,176	eng_Latn	eng_Latn	0.867077	eng_Latn	0.997067	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	true	docling	[ 83, 197, 1781, 3429, 5371, 5491 ]
Unifying Margin-Based Softmax Losses in Face Recognition Yang Zhang, Simao Herdade, Kapil Thadani, Eric Dodds, Jack Culpepper, and Yueh-Ning Ku Yahoo Research Abstract In this work, we develop a theoretical and experimental framework to study the effect of margin penalties on angular softmax losses, which have led to state-of-the-art performance in face recognition. We also introduce a new multiplicative margin which performs comparably to previously proposed additive margins when the model is trained to convergence. A regime of the margin parameters can lead to degenerate minima, but these can be reliably avoided through the use of two regularization techniques that we propose. Our theory predicts the minimal angular distance between sample embeddings and the correct and wrong class prototype vectors learned during training, and it suggests a new method to identify optimal margin parameters without expensive tuning. Finally, we conduct a thorough ablation study of the margin parameters in our proposed framework, and we characterize the sensitivity of generalization to each parameter both theoretically and through experiments on standard face recognition benchmarks. 1. Introduction Deep learning models trained with margin softmax losses achieve state-of-the-art performance on standard metric learning benchmarks such as face verification and identification [8, 10, 15, 27, 3, 31] and fine-grained classification [20]. However, the existing literature fails to explain why different proposed margin penalties result in better generalization. Claims have been made that reducing intra-class distance helps generalization [27], or that enforcing class separation in angle space is more effective than in cosine space [3], but such claims have not been proven or empirically verified. Furthermore, works reporting competitive performance use different model architectures, training schedules, learning rate schedules, batch sizes, and/or data augmentation paradigms, as well as different test time augmentation strategies and test set preprocessing. These differences obscure the effects of the primary contributions of these works on the quality of their models as measured by benchmark performance. Indeed it has been shown that the improvement of new metric learning loss functions over previous work is often smaller than stated when holding fixed these confounding factors [20]. This work serves as a first attempt to characterize how different margin penalties affect the training optimization as well as the resulting model generalization. Through a comprehensive fair comparison on face recognition benchmarks, we demonstrate that all primary margin parameters on the softmax loss—including CosFace [27], ArcFace [3] and a natural new multiplicative margin which has not been studied before—are fundamentally alike, though they differ in optimization difficulty. We argue that prevailing explanations for margin effectiveness are insufficient and develop a new theoretical framework to better understand the mechanisms underlying the success of margin softmax losses. Specific contributions of our work include: • A mathematical model of prototypes and samples that enables us to study training dynamics and optimization stopping points as a function of margin values. This allows us to approximate the influence of margin settings on intra-class and inter-class distances. • A formal characterization of a collapse mode that occurs in some margin parameter regimes. We propose two effective regularization techniques to avoid these degenerate minima without harming performance. • A natural new margin parameter to complete the family of margin-based softmax losses. Our experiments show that all margin formulations yield similar performance when models are trained to convergence. • A new observation that optimal values for different margins produce loss functions that appear to coincide at a specific angle which can be analytically derived for any dataset. This leads to a conjecture on how to select optimal margin parameters without computationally expensive tuning experiments. 2. Related Work Face recognition, one of the oldest problems in computer vision, has matured significantly with the advent of large databases and deep feature learning. Facenet [22], an early example of the leverage gained with these tactics, utilizes a metric learning approach based on pairs of similar and dissimilar images. Since the emergence of equivalences between pairwise and proxy-based metric learning [19, 24], advancements in face verification have mainly utilized multi-class classification losses for training [21, 26, 15, 34, 27, 3, 12, 31, 10, 8, 6, 1] which have higher memory requirements but are less reliant upon complex and computationally expensive hard (negative) example mining. Proxy-based metric learning has converged on the use of a modified softmax loss where each logit is the cosine of the angle between a feature vector and a weight matrix column. A global scaling factor characterizing the “temperature” or sparseness of the softmax then multiplies the cosine as a fixed hyperparameter optimized by cross-validation or as a learnable model parameter [26, 31]. Introducing margin parameters which multiply the angle [15], add to the angle [3], or add to the cosine of the angle [27] have been shown to improve generalization, and to simultaneously reduce intra-class angles and increase inter-class angles. Gains are observed when heavy-tailed class distributions in the training data are addressed by per-class margins with larger margins when classes have fewer training examples [12]. To model variability in sample difficulty, margins can be formulated as a function of the magnitude of the feature vector [17]. While some attention has been paid to their individual effects, we are not aware of a comprehensive analysis of the ways these modifications to the softmax loss affect training. Several studies have characterized the effect of normalization in the modified softmax loss. D-Softmax [6] identifies the entanglement of the intra-class and inter-class optimizations and proposes a new loss to optimize intra-class variation and inter-class distance separately. CircleLoss [24] reveals the sub-optimal magnitude of the gradients throughout the training and proposes a second order margin to correct that. Similarly, we study the intra- and inter-class optimization process both theoretically and empirically in this work. 3. Margins on the Hypersphere 3.1. Unified Angular Margin Softmax Losses A standard metric learning approach to face recognition is to learn an embedding function such that the embedding $x_i \in \mathbb{R}^d$ of an example input $i$ (i.e., a face image) is closer to other examples of the same class (identity) than to examples from other classes, without knowing about the classes in advance. Following prior work, we learn this function by optimizing a modified classification objective on a training set with $C$ known classes represented by a learnable matrix $W \in \mathbb{R}^{d \times C}$ where we refer to each column $W_j$ as the “prototype” of class $j$. Taking the dot product as our measure of similarity, the softmax cross-entropy loss for $N$ examples can be written as an average of per-example losses $L_1 \ldots L_N$ such that $$L_i = -\log \frac{e^{W_i^\top x_i}}{\sum_{j=1}^{C} e^{W_j^\top x_i}}$$ \hspace{1cm} (1) where $y_i$ is the class of the $i$th example. For any given example $i$, we also have $W_i^\top x_i = \|\|W_j\|\| \|\|x_i\|\| \cos \theta_j$, where $\theta_j$ is the angle between column $W_j$ and feature vector $x_i$. By normalizing $W_j$ and $x_i$ to unit vectors and incorporating a global scaling parameter $s$ for all logits [15, 26], the loss in equation (1) becomes $$L_i = -\log \frac{e^{s \cos \theta_{y_i}}}{\sum_{j=1}^{C} e^{s \cos \theta_j}}$$ \hspace{1cm} (2) where $0 \leq \theta_j \leq \pi$ for all angles $\theta_j$. Prior work introduced margin parameters in the correct-class exponent which are multiplied with the angle [15], added to the angle [3] or to its cosine [27]. Following [3], incorporating these margins can be summarized as replacing $\cos \theta_{y_i}$ in the angular softmax loss (2) by $z_{y_i} = \cos(m_1 \theta_{y_i} + m_2) - m_3$ so that the loss becomes $$L_i = -\log \frac{e^{s z_{y_i}}}{e^{s z_{y_i}} + \sum_{j \neq y_i} \rho_{y_j} e^{s z_j}}$$ $$= \log \left( 1 + \frac{\sum_{j \neq y_i} \rho_{y_j} e^{s z_j}}{e^{s z_{y_i}}} \right)$$ \hspace{1cm} (3) where the wrong-class exponents $z_j = \cos(\theta_j)$ do not have the margins. Each margin can be used during training to encourage smaller correct-class angles than the ordinary softmax loss. The margins are typically fixed hyperparameters but can also be learned [12]. Previously introduced margins $m_1, m_2, m_3$ modulate respectively the period, phase, and vertical shift of the function $\cos(\theta_{y_i})$. We complete the framework of angular margins with a novel margin parameter $m_0$ that modulates the amplitude of $\cos(\theta_{y_i})$ by redefining $z_{y_i}$ as $$z_{y_i} = m_0 \cos(m_1 \theta_{y_i} + m_2) - m_3,$$ \hspace{1cm} (4) and use the name AmpFace for the family of models defined by equation (4) with $0 < m_0 < 1$. Note that the effect of this margin parameter cannot be subsumed by the scale parameter $s$ in the softmax loss as $m_0$ affects only the positive logit while $s$ appears in all terms, scaling positive and negative logits alike. These four margin hyperparameters, together with the scale parameter $s$, play important roles in generalization for metric learning models. We study each margin penalty independently by analyzing its impact on the training dynamics. 3.2. Polar Collapse Using the margin parameters described above can create an undesirable minimum of the loss function, which we call the polar collapse mode, since the model may collapse towards this degenerate configuration rather than learning a useful representation. Fig. 1a illustrates the polar collapse configuration in $d = 3$. Blue curves in Fig. 1b log typical training dynamics for $m_0 = 0.35$. After around 100k optimization steps (upper subplot, blue trace), the mean correct-class angle $\theta_i$ increases rapidly towards $\pi$. Polar collapse drives the norm of the average prototype $\frac{1}{C} \sum_j W_j$ towards 1, indicating that the prototypes are converging towards a single point (lower subplot). In the limit of total collapse, all angles equal $\pi$ i.e. $\theta_{yi} = \theta_j = \pi$, and the per-example loss (3) reduces to: $$L_i^{\text{collapse}} = \log \left( 1 + \frac{C - 1}{e^{s(z' + 1)}} \right)$$ where $z' = m_0 \cos(m_1 \pi + m_2) - m_3$. With no margins applied ($m_0 = m_1 = 1$ and $m_2 = m_3 = 0$), we have $z' = -1$ and so $L_i = \log C$, which is an appropriately large loss for an undesirable model. However, using aggressive margins can result in $e^{s(z' + 1)} \gg C - 1$, which would decrease $L_i$ to zero. In geometric terms, the optimizer could simply minimize the training loss by collapsing all feature vectors $x_i$ to a single point and all prototypes $W_j$ to the opposite pole on the $d$-dimensional hypersphere. Figure 2 shows how the loss $L_i$ varies with a constant distance to all prototypes and with each margin parameter while keeping the other margins fixed; angles and margin settings that bring this loss to near-zero are in danger of inducing the collapse mode. In practice, polar collapse is regularly observed for multiplicative margins, e.g., SphereFace with $m_1 \geq 1.8$ or AmpFace with $m_0 \leq 0.65$. Note that this collapse mode is different from the triplet loss collapse observed in [22], in that the triplet loss always has a bad local minimum where all feature vectors collapse, and this problem can be mitigated by optimization and sampling strategies. In contrast, the margin softmax polar collapse described here may be a local or global minimum of the loss, so reliably avoiding it requires modifications to the loss function. We propose two strategies to avoid this polar collapse during model training: 1. Spherical Symmetry Regularization (Reg$_{\text{ss}}$) Add a regularization term to the total loss with weight $\lambda$ that encourages prototypes $W_j$ to be symmetrically distributed on the hypersphere manifold by minimizing the L2-norm of the mean normalized prototype. $$\text{Reg}_{\text{ss}} = \left\\| \frac{1}{C} \sum_j \frac{W_j}{\\|W_j\\|_2} \right\\|_2$$ 2. Wrong-class Logit Rectification (WC-ReLU) Rectify the values of $z_j$ in equation (3) using a ReLU activation, denoted by $[\cdot]_+$, $$L_i = \log \left( 1 + \frac{\sum_{j \neq y_i} e^{s[z_j]_+}}{e^{sz_{y_i}}} \right)$$ When $d_j > \frac{\pi}{2}$, the gradient $\partial L_i / \partial d_j$ becomes 0 to avoid driving $x_i$ and $W_j$ to opposite poles. Figure 2 shows that no margin setting results in zero loss for examples which are $\frac{\pi}{2}$ away from prototypes. To our knowledge, this is the first consideration in the literature of this common failure mode for softmax losses with margin penalties. The ad-hoc easy-margin trick from the original implementation of ArcFace [3] does not extend to multiplicative margins because removing a fractional multiplicative factor on the correct-class logit (when the corresponding cosine is negative) makes its value smaller and the correct classification harder. Reg$_{\text{ss}}$ has been studied previously in the context of generalization through hyperspherical uniformity [13]. UniformFace [4] was not originally proposed as a regularization method but shares the same high-level intuition as Reg$_{\text{ss}}$. Both encourage the symmetric distribution of prototypes $W_j$, although the calculation of Reg$_{\text{ss}}$ is simpler and more efficient. We empirically compare our two proposed strategies with UniformFace in Section 4.4 and show that either Reg$_{\text{ss}}$ or WC-ReLU allows a significantly larger hyperparameter search space where regular training would normally fail due to polar collapse. 3.3. The Hypersphere Manifold In this section, we make theoretical predictions for the average smallest wrong-class angle $M_{\text{wrong}} = \mathbb{E}_i[\min_j \theta_{ij}]$ and the average correct-class angle $M_{\text{correct}} = \mathbb{E}_i\theta_{yi}$ for an example $i$ using properties of high-dimensional spaces. In Appendix A, we provide numerical simulations for our experimental setting that verify these expressions obtained in the limit of large $C$ and $d$. The class prototypes $W_j$ represent points on the hypersphere of dimension $d - 1$. Since we initialize the entries of $W$ to i.i.d. samples from a normal distribution (before normalizing), the initial prototypes are approximately uniformly distributed on the surface of the hypersphere after normalization. We theoretically model optimization and generalization as a function of the different margin parameters, under the assumption of a spherical uniform distribution of the prototypes throughout training. Our assumption of prototypes distributed uniformly on the hypersphere predicts an approximate value for the angle from a prototype to the nearest prototype for large $d$ [2, 3]. Proposition 1 Let $W_i \in \mathbb{R}^d$ for $i = 1, \ldots, C$ be i.i.d. from the uniform distribution on the unit sphere. Then the expected angle from a vector $W_i$ to its nearest neighbor, $\theta_{\min}(W_i) = \min_{j \neq y_i} \arccos(W_i^\top W_j)$, converges to $$\mathbb{E}[\theta_{\min}(W_i)] \xrightarrow{C \to \infty} C^{-\frac{2}{d-1}} \Gamma\left(\frac{d}{d-1}\right) \left(2\sqrt{\pi(d-1)\Gamma\left(\frac{d+1}{2}\right)}\right)^{-\frac{d-1}{d-1}}$$ For large $d$ and $C$, this expression also approximates the angle between a random vector (which need not be a prototype) and the nearest prototype. If we assume each feature vector has either a random direction (as is likely at initialization) or is only much closer to the correct prototype, equation (8) gives an estimate of $M_{\text{wrong}}$. To predict the average correct-class distance $M_{\text{correct}}$, we note that the gradient of the margin softmax loss for an example with respect to the correct prototype nearly vanishes at a certain angle value. This value is dependent on the margins and the expected wrong-class angles, as discussed in [6] and examined in Section 3.4. While correct-class distances could be smaller than this angle value after optimization, they will with high probability lie very close to the value due to the concentration-of-measure phenomenon in high-dimensional hyperspheres. Proposition 2 Fix $0 < \epsilon \ll 1$ and define $\tau_\epsilon = \max\{0 < \theta < \pi/2 : \frac{\partial L}{\partial W_{yi}} < \epsilon\}$ as the angle for which optimization gradients w.r.t. the positive prototype “vanish.” Then $$M_{\text{correct}} \approx \mathbb{E}_{x_i \in \text{cap}(W_i, \tau_\epsilon)}[\theta_{yi}] \xrightarrow{d \to \infty} \tau_\epsilon$$ where $\text{cap}(W_i, \tau_\epsilon)$ denotes the spherical cap centered on prototype $W_i$ with radius subtended at the origin by $\tau_\epsilon$. In the following section, we analyse the effect of different margins on the loss curves and attend to the angle values for which the corresponding gradients vanish. To do so we make use of the following estimate of the sum of wrong-class logits in the denominator of the softmax loss. Proposition 3 Assume the prototypes $W_j$ are uniformly distributed on the hypersphere, and denote by $z_j = W_j^\top x_i = \cos(\theta_{ij})$, $\forall j \neq y_i$, the wrong-class logits for the $i$th example. Then for sufficiently large $C$ and $d$ ($e^{s^2/d}/C \ll 1$) $$\sum_{j \neq y_i} e^{sz_j} \approx (C - 1) * e^{s^2/(2d)}$$ For large dimension $d$, the inner product between a fixed unit vector $x_i$ and a random unit vector is approximately a sample from $\mathcal{N}(0, 1/\sqrt{d})$. Thus $e^{sz_j}$ is approximately log-normally distributed with mean $e^{s^2/(2d)}$. By the law of large numbers, assuming $C$ sufficiently large, the sum converges to the expectation and we have $$\sum_{j \neq y_i} e^{sz_j} \to (C - 1) * \mathbb{E}[e^{sz_j}] \approx (C - 1)e^{s^2/(2d)}$$ See Appendix A for a proof of the approximation. 3.4. Gradients and Training Dynamics The gradient of the per-example loss from equation (3) $ L_i = -\log P(y_i \| x_i) $ with respect to the distance $ \theta_{y_i} $ to the correct class is \[ \frac{\partial L_i}{\partial \theta_{y_i}} = -(1 - P(y_i \| x_i)) \cdot s \cdot \frac{\partial z_{y_i}}{\partial \theta_{y_i}} \] \[ = (1 - P(y_i \| x_i)) \cdot s \cdot m_0 \cdot m_1 \cdot \sin(m_1 \theta_{y_i} + m_2) \] (12) Using the approximation of wrong-class logits from equation (10), Figure 3 illustrates the gradient $ \partial L_i / \partial \theta_{y_i} $ as a function of $ \theta_{y_i} $ and shows how it varies as each margin parameter is adjusted individually. The magnitude of $ \partial L_i / \partial \theta_{y_i} $ for some $ \theta_{y_i} $ depends on $ 1 - P(y_i \| x_i) $ regardless of the margin, but also has a factor that grows linearly with the introduced margin $ m_0 $, approximately quadratically with $ m_1 $ as $ m_1 \theta_{y_i} / 2 \leq \sin(m_1 \theta_{y_i}) \leq m_1 \theta_{y_i} $ when $ m_1 \theta_{y_i} \in [0, \frac{\pi}{2}] $, and non-linearly with $ m_2 $. The dependence of the gradient magnitude on the margin implies that models with different margins will converge at different rates when training hyperparameters are held fixed. Therefore, there are two fair training schedules for comparing models. The first is long enough to make sure models are close to convergence and will likely produce the best performance but may be expensive or time consuming. The second is a shorter schedule with a limited computation budget. Inspired by [26, 6], we are interested in when $ \partial L_i / \partial \theta_{y_i} $ becomes zero as $ \theta_{y_i} $ decreases during training as this is the termination point for intra-class optimization. This angle is also our theoretical estimate of the average correct-class distance $ M_{\text{correct}} $, defining the edge of the spherical cap around prototypes $ W_{y_i} $, where examples $ x_i $ accumulate as shown by Proposition 2. Figure 3 shows that this angle decreases linearly with $ m_2 $ and non-linearly with the other margins. In Section 4.3., we compare these estimates $ M_{\text{correct}} $ with empirical correct-class angles under varying margins. 4. Experiments 4.1. Implementation Details The architecture of our feature embedding network is identical to the ArcFace [3] network: it is their ResNet-100 [5] backbone acting on input images of resolution 112x112, and outputting a feature vector of dimension 512. Training The feature embedding network is trained on a cleaned version of the MS-Celeb-1M (C-MS1M) as provided by the authors of [3]. This database contains 5,822,653 images of 85,742 identities, and each image has already been aligned and cropped to $ 112 \times 112 $ following standard procedures [3, 27, 15]. We train our model from random initialization with 8 NVIDIA V100 GPUs using synchronous stochastic gradient descent (SGD) and momentum 0.9. We use batch size 512 and weight decay $ 5e^{-4} $. Our training schedule starts the learning rate at 0.1 and runs 100K steps, then runs 60K steps at 0.01, and then finally runs 20K steps at 0.001 – 180K steps in total. Testing We evaluate on the following benchmarks: - LFW [7] which contains 13,233 images of 5,749 individuals. We follow the ‘unrestricted, with labelled outside data’ protocol, and evaluate our model with the dataset as is, without mislabel correction. - CFP-FP [23] which contains 10 frontal images and 4 profiles images of 500 identities. - AgeDB-30 [18] which is composed of 16,488 images of 568 unique subjects. - CALFW [33] and CPLFW [32], reconstructed from LFW with additional age and pose variations. - YTF [29] which contains 3,425 videos from 1,595 identities. We calculate the mean of embedding features from all frames of videos then evaluate pairs by their feature centre. $^1$All datasets are publicly available and are only used to benchmark our models for a fair comparison with prior work in the literature. Our work is conducted for non-commercial research purposes only. \| Method \| Verification Results \| IJB \| MegaFace \| \|------------------------\|----------------------\|--------------\|----------\| \| \| LFW \| CALFW \| CPLFW \| AgeDB \| CFR.FP \| YTF \| IJB-B \| IJB-C \| Id \| Ver \| \| GroupFace [10] \| 99.85 \| 96.20 \| 93.17 \| 98.28 \| 98.63 \| 97.8 \| 94.93 \| 96.26 \| 98.74 \| 98.79 \| \| CurricularFace [8] \| 99.80 \| 96.20 \| 93.13 \| 98.32 \| 98.37 \| \| 94.8 \| 96.1 \| 98.71 \| 98.64 \| \| AmpFace ($m_0 = 0.375$) \| 99.76 ±0.02 \| 95.53 ±0.06 \| 90.93 ±0.20 \| 97.82 ±0.17 \| 97.72 ±0.20 \| 97.71 ±0.23 \| 93.02 ±0.49 \| 94.54 ±0.47 \| 97.93 ±0.06 \| 98.06 ±0.07 \| \| SphereFace ($m_1 = 1.35$) \| 99.74 ±0.05 \| 95.49 ±0.05 \| 90.72 ±0.14 \| 97.68 ±0.10 \| 98.19 ±0.08 \| 97.83 ±0.12 \| 92.25 ±0.12 \| 94.14 ±0.09 \| 96.51 ±0.09 \| 96.89 ±0.13 \| \| ArcFace ($m_2 = 0.5$) \| 99.80 ±0.02 \| 95.75 ±0.04 \| 91.42 ±0.27 \| 98.09 ±0.04 \| 98.45 ±0.16 \| 97.88 ±0.06 \| 94.10 ±0.07 \| 95.63 ±0.04 \| 98.38 ±0.13 \| 98.53 ±0.15 \| \| CosFace ($m_3 = 0.35$) \| 99.79 ±0.01 \| 95.75 ±0.01 \| 91.60 ±0.09 \| 98.06 ±0.01 \| 98.31 ±0.13 \| 97.85 ±0.06 \| 94.22 ±0.28 \| 95.75 ±0.28 \| 98.16 ±0.08 \| 98.39 ±0.06 \| \| AmpFace ($m_0 = 0.375$) * \| 99.77 ±0.05 \| 95.70 ±0.05 \| 92.00 ±0.28 \| 98.08 ±0.14 \| 98.40 ±0.06 \| 97.86 ±0.17 \| 94.44 ±0.23 \| 95.91 ±0.11 \| 98.83 ±0.06 \| 98.93 ±0.05 \| \| ArcFace ($m_2 = 0.5$) * \| 99.82 ±0.01 \| 95.82 ±0.04 \| 92.05 ±0.11 \| 98.21 ±0.14 \| 98.40 ±0.06 \| 97.88 ±0.11 \| 94.91 ±0.08 \| 96.18 ±0.02 \| 98.80 ±0.07 \| 98.98 ±0.04 \| \| CosFace ($m_3 = 0.5$) * \| 99.76 ±0.05 \| 95.72 ±0.06 \| 92.07 ±0.11 \| 98.19 ±0.16 \| 98.52 ±0.16 \| 97.85 ±0.14 \| 94.51 ±0.11 \| 95.93 ±0.11 \| 98.91 ±0.06 \| 99.02 ±0.04 \| Table 1: Common face identification and verification benchmark results in %. For IJB, TAR@FAR=1e-4 is reported. For MegaFace, “Id” refers to the rank-1 identification accuracy against 1M distractors and “Ver” refers to the face verification task where TAR@FPR=1e-6 is reported. For a fair comparison, the first group contains only recent models trained on the cleaned version of MS-Celeb-1M [3]. The second and third groups contain averaged results over three identical runs. All runs follow the protocol described in Section 4.1 with 180K steps and a batch size of 512, except runs indicated with * which are trained to convergence using 300K steps and a batch size of 1536. AmpFace models are trained with Reg$_\alpha$. • MegaFace [9] which includes 1,027,060 images of 690,572 unique identities. • IJB-B [28] which contains 1,845 subjects with 21,798 images, and 55,025 frames from 7,011 videos. • IJB-C [16] which includes 31,334 images and 11,779 videos of 3,531 subjects, with more occlusion and diversity of subjects from IJB-B. ### 4.2. Model Baselines Even though recent literature aims for a fair comparison with other work, we were unable to find consistently-reported baselines. For example, on the Refined MegaFace Identification task (R-MegaFace-Id) [3]: ArcFace [3] reports 98.35% with a model trained on CASIA-WebFace [30]. CosFace [27] makes use of a private dataset and reported 82.72% without removing the noise. GroupFace [10] reports 98.74%, despite the network architecture being significantly different; they use pre-training, a batch size of 1024 and a different learning rate schedule. CurricularFace [8] employs a training schedule of 24 epochs, which is equivalent to 270K steps when the batch size is 512, and reports 98.71%. CircleLoss [24] reports 98.50% where tail identities from C-MS1M are excluded. With the goal of establishing more consistent baselines, we carefully evaluate SphereFace, CosFace and ArcFace in Table 1 under the same training configuration as described in Section 4.1 (bs=512, 180K steps). We include models trained with the new multiplicative margin $m_0 < 1$ proposed in Section 3.1, which we name AmpFace. As pointed out in Section 3.4, the margin parameters affect the magnitude of $\partial L_i / \partial \theta_{y_i}$ and hence some adjustment to the training hyperparameters may be needed for the model to fully converge. For comparison purposes, we also train models with an increased batch size (1536) and number of steps (300K) in each leg of the training schedule, in order to get closer to convergence; these models achieve better performance. In group three of Table 1, AmpFace has identical performance to previous state-of-the-art margins ArcFace and CosFace. And all three have comparable performance to recent state-of-the-art models in group one. ### 4.3. Margin Comparison We strive to clearly understand how different margins affect the corresponding trained model optimization and generalization. In Fig. 4, we display final trained model performance on R-MegaFace-Id (bottom row) for AmpFace, SphereFace, ArcFace, and CosFace under a range of margin values. Following a few recent works [31, 6, 24] we also measure (top row) the corresponding empirical intra- and inter-class angular distances averaging at batch level by: - $M_{\text{intra}} = \frac{1}{N} \sum_{i=1}^{N} \theta_{y_i}$ - $M_{\text{inter}} = \frac{1}{N} \sum_{i=1}^{N} \min_{j \neq y_i} \theta_j$ Lastly we compare these with their theoretical counterparts derived in Section 3.3 (middle row) under the assumption of spherically equidistributed prototypes. Comparing these predicted angle distances with the empirical values of $M_{\text{intra}}$ and $M_{\text{inter}}$, we can observe that: 1. Inter-class distances do not seem to depend strongly on the value of the margin hyperparameters. 2. The test set inter-class distances are lower than corresponding training set inter-class distances, as predicted by the greater size of the test set and Proposition 1. 3. The slopes of our theoretical intra-class angle curves reflect approximately the empirical results where the predictions are possible. For ArcFace, the predicted linear relationship between intra-class distance and the margin appears to hold until the point where the model achieves peak performance. The prevailing explanation in the literature for the value of introducing a margin on the correct class logit has been that doing so encourages smaller intra-class distances for the corresponding trained model on the training set. This explanation seems to imply that increasing the margin further should always improve model performance, and that improved training set intra-class distance implies improved test set intra-class distance. However, we observe that the SphereFace and AmpFace plots in Fig. 4 seem to refute that observation. When we increase SphereFace’s margin past the optimal model performance value of $m_1 = 1.35$, the intra-class angle keeps decreasing as before but model performance drops significantly. More dramatically, decreasing AmpFace to the optimal value $m_0 = 0.35$ greatly improves model performance without a significant change in final intra-class distance. This indicates that though these multiplicative margins correlate more or less with intra-class distance, they contribute to generalization at least in part for different reasons. In Fig. 5, we display the curves theoretically derived in Section 3.4 for the loss, as a function of the correct class angle, for each of the empirically verified best margin values for $m_0$, $m_2$, and $m_4$ (see Appendix B for details). We also plot as a dashed blue line the inter-class expected angle given by Proposition 1 ($M_{\text{inter}} = 78.64^\circ$), and as a dashed red line the corresponding half-angle $M_{\text{inter}}/2 = 39.32^\circ$. Notice that this half-angle coincides very closely with the optimization termination point that defines our $M_{\text{inter}}$. The same half-angle relationship holds approximately between the observed train intra-class and inter-class distance for the model checkpoints trained with optimal margin settings $m_0 = 0.35$, $m_2 = 0.6$, $m_4 = 0.5$ identified through a careful linear margin sweep with step size 0.05. Our hypothesis also indicates an optimal value of $m_1 = 1.85$, which lies out of the parameter range where our SphereFace training converges. Recent work [14] however enables model convergence for larger values of $m_1$ by flattening the loss function when $m_1 \theta > \pi$. This shows that SphereFace can achieve maximum performance matching that of ArcFace. Figure 5: Predicted loss, as a function of the correct class angle, for the margins that achieve best model performance. The dashed red vertical line marks half the predicted inter-class distance ($M_{\text{inter}}/2 = 78.64^\circ/2 = 39.32^\circ$) for $C = 85,742$ in the $(512 - 1)$-unit sphere, which is very close to the optimization termination point and predicted intra-class distance for AmpFace, ArcFace, CosFace, as well as a recent regularized formulation of SphereFace [14]. and CosFace for $m_1 = 1.9$ (Table 8 of [14]), which is nearly identical to the value predicted here. We therefore conjecture that the optimal margin value reliably produces a loss function with optimization termination point at half the mean inter-class angle. This angle can be understood as the decision boundary between two prototypes after which a higher margin would result in train classification error. However, two spherical caps in high dimensions have a small intersection area even for larger angles [11]. A clear explanation thus defies our current understanding, but if true in general our conjecture is valuable for two reasons. First, it predicts the optimal value for each of the margin parameters, obviating the need for a laborious and expensive grid search across multiple benchmarks. Second, it may shed light on the reason that margins are helpful for optimization and generalization. ### 4.4. Reg$_{\text{ss}}$ vs. WC-ReLU Here, we empirically compare our two proposed regularization strategies with UniformFace [4] on the MegaFace Id benchmark with one million distractors. Table 2 shows that models that perform well without these extra regularizers still perform equally well after the addition of either strategy. When $m_0$ is used as the margin, Fig. 6 shows that both strategies are effective at avoiding collapse while UniformFace is much less effective. For extreme $m_0$ values, WC-ReLU still performs well whereas Reg$_{\text{ss}}$ fails. Reg$_{\text{ss}}$ may fail if prototypes collapse in low dimensions in a more complicated symmetrical way rather than towards a single point, though studying a more general degenerate solution space is out of the scope of this work. We argue that in practice, either strategy—and especially WC-ReLU—allows a larger search space for the optimal margin hyperparameter and is beneficial for systematic studies. \| \| Margin \| Plain \| WC-ReLU \| Reg$_{\text{ss}}$ \| \|----------------\|--------\|---------\|---------\|-------------------\| \| Softmax \| - \| 88.58 \| 88.95 \| 88.54 \| \| SphereFace \| $m_1 = 1.35$ \| 96.53 \| 96.89 \| 96.45 \| \| ArcFace \| $m_2 = 0.50$ \| 98.24 \| 98.30 \| 98.30 \| \| CosFace \| $m_3 = 0.35$ \| 98.11 \| 98.10 \| 98.06 \| Table 2: Comparison of MegaFace Id for two proposed regularization strategies. When the original training works well, adding either does not harm the performance. Figure 6: Comparison of the two proposed regularization strategies from Section 3.2 to avoid collapse during training. WC-ReLU outperforms Reg$_{\text{ss}}$ for extreme margin values, while UniformFace [4] is less effective than both. ### 5. Conclusion Our analysis reveals several new important insights: a training failure mode for certain margin ranges and two regularization strategies to address it; a new multiplicative margin with competitive results when regularized properly; predictions of intra-class and inter-class distances; and clarification of the generally held assumption of smaller intra-class distance leading to better generalization. Our work further suggests that there is a fixed inter-class angle at which optimization should stop, and that it informs the optimal value of the margins for AmpFace, ArcFace, and CosFace. Namely, that angle seems to be given by the point at which intra-class distance equals half the inter-class distance. This seems to be true both in practice and in our theoretical predictions, and represents a potential direction for future research. Although further work is needed to fully understand generalization in metric learning applications, the theoretical framework presented here is a first step to a clearer picture of margins in softmax losses and their effects on the spherical manifold during optimization. We also hope the evaluation settings presented here will help researchers benchmark quickly and fairly against prior work. Acknowledgements: The authors thank Arun Isaac for useful conversations on his algorithm for uniform sampling in spherical cones and for making the code publicly available. References [1] Xiang An, Xuhan Zhu, Yang Xiao, Lan Wu, Ming Zhang, Yuao Gao, Bin Qin, Debing Zhang, and Ying Fu. 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ABOUT IC-FTAI'2024 The IEEE Egypt AP-S/MTT-S Joint Chapter is organizing the International Conference on Future Telecommunications and Artificial Intelligence (IC-FTAI'2024). The IEEE-APS and MTT-S societies are providing technical support for the conference. The IEEE Egypt Section and IEEE Alexandria Subsection are supporting the IC-FTAI'2024 conference technically. In light of global mass COVID-19 vaccination campaigns, it is scheduled for December 31, 2024 To January 2, 2025, in Alexandria, Egypt, in a hybrid format (attend and/or online). In addition to contributed sessions, the conference program will include invited sessions on selected tracks. The technical sessions and invited talks are expected to provide in-depth coverage of the conference tracks’ most recent advances. All submitted papers must describe original work and be within the scope of the conference; all papers will be subjected to a double-blind review process. For papers to be added to IEEE Xplore, they will be judged on IEEE scope and quality. Authors are invited to submit original paper work within the scope of the IC-FTAI'2024 conference; all papers will be double-blind reviewed. The IC-FTAI'2024 seeks half-day (3-hour) or full-day (6-hour) tutorial proposals. The tutorial is part of the technical program. The IC-FTAI'2024 includes workshops. They introduce topics of interest to the telecommunications technology industry and encourage active discussion. Papers Submission Deadline: 30 October 2024 TECHNICAL PROGRAM TRACKS - Antennas and Emerging Technologies. - Electromagnetics and Materials. - Computational, Propagation and Scattering. - Electromagnetic Field, Devices, and Circuits. - Artificial Intelligence and Computer Architecture. - Computer Systems, Security and Robotics. - Bioinformatics, Computational Biology. - Systems, Applications and Emerging Technologies. - Communications Engineering, Networking and Technology. - Power Management and Control. The most important information is included here https://r8.ieee.org/egypt-apmtt/ic-ftai-conference/ Conference Goals - Encourage excellence and innovation in antenna, propagation, and electromagnetic theory, technology, and applications. - RF and microwave technology development and applications. - Encourage cross-disciplinary collaboration in computers, bioinformatics and artificial intelligence. IMPORTANT DATES 30 October 2024 Papers and Tutorials Deadline 10 November 2024 Workshops and Demonstrations Deadline 30 November 2024 Projects and Final papers Deadline Alexandria, Egypt Alexandria is Africa's seventh-largest city and Egypt's third-largest after Cairo and Giza. "Bride of the Mediterranean" is her nickname. Alexandria is the largest city in the Mediterranean, fourth in the Arab world, ninth in Africa, and 79th in the world. PROJECT POSTERS All undergraduate engineering and school students are encouraged to submit a one-page proposal to the IC-FTAI'2024 and demonstrate their engineering skills, talent, and ability to defend their innovative ideas through posters and seminars. The goal of project posters is to cover all areas of interest listed in the conference tracks. All conference activities were free of charge for the students who took part. EXHIBITORS AND SPONSORS The IC-FTAI'2024 will feature an international scientific program and a forum for academic and industrial knowledge exchange. The three-day conference has keynote speeches, panels, forums, technical sessions with peer-reviewed papers, tutorials, workshops, demonstrations, project posters, exhibitions, and a banquet.	5b1a7441-30e9-48cc-93a1-f7de0b0e87ea	CC-MAIN-2024-22	https://r8.ieee.org/egypt-apmtt/wp-content/uploads/sites/152/Call-For-Papers-IC-FTAI2024.pdf	2024-05-27T12:12:50+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-22/subset=warc/part-00158-4dd72944-e9c0-41a1-9026-dfd2d0615bf2.c000.gz.parquet	412,000,291	733	eng_Latn	eng_Latn	0.989698	eng_Latn	0.990746	[ "eng_Latn", "eng_Latn" ]	true	docling	[ 1499, 3597 ]
Edmund J. Malesky Rubenstein Hall, 302 Towerview Road Box 90237 Durham, NC 27708 Tel. (919) 660-4340 Cell. (858) 568-8719 Email:[email protected] Academic Positions Duke University, Durham, NC, Department of Political Science Director of Duke Center for International Development (DCID), 2020 to Present. • Responsible for a center that hosts 5 full-time faculty, 13 staff members, a two-year masters program with over 60 students, an annual budget of $3.5 million, and over $3 million in research grants. DCID also has an Executive Training and Advisory program that provides training courses for the Fort Bragg Civil Affairs Battalions, Oxfam International, and several open-enrollment courses that provide training for over 180 short-term students. Professor of Public Policy, June 2020 to Present University of North Carolina Professor of Political Science, June 2016 to Present Associate Chair of Po Associate Professor, June 2012 to 2016 litical Science, September 2016 to 2017 National University of Singapore Business School , Department of Econ omics Visiting Associate Professor, A Fixed Term Professor, July 2024 to Present University of California, San Diego, ugust 2013 to August 2014 , Department of Strategy and Policy Associate Professor, June 2011 to June 2012 Graduate School of International Relations and Pacific Studies (IR/PS), Visiting Professor, August 2017 to August 2018 Assistant Professor, July 2005 to June 2011. Duke University, Harvard University Academy Fellow, Weatherhead Center for International Affairs, 2004/2005 & 2007/2008 Academic Years. Departments. B.S. Developmental Economics, Georgetown University, Edmund A. Walsh School of Foreign Service , 1996. Summa Cum L aude, Phi Beta Kappa Education Ph.D. Po litical Science, M.A. Pol itical Science, Duke University, 2 001. · Passed Comprehensive Examinations with Distinction · Certificate of Political Economy awarded jointly by Duke Economics and Political Science 2004. Professional Activities External Chair, Social Science and Humanities Research Fellowship Expert Panel, 2022. Chair, Southeast Asia Research Group (SEAREG), funded by the Luce Foundation, 2012-Present Chair, Evidence for Governance and Politics, Metaketa Research Initiative V, 2019-Present Member of External Review Committee, Fulbright University of Vietnam Public Policy School, August 2016. Board Member, International Political Economy Society (IPES), 2014-Present Host of International Political Economy Society ,2016. Board Member, APSA East Asia Initiative Editor, Member,Experiments and Government and Politics (EGAP) ,2013-Present Member,American Political Science Association,Washington, D.C., 1998 – Present. Council Member, APSA Political Economy Section Editorial Board, Journal of Politics, 2016-2019 Editorial Board, Comparative Political Studies Journal of East Asian Studies, , 2010-2019 , 2016-Present Editorial Board, 2016-Present. Editorial Board, American Journal of Political Science, 2024-Present Japanese Journal of Political Science, Annual Meeting at Duke University (Sel 2024-Present n, Myanm ar. Myanmar Business Environment Index, ected) Vietnam Education Foundation, Washington D.C., 2013-2016. ling approach and cre ated indexing methodolog y. sis and author report. Lea d Researcher, Architect, and Author of the Vietnam Provincial Competitiveness Index (PCI), US-AID's Vietnam Competitiveness Initiative , Hanoi, Vietnam, 2004 to Present. · Author annual report · Designed s urvey and samplin g appr oach, perfor med statistical analysis, and created indexing methodolo gy. · Perform an nual data analysi s and au thor report . · Discussed over 6,000 articles in new spapers in Vietnam and around the world, including citations in Bloomberg News and the Economist . Non-Academic Positions Board Member and Finance Chair, · Position requiring US Presidential Appointment Chief Technical Adviser, The Asia Foundation, Yango 2017 to 2021. · Designed survey and samp · Perform annual data analy Sen ior Adviser on Methodology, United Nations Development Program, Hanoi Vietnam. Public Administration Performance Index , 2009 to Present. · Author annual report · Designed survey and sampling approach and cre ated indexing methodology. · Perform annual data analysis an d author report. · Profiled as an exemplary de velop ment project at Innovations for Successful Society , Princeton University (December 2014 ). * Hav e worked on or served as an official advisor on similar indices in Indonesia, Sri Lank a, Kos ovo, El Salvador, Bangl adesh, Laos, and Myanmar. * Designed survey and sampling approach, performed statistical analysis, and created indexing methodology. Met hodology Ad viser and Author of the Chinese-Government Assessment Project (C-GAP) , The Asia Foundation , Beijing C hina , 2008 to Present. · Designed method olo gy and analyzed index results Lea d Researcher, Architec t, a nd Author of the Cambodia Provincial Business Environment Scorecard (PBES), The Asia Foundation, and Mekong Private Sector Development Facility of the World Bank Group, Phnom Penh, Cambodia, 2005 to 2009. Service to Duke University * Author of Social Science Curriculum, 2016 to 2019 Duke Kunshan University • Chair of Search Committee for Executive Vice Chancellor, 2019-Present Vice Provosts Committee on Research Policy * University Committee on Data Policy Global Priorities Committee, 2015 to Present • Member of Duke Data Management Planning Team Member of Provost's Committee on Research Member of Duke Global Centers Task Force * * Political Science Department • * Associate Chair, 2016 to Present Honors and Awards Duke Teaching Award for Top 5% of all instru Chair of Political Economy Field, 2014 to 2016, 2018-2019. 2021-2023 * Fall 2024, Spring 2022, Fall 2022 Chair of Comparative Ethnic Politics Search, 2023. Southeast Asia Politics Related Group ctors on undergraduate teaching evaluations. Duke Teaching Award f or Highest Student Evalu ations in class with under 20 students, May 2016. Rockefeller Foundation,Bellagio Center Fellow,June 2014 , Best Pap er Award, 2022 ese Chamber of Commerce and Industry, American Academy of Management ONE-SIMA ward for best outreach activities based on a published ber 2012. paper. Decision to b e made in August 2020. the country's economic development. Mancur Olson Award State Medal Awarded by the Vietnam o Hanoi, Vietnam, Decem o Awarded for service to Faculty Teaching Excellence Award , Voted by the entire graduating class. Gabriel A. Almond Award American Political Science Association, 2005. UCSD IR/PS, May 2007 Political Science As for for Best Dissertation in Comparative Politics, Development, 2 Best Dissertation in Political Economy (Runner-up)H, American James B. Duke Scholar . Duke University, 1998 t o 200 sociation, 2005. David Boren Scholarship for dissertation research, Association of Education 001. Luce Scholar to Vietna m, Henry Luce Foundation, 1997 to 1998. Major Grants Research Technical Assistance Center (RTAC),$50,00, 2021 has provided my center buy-ins for research on climate migratio Luce Foundation, Southeast Asia Research Group, $300,000, 2016, 2019, 2022 International Growth Center. $35,000 for a pilot project on Digital consultation of firms and perception of government's regulatory legitimacy in Thailand, 2023. USAID Research Technical Assistance Center. $500,000. This is a multi-organizational consortium that in Fall 2018 an n, China's Belt and Road, and Malawi, Myanmar, Pakistan, and Vietnam—rangin evaluation of USAID science projects. It also funds training work shops for development practitioners projects use common interventions to increase the around the world. committees, $2.5 million, 2020. Metaketa Round V: Women's Action Committees and Local Services: This Metaketa round was launched USAID Laser Pulse: "Do Better Managers Engage in Les d will run until Fall 2023. This round awarded five projects—one each in Kyrgyzstan, USAID DRG Learning Evaluation and Research Center: g in funding from $250,000 to $300,000. All of the $250,000, 2022. collective efficacy of women-only action USAID Cambodia, "Solid Waste Management Program," $1.5 million, 2019. USAID Research Technical Assistance Center, "Consortium on improving research in international development projects," $26,000, 2019 "Anti-Corruption Learning Agenda Review," s Corruption?", $217,418, 2020. Organization for Economic Cooperation and Development, "OECD Research project on improving data quality on governance in Southeast Asia," $10,000, 2019. Jameel Poverty Action Lab, "Governance Initiative Grant for RCT on "Responsiveness in Authoritarian Parliament Project," $67,000, 2016 The Asia Foundation, Myanmar Business Environment Index, $250,000, 2018. Luce Foundation, Southeast Asia Research Group, $300,000, 2016 and 2019. Jameel Poverty Action Lab, Governance Initiative Grant for RCT on "Business Participation and Regulatory Compliance," $263,000, 2014. Ph.D. Students Paul Schuler, Associate Professor at the University of Arizona. Tuan-Ngoc Phan, Assistant Professor, Fulbright University of Vietnam * · Kai Ostwald, Associate Professor at the University of British Columbia · Dimitar Gueorguiev, Associate Professor at Syracuse University Maxwell School · Steven Oliver, Assistant Professor at Yale-National University of Singapore · Cesi Cruz, Assistant Professor at the University of British Columbia · Ben Graham, Associate Professor at the University of Southern California · Celeste Beesly, Assistant Professor at Brigham Young University · Quoc Anh Le, Data Scientist at Facebook · Trang Anh Do, Data Scientist at AC Neilson · Jason Todd, Assistant Professor at Duke Kunshan University · Zeren Li, Lee Assistant Professor at Kuan Yew School of Public Policy, National University of Singapore · Dean Dulay, Assistant Professor at Singapore Management University · Harunobo Saijo, Assistant Professor at Hiroshima University · · Publications Peng Peng, Assistant Professor, Washington University Books Jens en, Nathan, and Edmund Malesky. 2018. Incentives to Pander. How Politicians Use Corporate Welfare for Political Gain . Cambridge University Press. Stro mseth, Jonathan, Edmund Malesky, Dimitar Gueorguiev . 2017. China's Governance Puzzle Enabling Transparency and Participation in a Single-Party State. Cambridge University Press. Publications in Refereed Journals Fertig, Alexander., Iyer, Lakshmi, Hartman, Alexandra, & Malesky, Edmund J. (Forthcoming). "A Field of Her Own: Property Rights and Women's Agency in Myanmar." Journal of Politics Leventoğlu, Bahar, Edmund J. Malesky, & Wen, Undes (2024). "Synthesizing Theories of Authoritarian Nat han Jensen, Glenn Biglaiser , Quan Li, Edmund Malesky Pablo Pinto, Santiago Pinto. 2012. Politics and Foreign Direct Investment . Ann Arbor: University of Michigan Press Elections: A Game-Free Analysis." Comparative Political Studies, 00104140241302708. Bonifai, Niccolo, Edmund J. Malesky, Nita Rudra (forthcoming). "Economic Risk Perceptions and Willingness to Learn about Globalization: A Field Experiment with Migrants and Other Underprivileged Groups in Vietnam" American Journal of Political Science. APPENDIX Fertig, Alexander, Alexandra Hartman, Lakshmi Iyer, and Edmund Malesky (forthcoming). "A Field of Her Own: Property Rights and Women's Agency in Myanmar." Journal of Politics. Malesky, Edmund J., and Trung Anh Nguyen. (2024). Historical Communist Party Strength and Modern Party Loyalty. A Replication Study of Barceló (PNAS, 2021). Journal of Comments and Replications in Economics (JCRE), 3(2024-5), 1-27. Malesky, Edmund J., and Quynh Nguyen (2024). "Testing the Drivers of Corporate Environmentalism in Vietnam." Studies in Comparative International Development 59.1 (2024): 86-112. Beijing License Plate Lottery on the Environment," Quarterly Journal of Political Science 19(1), 91-126. Dulay, Dean and Edmund J. Malesky (2023). " Facilitating Development: Evidence from a National-Level Experiment on Improving Bureaucratic Performance in Myanmar ." Journal of Politics 85(4), 1385-1400 Liu, Amy and Edmund J. Malesky (2024). " Cultural Constraints and Policy Implementation: Effects of the Delios, Andrew, Malesky, Edmund J. Malesky, Yu Shu, and Griffen Riddler (2023). " Methodological errors in corruption research: Recommendations for future research ." Journal of International Business Studies , 55 (2), 235-251. Dang, Hai-Anh H., Edmund Malesky, and Cuong Viet Nguyen (2022) " Inequality and support for government responses to COVID-19 ." Plos one 17.9 (2022): e0272972. Springman, Jeremy, Edmund J. Malesky, Lucy Right, Erik Wibbels (2022). " The Effect of Government Repression on Civil Society: Evidence from a Conjoint Survey Experiment in Cambodia ." International Studies Quarterly 66.3: 1-15. Malesky, Edmund J., Jason D. Todd, and Anh Tran (2022). "Can Elections Motivate Responsiveness in a SingleParty Regime? Experimental Evidence from Vietnam." American Political Science Review, 1-21. • Awarded best paper on Southeast Asia at the American Political Science Association Conference. Malesky, Edmund, Tuan-Ngoc Phan, and Anh Quoc Le (2022). "Do subnational performance assessments lead to improved governance? Evidence from a field experiment in Vietnam." Fulbright Review of Economics and Policy (2022). Malesky, Edmund J. and Bui Hai Thiem (2024). " Vietnam in 2023: Stoking the Embers of the Blazing Furnace " Southeast Asian Affairs 2024. Bui, Thiem H., and Edmund J. Malesky. " Vietnam in 2022: Return to a Turbulent Normalcy. " Asian Survey 63.2 Malesky, Edmund and Jason Todd (2022). " Experimentally Estimating Safety in Numbers in a Single-Party Legislature ," Journal of Politics 84.3: 1878-1883 Nguyen, Quynh, and Edmund Malesky. 2021. "Fish or Steel: New Evidence on the Environment-Economy Trade-Off in Developing Vietnam." World Development 147.2021, 105603 (2023): 258-269. Malesky, Edmund. J. (2022). "Vietnam Makes a Model Recovery from COVID-19," East-Asian Forum, December 24 Chapman, Terrence L., Nathan M. Jensen, Edmund J. Malesky, and Scott Wolford. (2021) " 'Leakage' in International Regulatory Regimes: Did the OECD Anti-Bribery Convention Increase Bribery? ," Quarterly Journal of Political Science 16.4: 387-427. Malesky, Edmund J. 2021. " Enhancing the Literature on Authoritarian Regimes through Detailed Comparisons of China and Vietnam ," Problems of Postcommunism . 68. 3: 163-170. agreements: Evidence from Vietnam," Economics & Politics 33.3, 443-482. Todd, Jason D., Edmund Malesky, Anh Tran, and Quoc Anh Le (2021). " Testing Legislator Responsiveness to Citizens and Firms in Single-Party Regimes: A Field Experiment in the Vietnamese National Assembly ," Journal of Politics 83.4: 1573-1588. Malesky, Edmund J., and Helen V. Milner (2021). " Fostering global value chains through international business tax registration and compliance: Evidence from Vietnam," Behavior and Organization 177: 762-786. Malesky, Edmund J., and Layna Mosley (2021) . " Labor Upgrading and Export Market Opportunities: Evidence from Vietnam ," Economics & Politics 33.3: 483-513. Le, Duong Trung, Edmund Malesky, and Anh Pham (2020). " The impact of local corruption on Journal of Economics Mal esky, Edmund and Paul Schuler (2020). " Single-Party Incumbency Advantage in Vietnam: A Conjoint Survey Analysis of Public Electoral Support, " Journal of East Asian Studies 20.1 : 2552. Malesky, Edmund and Markus Taussig (2019). "How Do Firms Feel About Participation by Their Peers in the Regulatory Design Process? An Online Survey Experiment Testing the Substantive Change and Spillover Mechanisms." Strategy Science. 4.2: 129-150. Mal esky, Edmund, Nguyen Van Thang, Bach Nguyen Thang, Bao D. Ho, (2020), " The effect of market competition on bribery in emerging economies: An empirical analysis of Vietnamese firms. " World Development 131 : 104957-104983. Malesky, Edmund and Markus Taussig (2019). "Participation, Government Legitimacy, and Regulatory Compliance in Emerging Economies: A Firm-Level Field Experiment in Vietnam." American Political Science Review 113.2: 530-551. • Discussed on VoxDev. Gueorguiev, Dimitar and Edmund J. Malesky (2019). "Consultation and Selective Censorship in China," Journal of Politics 81.4: 1539-1545. Bai, Jie, Seema Jayachandran, Edmund J. Malesk y, and Benjamin A. Olken. 2017. " Firm Growth and Corruption: Empirical Evidence from Vietnam. " The Economic Journal 29.618 : 651-677 · Discussed on VoxDev. Mal esky, Edmund J.. 2018. "How I Research: A Comment on Malesky vs. Fforde." Journal of Vietnamese Studies 13.3: 127-162. Mal esky, Edmund J., and Layna Mosley . 2018. " Chains of Love? Global Production and the Firm‐Level Bac cini, Leonardo, Giammario Impullitti, and Edmund J. Malesky (2019) " Globalization and state capitalism: Assessing Vietnam's accession to the WTO. " Journal of International Economics 119: 75-92. Diffusion of Labor Standards." American Journal of Political Science 62.3: 712-728, Jens en, Nathan and Edmund J. Malesky. 2018. "Nonstate Actors and Compliance with International Agreements: An Empirical Analysis of the OECD Anti-Bribery Convention." International Organization 72.1:33-69. * Awarded Best Article Award" of the Public and Nonprofit Division of the Academy of Management 2017. Bec ker, Jordan M., and Edmund J. Malesky. "Atlanticism and Transatlantic Burden Sharing: The Relationship between Strategic Culture and Disaggregated Defense Investment." International Studies Quarterly . 61.1: 163-180 · Discussed on Washington Post, Monkey Cage. Ing ersoll, Kieth, Edmund Malesky, and Sebastian Saiegh. 2017. "Heterogeneity and team performance: * Cited in United Kingdom House of Lords in Debate on Revisions to Anti-Bribery Bill. Malesky, Edmund J. and Markus Taussig. 2017. "The Danger of Not Listening to Firms: Government Responsiveness and the Goal of Regulatory Compliance." Academy of Management Journal, 60.5: 17411770. • Awarded Responsible Research in Management 2017 Inaugural IACMR Presidential Award 2017 Evaluating the effect of cultural diversity in the world's top soccer league." Journal of Sports Analytics * Discussed on Fortune.com Findley, Michael G., Nathan M. Jensen, Edmund J. Malesky, and Thomas B. Pepinsky. 2016 "Can Results-Free Review Reduce Publication Bias? The Results and Implications of a Pilot Study." Comparative Political Studies, Comparative Political Studies, 49.13: 1667-1703. • Introduction to a special issue I co-edited where all submissions were reviewed without empirical results. , 3.2:67-92 Mal Mal esky, Edmund, Neil McCulloch , Nguyen Duc Nhat. 2015. " The Impact of Governance and Transparency on Firm Investment in Vietnam. " Economics of Transition, 23.4 : 677-715 Malesky, Edmund, Dimitar Georguiev and Nathan M. Jensen. 2015. "Monopoly Money: Foreign Investment and Bribery in Vietnam, a Survey Experiment." American Journal of Political Science 59.2: 419-439. · Profiled on Experiments in Government and Politics Website (http://egap.org/research/brief-26/) * Discussed on The Replication Network , Retraction Watch , Monkey Cage esky, Edmund J., and Francis E. Hutchinson. 2016. " Varieties of Disappointment: Why Has Decentralization Not Delivered on Its Promises in Southeast Asia?." Journal of Southeast Asian Economies (JSEAE) 33.2: 125-138 . · Introduction to a special issue I co-edited by country experts discussing their country's experience with decentralization and recentralization. Mal esky, Edmund J. 2015. "Transfer Pricing and Global Poverty." International Studies Review 17.4: 669-677. Jens en, Nathan, and Edmund Male sky. 2015. " Competing for Global Capital or Local Voters? The Politics of Business Location Incentives. " Public Choice , 164.3-4: 3 31-356. * Awarded best paper presented at the annual meeting of the International Political Economy Society in 2011. Mal esky, Edmund, and Jason Morris Jung. 2015. " Vietnam in 2014: Uncertainty and Opportunity in the Wake of the HS-981 Crisis. " Asian Survey 55.1: 165-173. Mal esky, Edmund, Anh Tran, and Nguyen Viet Cuong. 2014. " The Impact of Recentralization on Public Services: A Differences‐in‐Differences Analysis of the Abolition of Elected Councils in Vietnam. " American Political Science Review 108.1: 144-1 68. * Awarded best paper on Comparative Policy presented at the annual conference of the Midwest Political in 2013. Mal esky, Edm Asian Survey 38. * Awarded best paper on McGillivray Best Paper Award in Political Economy at the annual conference of the American Political Science Association in 2014. und. 2014. " Vietnam in 2013: Single-Party Politics in the Internet Age. " 54.1: 30 - Science Association * Awarded best paper on Comparative Policy presented at the annual conference of the American Political Science Association in 2014. Malesky, Edmund, and Jonathan London. 2014. "The Political Economy of Development in China and " Annual Review of Political Science Authoritarian Legislatures and Political Risk." British Journal of Political Science, 44.3: 655-684. Vietnam. 17: 395-419. Jens en, Nathan, Edmund Malesky, Mariana Medin a, and Ugur Ozdemir. 2013. " Pass the Bucks: Credit, Blame, and the Global Competition for Investment," I nternational Studies Quarterly, 58.3: 433-447. Jens en, Nathan, Edmund Malesky, Stephen Weymouth. 2013. " Unbundling the Relationship between Mal esky, Edmund and Paul Schuler. 2013. " Star Search: Do Elections Help Non-Democratic Regimes Identify New Leaders? " Journal of East Asian Studies 13.1: 35-68. Tua n-Minh Dinh, Edmund Malesky, Trung-Thanh To and Duc-Thanh Nguyen. 2013. " Effect of Interest Rate Subsidies on Firm Performance and Investment Behavior during Economic Recession: Evidence from Vietnam." Asian Economic Journal 27.2 (May): 185–207 Malesky, Edmund and Dimitar Georguiev. 2012. "Foreign investment and bribery: A firm-level analysis of corruption in Vietnam." Journal of Asian Economics 23.2: 111–129 Mal esky, Edmund, Paul Schuler, and Anh Tran. 2012. " The Adverse Effects of Sunshine: Evidence from a Field Experiment on Legislative Transparency in an Authoritarian Assembly. " American Political Science Review 106.4: 762-786. Regimes: A Comparative Analysis of Vietnam and China." Comparative Politics 43(4): 401-421. Mal esky, Edmund, Anh Tran, and Paul Schuler. 2011. " Vietnam 2010: Familiar Patterns and New Developments Ahead of the 11th Vietnam Communist Party Congress. " Southeast Asian Affairs 2011 : 339363. Mal esky, Edmund and Paul Schuler. 2010. " Nodding or Needling: Analyzing Delegate Responsiveness in an Authoritarian Parliament. " American Political Science Review 106.4: 762-7 86. Jensen, Nathan, and Edmund Malesky. 2010 . " FDI Incentives Pay – Politically ." Vale Columbia FDI Perspectives 26 (June). Gel bach, Scott and Edmund Malesky. 2010. " The Contribution of Veto Players to Economic Reform. " Journal of Politics 72.4: 957–975. Mal esky, Edmund and Markus Taussig. 2009. " Out of the Gray: The Impact of Provincial Institutions on Business Formalization in Vietnam. " Journal of East Asian Studies 9.2: 249-290. Mal esky, Edmund. 2009. " Foreign Investors: Agents of Economic Transition. An Instrumental Variables Analysis. " Quarterly Journal of Political Science 4.1: 59-85 Mal esky, Edmund. 2009. " Gerrymandering Vietnam Style: Escaping the Partial Reform Equilibrium in a NonDemocratic Regime. " Journal of Politics 71.1: 132-159. Ca mmet, Melani and Edmund Malesky. 2012. " Power-Sharing in Post-Conflict Societies: Implications for Peace and Governance. " Journal of Conflict Resolution 56.6: 982-1016. REPLICATION DATA Mal esky, Edmund and Nina Merchant-Vega. 2011. " A Peek under the Engine Hood: The Methodology of Subnational Economic Governance Indices. " Hague Journal on the Rule of Law 3.2: 186–219. Mal esky, Edmund and Paul Schuler. 2011. " The Single-Party Dictator's Dilemma: Information in Elections without Opposition. " Legislative Studies Quarterly 36.4: 491-530. Mal esky, Edmund, Regina Abrami and Yu Zheng. 2011. " Accountability and Inequality in Single-Party Malesky, Edmund, and Krislert Samphantharak. 2008. "Predictable Corruption and Investment Strategy: Evidence from a Natural Experiment and Survey of Cambodian Entrepreneurs." Quarterly Journal of Political Science 3.3: 227-267. Malesky, Edmund. 2019. "Decentralization and Business Performance," in Decentralized Governance and Accountability, edited by Jonathan Rodden and Erik Wibbels. Cambridge University Press: 144-177. Mal esky, Edmund and Paul Schuler. 2008. " Paint-by-Numbers Democracy: The Stakes, Structure, Results, and Implications of the 2007 Vietnamese National Assembly Elections. " Journal of Vietnamese Studies 4 . 1: 1-48. Mal esky, Edmund and Markus Taussig. 2008. "Where is Credit Due? Companies, Banks, and Locally Differentiated Investment Growth in Vietnam." J ournal of Law, Economics, and Organization 25.2: 535-578 Mal esky, Edmund. 2008. "Straight Ahead on Red: How Foreign Direct Investment Empowers Subnational Leaders." J ournal of Politics 70.1:97-119. Mal esky, Edmund. 2004. " Leveled Mountains and Broken Fences: Measuring and Analy z in g D e Fa cto Decentralization in Vietnam . " European Journal of South East Asian Studies 3.2: 307-337. Book Chapters, Handbook Entries, Encyclopedia Entries Malesky, Edmund. 2020. "Decentralization in Vietnam," Handbook of Vietnamese Studies , edited by Jonathan L. London, London: Routledge Curzon. Mc Culloch, Ne il, and Edmund Malesky. 2014. "What d etermines the quality of subnational economic governanc e? Comparing Indonesia and Vietnam." Indonesia Update: Regional Dynamics in a Decentralized Indonesia , edited by Hall Hill. Canberra: Australia National University: Chapter 9. Malesky, Edmund and Phan Ngoc Tuan. 2019, "Rust R emoval: Why Vietnam's Anticorruption Efforts Have Failed to D eliver Results, and What That Implies f or Future Campaigns," in The Political Logics of Anticorruption Efforts in Asia , edited by Cheng Ch en and Meredith Weiss. Albany, Suny Press: 103-138. , edited by Shane Martin and Kore Strom. Oxford: Oxford University Press: 676-695. Malesky, Edmund. 2014. "Understanding the C onfidence Vote in Vietnamese National Assembly: A n Update on 'Adverse Effects of Sunshine.'" In Politics in Contemporary Vietnam: Party, State, and Authority Relations . London: Palgrave McMillan: 84-99. Schuler, Paul and Edmund Malesky. 2014. "Authoritarian Legislatures." In Oxford Handbook on Authoritarian Institutions Abrami, Regina, Edmund Malesky, and Yu Zheng. 2013 "Vietnam through Chinese Eyes: Divergent Accountability in Single-Party Regimes." In Why Communism Did Not Collapse: Understanding Authoritarian Regime Resilience in Asia and Europe, edited by Martin Dimitrov. New York: Cambridge University Press: 237-276. Malesky, Edmund. 2010. "Interest Group Politics." Handbook of Safeguarding Global Financial Stability: Political, Social Cultural, and Economic Theories and Models, edited by Gerard Caprio Jr. Boston: Elsevier: 60-67. Malesky, Edmund. 2008. "Battling Onward: The Debate Over Field Research in Developmental Economics and its Implications for Comparative Politics." Qualitative Methods (Fall). Malesky, Edmund. 2008. "Provincial Governance and Foreign Direct Investment in Vietnam." In Twenty Years of Foreign Investment in Vietnam." Ho Chi Minh City: Knowledge Publishing House. Malesky, Edmund. 2008. "The Vietnam War." In International Encyclopedia of the Social Sciences (Second Edition), ed. William Darity. Detroit: Macmillan Reference USA: 612-617. Malesky, Edmund. 2004. "Push, Pull, and Reinforcing: The Channels of FDI Influence on Provincial Governance in Vietnam." in Beyond Hanoi: Local Governance in Vietnam, eds. by Ben Kerkvliet and David Marr. Singapore: Institute for South East Asian Studies and NIAS Press: 285-333. Gel bach, Scott and Edmund M alesky. 2012. "The Grand Experiment that Wasn't? New Institutional Economics and the Postcommunist Experience . In Institutions, Property Rights, and Economic Growth: The Legacy of Douglass North , edited by Sebastian Galiani and Itai Sened. 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Building Skills in Motivational Interviewing Helping People Change SC Coalition for the Homeless in partnership with ECHO Myrtle Beach, SC September 19, 2017 Ken Kraybill Center for Social Innovation/t3 www.thinkt3.com Building Skills in Motivational Interviewing Training Objectives Participants will be able to: * Describe the four elements of the mindset and heart-set of MI * Provide examples of the core interviewing skills of MI * Explain the four processes that guide MI conversations * Name three strategies to elicit change talk 9:00 Overview of MI Basics What would you say next? Relevancy of MI for your work Embodying the mindset and heart-set of MI Four processes that guide the flow of MI 10:30 BREAK 10:45 Responding with reflective statements and summaries Forming reflective statements Using reflective statements strategically Offering three types of summaries 12:15 LUNCH 1:00 Using evocative questions and affirmations Forming thoughtful, compelling open questions Using open questions to deepen the conversation Combining reflective statements with questions Offering affirmations to highlight strengths 2:30 BREAK 2:45 Recognizing, eliciting, and responding to change talk Recognizing change talk Strategies to elicit change talk Responding to change talk to strengthen it Providing information and suggestions 4:00 ADJOURN 1 A Brief History of Motivational Interviewing Motivational Interviewing (MI) is a way of talking with people about change related to things we often have mixed feelings about – exercise, diet, alcohol and other drug use, relationship issues, risky sexual behaviors, school and job related concerns, spiritual practices, certain attitudes, and other issues we face in our lives. The MI approach grew out William R. Miller's work with problem drinkers. In the past, it was believed that people who drank too much were unable to see how their use was harming themselves and others. They were said to be in denial. Counselors and others who wanted to help would try to break through this denial by using "in-your-face" tactics such as confrontation and shame to try to convince people of their need to change. As you can imagine, this approach didn't work very well. None of us like it when other people think they know what's best for us or try to get us to change. We want to decide for ourselves how to live our lives. In 1991, William R. Miller and Stephen Rollnick wrote a book titled Motivational Interviewing: Preparing People to Change Addictive Behavior. It explained how to talk with people about their alcohol and drug use in ways that respected their ability to decide for themselves whether they wanted to change. In the book, the authors described the spirit (core attitudes and beliefs) of this approach and the specific skills and strategies of MI. A second edition, Motivational Interviewing: Preparing People for Change, was published in 2002. It further explained how MI works, the research behind it, and how to get better at using MI. It also described the spread of MI to other areas beyond substance use disorders including health care, mental health, corrections, and school settings. A third edition, Motivational Interviewing: Helping People Change, 2013, expanded on the MI approach and included some new ideas such as the four processes of MI conversations: engaging, focusing, evoking, and planning. MI is defined as "a collaborative conversation style for strengthening a person's own motivation and commitment to change." MI can also be described as "a way of helping people talk themselves into changing." This approach embodies "a mind-set and a heartset" that includes partnership, acceptance, compassion, and evocation. Motivational Interviewing is a guiding style that invites people to examine their own values and behaviors and come up with their own reasons to change. It doesn't try to convince people or argue with them. Instead, it draws out people's own hopes, experience, and wisdom about themselves including whether or not to change. As William R. Miller says, "You already have what you need, and together let's find it." People who are used to confronting and giving advice will often feel like they're not "doing anything." But, as Miller and Rollnick point out, the proof is in the outcome. More aggressive strategies often push people away. MI, on the other hand, increases the odds that people will give change a chance. The Mindset and Heart-set of MI: Partnership, Acceptance, Compassion, and Evocation "MI is done for or with someone, not on or to them." Motivational Interviewing, 3 rd edition Imagine taking a drink of a carbonated beverage that has gone flat. It still tastes vaguely like itself, but the fizz has gone out of it. It's no longer worth drinking, and you'll probably pour it down the drain. The spirit of MI is the fizz of a helping conversation. It's what shows you that a person truly cares about you and isn't just pretending to care. In describing MI spirit, Miller and Rollnick note: "When we began teaching MI in the 1980s we tended to focus on technique, on how to do it. Over time we found, however, that something important was missing. As we watched trainees practicing MI, it was as though we had taught them the words but not the music… This is when we began writing about the underlying spirit of MI, its mind-set and heart-set." (Motivational Interviewing, 3 rd edition) The spirit of MI is communicated in our body language, facial expressions, tone of voice, and attitudes. It comes from inside us and can't be faked. It has to be real. Spirit is about the way we are with people, not just what we say. Miller and Rollnick identify four parts of the spirit of MI: partnership, acceptance, compassion, and evocation. Each of these is related but also unique. PARTNERSHIP – showing real respect for the other person; assuming both of you have important input; dancing rather than wrestling ACCEPTANCE – meeting people "where they're at" without judging them; believing in them; trying to understand where they're coming from; shining a light on the good stuff you see in them instead of pointing out what's wrong with them COMPASSION – hanging in there with people when they're hurting or struggling with an issue; doing whatever is in the person's best interests EVOCATION – "calling forth" or asking people about things such as what makes them tick, what they already know, what's important to them, how would they like their lives to be different Adapted from Motivational Interviewing, 3 rd edition by Miller & Rollnick, 2013 Four Processes of MI: Engaging, Focusing, Evoking, Planning MI conversations have a purpose and direction. They seek to help people identify and explore their hopes, values, and change goals using an empathic, guiding approach. The guiding approach used in motivational conversations generally moves through four processes. These processes – engaging, focusing, evoking, and planning – tend to follow a logical order beginning with engaging and ending with planning. However, it doesn't mean that they always follow a straight line or that every conversation will include all four. Using MI is similar to improv theatre; you don't have a script, but there is a basic storyline that you're trying to follow. Engaging – getting to know someone and building trust * "It's really good to meet you." * "Tell me a bit about yourself." * "What do you do for fun?" Focusing – figuring out together what to talk about * "What would you like to talk about today?" * "You mentioned some problems at school, some issues with your girlfriend, and wanting to find a way to make some money. Where do you want to start?" * "Would it be all right if we took a closer look at your relationship with alcohol?" Evoking – drawing out the person's own desire, reasons and ability to change * "How would you describe the role of alcohol in your life?" * "How confident are you that you could make this change if you wanted to?" * "If you did decide to have a healthier lifestyle, where would you start?" Planning – developing a specific change plan that the person is willing to put in action * "What do you think you'll do next?" * "What might get in the way of your plan?" * "How can I and others support you in carrying out your plan?" Adapted from Motivational Interviewing, 3 rd edition by Miller & Rollnick, 2013 4 OARS: Open Questions Open questions invite people to say as much or as little as they want about a topic. They allow people to decide for themselves what ideas, thoughts or feelings they want to share. Answering open questions tends to help people understand themselves better and think in new ways about their situation. Here are some examples of open questions: What's going well in your life? What's not going so well? What would you like to talk about today? How does alcohol fit in your life, if at all? When you do drink, what does it do for you? What do you value most in a friend? If you could change anything in your life, what would it be? What specific changes are you thinking about making? Closed questions, in contrast, limit the conversation. They are most often used to gather specific information or ask yes or no questions. For example: What is your date of birth? How much do you drink? When is the last time you got a physical exam? Which day would you like to meet next week? Open questions are used throughout the four processes of MI and help to engage with the person, increase understanding, strengthen collaboration, find a focus, draw out motivation, and develop a plan for change. As a general guideline, open questions should be used more than closed ones. OARS: Affirmations Affirmations are statements that shine a light on what is good about a person. They put emphasis on people's strengths rather than their weaknesses. Strengths can include a person's talents, qualities, knowledge, skills, efforts, and much more. Affirmations often help people see strengths they possess that they may have a hard time seeing for themselves. Affirmations can also build a person's confidence in being able to make changes. An affirmation must be real and from the heart. People will know if it seems false and might be less likely to trust you. Affirming someone's strengths is different than cheerleading or praising. Praise statements put you in a "one-up" position and are usually based on judging someone's performance. Furthermore, praise can be both given and withdrawn. When forming affirmations, it's usually best to avoid starting with "I" and instead center the comment on "you." It's also helpful to be specific. Here are a few examples of affirmation. You were very courageous to speak up for what you thought was right. You know what's best for you and you aren't going to be easily swayed. You showed a lot of patience in the way you waited until he finished speaking. It was hard, yet your efforts to not drink on the weekend paid off. Thank you for taking the time to talk with me today. 5 OARS: Reflective Listening "What people really need is a good listening to." – Mary Lou Casey "Good listening is fundamental to MI. The particular skill of reflective listening is one to learn first because it is so basic to all four processes of MI. It takes a fair amount of practice to become skillful in this way of listening so that reflections come more naturally and easily." [p. 48] Reflective listening is the skill of "bending back" to people what we hear them saying in an effort to understand "where they're coming from." In other words, to see the world through the other person's eyes. This kind of listening means giving a person your full attention. We do this with our words, actions, and body language. Reflective listening is a special gift we can offer to others in both our work and personal lives. Reflective listening takes the conversation to a deeper level. This is especially true of reflective statements that go beyond repeating what was said by making a reasonable guess about the person's meaning. Such statements "have the important function of deepening understanding by clarifying whether one's guess is accurate. Reflective statements also allow people to hear again the thoughts and feelings they are expressing, perhaps in different words, and ponder them. Good reflective listening tends to keep the person talking, exploring, and considering. It is also necessarily selective, in that one chooses which aspects to reflect from all that the person has said." [p. 34] Forming reflections requires the ability to think reflectively. Since words can have multiple meanings, and people don't always say exactly what they mean, it is useful to regard people's statements as a "first draft." In other words, rather than assuming what someone means, check it out. Because reflections are statements, not questions, the inflection usually turns down at the end. For example, notice the difference between: "You don't think your drinking is a problem?" "You don't think your drinking is a problem." Some reflective statements basically repeat or slightly rephrase what a person has said. These simple reflections can convey basic understanding and help the flow of the conversation. However, they add little or no meaning to what the person said, and can stop the conversation from going to a deeper level. For example: Statement: I'm feeling pretty depressed today. Response: You're feeling depressed./You're feeling kind of down./Pretty depressed… Complex reflections add meaning or emphasis to what someone has said by making a guess about what is unspoken. Complex reflections tend to help people think more about their situation. When first learning to use complex reflections, it can feel a bit strange. However, when you get used to it, such reflections communicate real understanding. For example: Statement: I'm feeling pretty depressed today. Response: You're not feeling like your usual self./You wish you had more energy and interest in doing things./It sounds like something has happened since we last talked. OARS: Summaries A summary is a statement that draws together two or more things that someone has said previously. It is basically a paragraph of selected reflective statements. Deciding what to choose to include in a summary depends on the situation. However, usually you want to pick the things that move in the direction of change – kind of like picking the tastiest chocolates from a box of candy. Summaries can be offered at various times in a conversation to draw ideas together and guide the conversation. Summaries, like the other OARS skills, are used throughout the four processes of MI. Particularly in the engaging and focusing processes, summaries show that you have been listening carefully and that you value what the person has said. They also provide an opportunity for asking the person to fill in what you have missed. In the evoking process, summaries are often used to emphasize things that support a person's change goal. Summaries can have different purposes. Collecting summaries pull together "in one basket" various statements the person has made. Linking summaries connect what the individual has said with something they said in a prior conversation. Transitional summaries are used as a wrap-up at the end of a conversation, or to create a bridge for shifting the conversation. In all three cases, emphasis is placed on shining a light on the persons change talk (see more on page 9). During the planning process of MI, summaries are generally used to recap the person's reasons for wanting to change and what they intend to do. This can help strengthen commitment to make the change. Below are some guidelines for developing and offering summaries. Remember to keep summaries brief and to the point. 1. Begin with a statement indicating you are making a summary. For example: Let me see if I understand so far… Here is what I've heard. Tell me if I've missed anything. 2. If the person is "feeling two ways" about changing, name both sides of the uncertainty in the summary. For example: On the one hand you . . . on the other hand . . ." 3. Highlight change talk you heard – statements indicating the person's desire, ability, reasons, need, and commitment to change. For example: You mentioned several reasons why you would want to make this change, including . . . 4. End with an invitation. For example: What would you add? Adapted from Motivational Interviewing, 3 rd edition by Miller & Rollnick, 2013 and handouts created by David B. Rosengren, Ph.D. Informing and Advising While MI is an inherently person-centered approach, this does not mean that information and suggestions are never offered. In MI, both parties are viewed as having expertise; thus, there may be occasions when this kind of input is appropriate, such as when a person requests it. However, information and suggestions are provided sparingly and not as a first line of response. There are two main differences as to how information and suggestions are offered in MI, as compared to being dispensed in an unsolicited, authoritative manner. The first is that it is offered only with permission from the person. Secondly, it is provided not as the "final word" but rather in the context of helping people come to their own conclusions about its relevance and value. It is often helpful to verbally acknowledge this with people. Intent of providing information and suggestions in MI * Not an attempt to convince people of the folly of their ways * Provides an opportunity to express concerns and help the individual move further along in the process of change * Can help a person come to a decision A few considerations * It's all right to express your concerns * Focus on helping the person evaluate options * There are many pathways to change; your way may not be the way of another * Offer information and advice, don't impose it Suggested method: Evoke-Provide-Elicit (E-P-E) Elicit * Ask what the individual already knows about the topic/issue * Ask permission to provide input – e.g., "Would it be all right if I share some ideas/impressions/possible options with you?" * Inquire what she or he would like to know Provide * Offer small dose of information or advice in a kind, nonjudgmental manner Elicit * Ask for the person's response – e.g., "I wonder what you think of that" * Recognize and affirm it is the individual's decision to make – e.g., "Of course, you're the only one who can make this decision." * Emphasize change talk, provide affirmations, and instill hope. Adapted from Motivational Interviewing, 3 rd edition by Miller & Rollnick, 2013 and handouts created by David B. Rosengren, Ph.D. Evoking Change Talk Change talk refers to anything someone says that "favors movement toward a particular change goal." Evoking, or "calling forth," change talk helps people come up with their own reasons to change. This is far better than someone else trying to convince them to change, which often makes people defensive and argue against changing. As a worker you can use the OARS skills (Open questions, Affirmations, Reflective listening, and Summaries) to "ask for" and respond to change talk. Notice that change talk comes in different flavors that form the phrase DARN-CAT. Preparatory Change Talk – "thinking about changing" Desire – I want to, I would like to, I wish, I hope Ability – I can, I could, I am able to Reasons – It would help me, I'd be better off if Need – I need to, I have to, something has to change Mobilizing Change Talk – "taking action" Commitment– I will, I promise, I give you my word Activation – I'm willing to, I am ready to, I am prepared to Taking steps – I cut back on my weekend drinking Methods for Evoking Change Talk Asking evocative questions What worries you about your current situation? Why would you want to make this change? How might you go about it, in order to succeed? Using the importance ruler (also use regarding person's confidence to change) On a scale of 0 to 10, how important is it for you to make this change? Tell me about being at ___ compared to (several numbers lower)? What would it take to move from ___ to (next highest number)? And how I might I help you with that? Exploring extremes – What concerns you absolutely most about ____? What are the very best results you could imagine if you made a change? Looking back – What were things like before you began drinking more frequently? Looking forward – How would you like things to be different in the future regarding ____? Exploring goals and values – What's most important to you in life? What are the rules you'd say you live by? How does drinking fit with your personal goals? Responding to Discord What do you do when someone "pushes back" at you in a way that feels like it's personal? Maybe the person says, "Who are you to tell me what to do!" or "You don't really care about me!" Or, the individual refuses to talk. Or, perhaps agrees to do something, but then doesn't do it. When these things happen, you can be pretty sure that something's gone wrong in the relationship. In MI, we call this discord. This rift can occur for various reasons as noted below. Rather than placing blame on the individual, it is important for workers to look at their own behavior to consider what might be prompting the person to react. The presence of discord in the relationship is a signal to try a different approach. Common causes of discord in the relationship * The two of you have different goals * When either of you brings anger and frustration into the situation * You're trying to get the person to change * You're not truly listening, or you're making assumptions or interrupting * There's a lack of agreement about roles in the relationship Practitioner behaviors that tend to increase discord * Pushing too hard on the person to change * Criticizing, shaming, blaming; using negative emotions to get the person to change * Assuming you're the expert; not working collaboratively * Labeling; "that's because you're an alcoholic/addict" * Giving the impression that you "know what's best for the individual" * Being hurried Practitioner behaviors that tend to decrease discord * Using simple and complex reflective statements o "You're not sure you can trust me" o "You're wondering if I can help you" * Other responses o Affirming – "You've been doing this for a long time and know how to keep yourself safe." o Apologizing – "Sorry, I didn't mean to lecture you." o Shifting focus – "Maybe there's something else that would be more useful to talk about for now." o Emphasizing personal choice and control – "It is entirely up to you. This is your decision. No one else can make it for you." Adapted from Motivational Interviewing, 3 rd edition by Miller & Rollnick, 2013 Motivational Interviewing: A Guided Conversation Here is an outline of how a model MI conversation might flow. In this case, drinking is the focus. Of course, real life conversations rarely play out in such a straightforward manner. Note that the spirit and core skills of MI are applied throughout the four processes of MI. As a general guideline, it is useful to follow a basic rhythm of asking an open question followed by one or more reflections, before asking another question. ENGAGING Provide a warm welcome; offer a beverage; exchange small talk; make sure the person feels safe; show that you care; get to know the person as a person; be hopeful § "Hi. It's really good to see you. Would you like some juice or tea?" "How have things been going lately?" (Respond with reflective statements) FOCUSING Agree on what to talk about § "What's on your mind?" "You mentioned several things. Where shall we start?" "Would it be all right if we took a closer look at you and drinking?" (Reflect) EVOKING Explore ambivalence § "What does drinking do for you? What concerns, if any, do you have about it?"(Reflect) Elicit change talk § DESIRE (want, wish, like) "How would you like things to be different than they are now?" (Reflect) § REASONS (specific reasons for change) "If you were to cut back or stop drinking, what are some reasons you might do that?" (Reflect) § ABILITY (can, could, able) "How might you go about it in order to succeed?" (Reflect) § NEED (have to or important to - without stating specific reason) "How important is it to you to make this change?" (use 0-10 scaling question) (Reflect) PLANNING § TESTING THE WATER (readiness and confidence) "How ready are you to make this change?" "How confident are you to make this change?" (or use 0-10 scaling question) (Reflect) § COMMITMENT (will, plan to, intend to, going to, willing, ready, etc.) "What do you think you will do next?" "What is your plan?" "How can I help you with that?" (Reflect) MI Self-Appraisal Developed by Ken Kraybill based on Miller, W.R. & Rollnick, S., Motivational Interviewing: Helping People Change, 2013 MI Self Check for Practitioners Individuals I meet with would say that I… o Believe that they know what's best for themselves o Help them to recognize their own strengths o Am interested in helping them solve their problems in their own way o Am curious about their thoughts and feelings o Help guide them to make good decisions for themselves o Help them look at both sides of a problem o Help them feel empowered by my interactions with them Adapted from Hohman. & Matulich. Motivational Interviewing Measure of Staff Interaction, 2008 Selected Resources Arkowitz, H, Westra, H.A., & Miller WR, Rollnick S. (Eds.). (2015). Motivational Interviewing in The Treatment of Psychological Problems (2 nd edition). New York, NY: Guilford Press. Center for Substance Abuse Treatment. (1999). Enhancing Motivation for Change in Substance Abuse Treatment: Treatment Improvement Protocol (TIP) Series 35. Rockville, MD: DHHS Publication No. (SMA) 99-3354. Hohman, M. (2011). Motivational Interviewing in Social Work Practice. New York, NY: Guilford Press. Miller, W.R., & Rollnick, S. (2013). Motivational Interviewing: Helping People Change (3rd Ed.). New York, NY: Guilford Press. Miller, W.R., & Rose, G. (2009). Toward a Theory of Motivational Interviewing. American Psychologist, 64(6), 527-537. Naar-King, S., & Suarez, M. (2011). Motivational Interviewing with Adolescents and Young Adults. New York, NY: Guilford Press. Rollnick, S., Miller, W.R., & Butler, C. (2008). Motivational Interviewing in Health Care. New York, NY: Guilford Press. Rosengren, D.B. (2009). Building Motivational Interviewing Skills: A Practitioner Workbook. New York, NY: Guilford Press. Wagner CC, Ingersoll KS. (2012). Motivational Interviewing in Groups. New York, NY: Guilford Press. Website: www.motivationalinterviewing.org Zuckoff, Allan with Gorscak, B. (2015). Finding your Way to Change. New York, NY: Guilford Press.	<urn:uuid:0d7aaa44-8ae9-4064-bd4e-d758afddc695>	CC-MAIN-2018-30	http://schomeless.org/media/1134/myrtle-beach-mi-agenda_handouts-sept-19.pdf	2018-07-17T09:42:31Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-30/segments/1531676589634.23/warc/CC-MAIN-20180717090227-20180717110227-00473.warc.gz	326,930,209	5,904	eng_Latn	eng_Latn	0.90427	eng_Latn	0.998408	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 221, 1367, 4445, 6600, 8410, 11052, 14117, 16620, 18763, 20785, 22892, 24874, 25013, 26937 ]
Internal/External Competition Human Resources Officer (Grade V) Temporary Full Time Post (2 Year Fixed Term Contract) We are recruiting for a Human Resources Officer with immediate effect, to join our team in a busy and dynamic work environment. The responsibilities will cover a full range of HR generalist duties, providing a comprehensive administrative and specialist service to the HR Function with a focus on recruitment, HR systems, data and reporting. The NRH is undergoing a transformation and development of its facilities and services so this is an exciting opportunity for a driven and ambitious HR professional to grow your HR career and be part of the strategic development of the service to meet changing organisational needs. Requirements: * 3 rd level qualification in HR or related course and (ideally) CIPD membership * 3+ years related experience in HR functional area, HR Generalist or comparable role * Good working knowledge of Human Resource Best Practice / Industrial Relations / Irish Employment Law / Recruitment * Previous knowledge and experience of working with a HR/Payroll System, knowledge /experience with the CoreHR system advantageous * Excellent organisational, communication, administration and interpersonal skills * Strong team working skills and ability to liaise with all members of the HR Team, Senior Management and other stakeholders * Capacity for responsibility, accountability and individual initiative * Proficient in Microsoft Word, Excel, Access, Outlook and Microsoft Teams * Background in and knowledge of the Health Services Sector advantageous The appointment is full-time, temporary and in a pensionable capacity. Remuneration is in accordance with the Salary Scale approved by the Department of Health. ________________________________________________________________________________ Applicants for the above post should submit a letter of application and curriculum vitae not later than 12:00 noon on Monday 6 th December 2021 by email to [email protected]. A job description for the above post is available at www.nrh.ie/careers. Shortlisting will be carried out on the basis of the information supplied in your CV. The criteria for shortlisting are based on the requirements of the post as outlined above. Interviews are scheduled to take place on Thursday the 9 th of December 2021. A panel may be formed from those interviewed for future temporary full time and part time Human Resource Officer Positions. We are an Equal Opportunities Employer and support a smoke-free workplace policy.	<urn:uuid:4c9d80d2-4eee-40dc-9c68-46da14ec948c>	CC-MAIN-2021-49	https://www.nrh.ie/wp-content/uploads/2021/11/Adv-Human-Resources-Officer-Temp-FT-Nov-2021-2.pdf	2021-12-02T15:19:58+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2021-49/subset=warc/part-00163-eb7089cf-762b-4a3e-8cab-20b677c0d246.c000.gz.parquet	960,621,580	480	eng_Latn	eng_Latn	0.99602	eng_Latn	0.99602	[ "eng_Latn" ]	false	rolmOCR	[ 2564 ]
EU Settlement Scheme: EU, other EEA and Swiss citizens and their family members Version 27.0 # Contents \| Section \| Page \| \|------------------------------------------------------------------------\|------\| \| About this guidance \| 11 \| \| Application process \| 13 \| \| Cost of application \| 13 \| \| The best interests of a child \| 13 \| \| Contacts \| 14 \| \| Publication \| 14 \| \| Changes from last version of this guidance \| 14 \| \| Who can apply \| 16 \| \| EEA citizen \| 17 \| \| Relevant EEA citizen \| 17 \| \| Applications made before 1 July 2021 \| 17 \| \| Applications made on or after 1 July 2021 \| 19 \| \| Irish citizen \| 22 \| \| Non-EEA citizen \| 22 \| \| Family member of a relevant EEA citizen \| 23 \| \| Relevant EEA family permit case \| 23 \| \| Concession for certain children of a ‘relevant EEA family permit case’ \| 24 \| \| Joining family member of a relevant sponsor \| 25 \| \| Relevant naturalised British citizen \| 25 \| \| Family member of a dual British and EEA citizen (McCarthy cases) \| 27 \| \| Relevant person of Northern Ireland \| 28 \| \| Specified relevant person of Northern Ireland \| 28 \| \| Person exempt from immigration control \| 29 \| \| Frontier worker \| 30 \| \| Relevant document \| 30 \| \| Letter from the Secretary of State \| 32 \| \| Specified relevant document \| 32 \| \| Family member of a qualifying British citizen \| 32 \| \| Person with, or who had, a derivative or Zambrano right to reside \| 33 \| \| Making an application: validity \| 34 \| \| Required application process: applications made online \| 34 \| \| Required application process: applications made on paper application form \| 34 \| \| Required proof of identity and nationality \| 35 \| \| Required proof of entitlement to apply from outside the UK \| 36 \| Required biometrics ................................................................. 36 Required date ........................................................................... 37 Joining family members .......................................................... 39 Reasonable grounds for delay in making an application .................. 40 Repeat applications ............................................................... 42 Examples of reasonable grounds .................................................. 43 Exempt from immigration control ............................................ 43 Example 1 ............................................................................. 44 Example 2 ............................................................................. 45 Existing limited leave to enter or remain ........................................ 45 Example ............................................................................... 46 Indefinite leave to enter or remain held since before the end of the transition period .............................................................. 46 Children (including children in care and care leavers) ..................... 47 Example 1 ............................................................................. 48 Example 2 ............................................................................. 49 Physical or mental capacity and/or care or support needs ............... 49 Example 1 ............................................................................. 50 Example 2 ............................................................................. 50 Serious medical condition or significant medical treatment ............ 50 Example ............................................................................... 51 Abusive or controlling relationship or situation ............................. 51 Example ............................................................................... 52 Served or serving a sentence of imprisonment .............................. 53 Example ............................................................................... 53 Visited the UK since 31 December 2020 ....................................... 53 Example ............................................................................... 54 Circumstances which will not generally constitute reasonable grounds for delay in making an application ........................................ 54 Example 1 ............................................................................. 56 Example 2 ............................................................................. 56 Joining family members and specified enforcement case ............... 56 Checking for evidence of illegal entry or irregular arrival ............ 57 Breach of deportation order .......................................................... 58 Breach of the immigration laws .................................................... 59 Use of deception (including deception by another person) .............. 59 Validity consideration .................................................................. 60 \| Topic \| Page \| \|----------------------------------------------------------------------\|------\| \| Not using the required paper application form \| 60 \| \| Fraudulent identity document \| 61 \| \| Non-EEA passport for EEA citizen \| 61 \| \| No biometric residence card as claimed \| 61 \| \| Biometric residence card lost, stolen or expired by more than 18 months \| 61 \| \| Reasonable grounds for the delay in applying \| 62 \| \| Invalid sponsor for a joining family member application \| 63 \| \| Void applications \| 65 \| \| Certificate of application \| 65 \| \| Multiple applications \| 65 \| \| Automated conversion from pre-settled to settled status \| 67 \| \| Further applications \| 67 \| \| Alternative evidence of identity and nationality or of entitlement to apply from outside the UK \| 69 \| \| Circumstances where alternative evidence may be accepted \| 70 \| \| Document unobtainable from national authority \| 70 \| \| Document exists but cannot be produced \| 70 \| \| Refugee status or humanitarian protection \| 71 \| \| Other reasons document cannot be obtained or produced \| 71 \| \| Other supporting information or evidence \| 73 \| \| Irish citizens \| 74 \| \| Withdrawing an application \| 75 \| \| Requesting to withdraw an application \| 75 \| \| Requesting to withdraw online \| 75 \| \| Requesting to withdraw by post \| 75 \| \| Withdrawn applications \| 75 \| \| Date of application: original application \| 76 \| \| Confirmation of withdrawal \| 76 \| \| Travel outside the Common Travel Area \| 76 \| \| Variation of applications \| 78 \| \| Making an application: eligibility \| 79 \| \| EEA citizens \| 79 \| \| Documented right of permanent residence \| 79 \| \| Indefinite leave to enter or remain held since before the end of the transition period \| 81 \| \| Continuous qualifying period of 5 years \| 81 \| \| Ceased activity \| 82 \| \| Topic \| Page \| \|----------------------------------------------------------------------\|------\| \| Child under the age of 21 \| 83 \| \| Continuous qualifying period of less than 5 years \| 85 \| \| Eligibility: family members of a relevant EEA citizen \| 87 \| \| Who can apply as a family member of a relevant EEA citizen? \| 87 \| \| Documented right of permanent residence \| 88 \| \| Indefinite leave to enter or remain held since before the end of the transition period \| 89 \| \| Continuous qualifying period of 5 years \| 90 \| \| Child under the age of 21 \| 91 \| \| The relevant EEA citizen has ceased activity \| 93 \| \| The relevant EEA citizen has died \| 97 \| \| A family member who has retained the right of residence \| 98 \| \| Continuous qualifying period of less than 5 years \| 101 \| \| Eligibility: joining family members of a relevant sponsor \| 104 \| \| Who can apply as a joining family member of a relevant sponsor? \| 104 \| \| Relevant sponsor \| 106 \| \| Not in the UK as a visitor \| 109 \| \| Continuous qualifying period of 5 years \| 110 \| \| Child under the age of 21 \| 111 \| \| The relevant sponsor has ceased activity \| 114 \| \| The relevant sponsor has died \| 117 \| \| A family member who has retained the right of residence \| 118 \| \| Continuous qualifying period of less than 5 years \| 121 \| \| Assessing family relationship \| 124 \| \| Spouse \| 124 \| \| Civil partner \| 125 \| \| Specified spouse or civil partner of a Swiss citizen \| 126 \| \| Durable partner \| 126 \| \| Resident in the UK by 11pm on 31 December 2020 \| 127 \| \| Joining on or after 1 January 2021 \| 128 \| \| Example \| 129 \| \| Civil partnership, durable partnership or marriage of convenience \| 130 \| \| Child under the age of 21 \| 130 \| \| Child aged 21 or over \| 133 \| \| Family relationship \| 133 \| \| Dependency \| 134 \| \| Example 1 \| 135 \| \| Topic \| Page \| \|----------------------------------------------------------------------\|------\| \| Example 2 \| 135 \| \| Example 3 \| 135 \| \| Dependent parent \| 136 \| \| Dependency \| 136 \| \| Example 1 \| 138 \| \| Family relationship \| 138 \| \| Dependent relative \| 139 \| \| Family members who hold pre-settled status based on dependency \| 141 \| \| Other evidence \| 141 \| \| Family members of the people of Northern Ireland \| 148 \| \| Specified relevant person of Northern Ireland \| 151 \| \| Family members of persons exempt from immigration control \| 152 \| \| Family members of frontier workers \| 153 \| \| Applications in respect of children \| 155 \| \| Referral to Children’s Services or other agencies \| 155 \| \| Requesting further information or evidence \| 156 \| \| Enquiries with the parent, guardian or other third parties \| 157 \| \| Making a referral \| 158 \| \| Deciding the application \| 158 \| \| Children adopted from outside the UK \| 158 \| \| Applicants aged over 18 and under 21 \| 160 \| \| Applications in respect of adults with mental capacity issues and / or care or support needs \| 161 \| \| Applications made on behalf of an adult with mental capacity issues and/or care or support needs \| 161 \| \| Power of Attorney \| 162 \| \| Court appointed authorisations \| 163 \| \| England and Wales: Deputy appointed by the Court of Protection \| 163 \| \| Scotland: Guardian or Intervener appointed by the Sheriff Court \| 163 \| \| Northern Ireland: Controllers appointed by the Office of Care and Protection \| 164 \| \| Legal guardianship \| 164 \| \| Applications made by another appropriate third party \| 164 \| \| Suitability \| 166 \| \| Qualifying residence \| 172 \| \| Continuous qualifying period \| 172 \| \| COVID-19 \| 177 \| \| Crown servants and HM Forces personnel \| 179 \| Crown Dependencies ........................................................................................................ 180 Overseas Territories ....................................................................................................... 180 Automated checks ........................................................................................................... 181 Automated conversion from pre-settled to settled status ............................................. 182 Consideration of applications: ILE or ILR .................................................................... 183 Supervening event ......................................................................................................... 184 Permanent residence (PR) document holders .............................................................. 185 Requirements .................................................................................................................. 185 Relevant evidence .......................................................................................................... 186 Decision .......................................................................................................................... 186 Scenario 1 ....................................................................................................................... 187 Scenario 2 ....................................................................................................................... 187 Holders of indefinite leave to enter (ILE) or indefinite leave to remain (ILR) held since before the end of the transition period ........................................................................ 188 Requirements .................................................................................................................. 188 Relevant evidence .......................................................................................................... 188 Applicants unable to provide evidence of ILE or ILR .................................................. 189 Decision .......................................................................................................................... 190 Scenario 1 ....................................................................................................................... 190 Scenario 2 ....................................................................................................................... 191 Applicant has completed a continuous qualifying period of 5 years .......................... 192 Requirements .................................................................................................................. 192 Relevant evidence .......................................................................................................... 193 Decision .......................................................................................................................... 193 Scenario 1 ....................................................................................................................... 194 Scenario 2 ....................................................................................................................... 194 A relevant EEA citizen who has ceased activity ............................................................ 195 Requirements .................................................................................................................. 195 Retired ............................................................................................................................ 195 Relevant evidence .......................................................................................................... 195 Permanent incapacity ..................................................................................................... 196 Relevant evidence .......................................................................................................... 196 Worker or self-employed person who has retained a place of residence .................... 197 Relevant evidence .......................................................................................................... 197 Decision .......................................................................................................................... 198 Scenario 1 ....................................................................................................................... 198 Scenario 2 ....................................................................................................................... 198 Scenario 3 ......................................................................................................................... 198 Family member of a relevant EEA citizen who is a person who has ceased activity ........................................... 200 Requirements .................................................................................................................. 200 Relevant evidence ............................................................................................................ 202 Decision ............................................................................................................................. 203 Scenario 1 .......................................................................................................................... 203 Scenario 2 .......................................................................................................................... 203 Family member of a relevant EEA citizen who has died .................................................................................. 205 Requirements .................................................................................................................. 205 Relevant evidence ............................................................................................................ 205 Decision ............................................................................................................................. 206 Scenario 1 .......................................................................................................................... 206 Scenario 2 .......................................................................................................................... 206 Child under the age of 21 of a relevant EEA citizen or of their spouse or civil partner ........................................ 207 Relevant evidence ............................................................................................................ 209 Decision ............................................................................................................................. 211 Scenario 1 .......................................................................................................................... 211 Scenario 2 .......................................................................................................................... 211 Family member who has retained the right of residence .................................................................................. 213 Evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor) .................................. 213 The relevant EEA citizen (or qualifying British citizen or relevant sponsor) has died ........................................ 215 Requirements .................................................................................................................. 215 Relevant evidence ............................................................................................................ 215 A child of a relevant EEA citizen (or qualifying British citizen or relevant sponsor) who has died or ceased to reside in the UK (or of their spouse or civil partner). 215 Requirements .................................................................................................................. 215 Relevant evidence ............................................................................................................ 216 A parent with custody of a child of a relevant EEA citizen or qualifying British citizen (or of their spouse or civil partner) ........................................................................................................ 216 Requirements .................................................................................................................. 216 Relevant evidence ............................................................................................................ 217 The marriage or civil partnership with a relevant EEA citizen (or qualifying British citizen or relevant sponsor) has been terminated ........................................................................................................ 217 Requirements .................................................................................................................. 217 Relevant evidence ............................................................................................................ 218 A relevant family relationship with a relevant EEA citizen (or with a qualifying British citizen or relevant sponsor) has broken down permanently as a result of domestic violence or abuse ........................................................................................................ 219 Requirements .................................................................................................................................................. 219 Relevant evidence ........................................................................................................................................... 220 Joining family member of a relevant sponsor who has completed a continuous qualifying period of 5 years ........................................................................................................................................ 223 Requirements .................................................................................................................................................. 223 Relevant evidence ........................................................................................................................................... 223 Decision ............................................................................................................................................................ 224 Joining family member of a relevant sponsor who is a person who has ceased activity ........................................................................................................................................ 225 Requirements .................................................................................................................................................. 225 Relevant evidence ........................................................................................................................................... 227 Decision ............................................................................................................................................................ 228 Joining family member of a relevant sponsor who has died ........................................................................ 229 Requirements .................................................................................................................................................. 229 Relevant evidence ........................................................................................................................................... 229 Decision ............................................................................................................................................................ 230 Joining family member who is a child under the age of 21 years of a relevant sponsor or of their spouse or civil partner .............................................................................................................. 231 Requirements .................................................................................................................................................. 231 Relevant evidence ........................................................................................................................................... 234 Decision ............................................................................................................................................................ 235 Consideration of applications: 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) ........................................................................................................................................ 236 Relevant EEA citizens and family members ..................................................................................................... 236 Relevant evidence ........................................................................................................................................... 236 Joining family members of relevant sponsors .................................................................................................. 236 Relevant evidence ........................................................................................................................................... 237 Decision ............................................................................................................................................................ 237 Consideration of applications: eligibility ....................................................................................................... 239 Standard process ............................................................................................................................................. 239 Truncated process ......................................................................................................................................... 239 All cases ............................................................................................................................................................ 240 Consideration under Annex 2 of Appendix EU ............................................................................................... 241 Requesting further information or evidence and interviewing ........................................................................ 241 Failure to provide information or evidence or attend an interview ............................................................... 241 \| Section \| Page \| \|------------------------------------------------------------------------\|------\| \| Refusals \| 243 \| \| Evidence of residence \| 244 \| \| Evidence required to establish residence in the UK \| 244 \| \| Preferred evidence of residence \| 244 \| \| Alternative evidence of residence \| 245 \| \| Cancellation, curtailment and revocation of leave to enter or remain \| 247 \| \| Cancellation \| 247 \| \| Curtailment \| 248 \| \| Revocation \| 248 \| \| Right of appeal \| 250 \| About this guidance This guidance tells you how, from 9 April 2025, to consider applications made under the EU Settlement Scheme (EUSS), contained in Appendix EU to the Immigration Rules. You must consider applications in line with the Immigration Rules and guidance in force at the date of decision on the application. The EU Settlement Scheme provides a basis, consistent with the Withdrawal Agreement with the European Union reached on 17 October 2019 and with the citizens’ rights agreements reached with the other European Economic Area (EEA) countries and Switzerland, for EEA and Swiss citizens resident in the UK by the end of the transition period at 11pm on 31 December 2020, and their family members, to apply for the UK immigration status which they require in order to remain here after 30 June 2021. Those agreements now have effect in UK law through the European Union (Withdrawal) Act 2018, as amended by the European Union (Withdrawal Agreement) Act 2020. The immigration status granted under the EU Settlement Scheme is either indefinite leave to enter (ILE) (where the application is made outside the UK) or indefinite leave to remain (ILR) (where the application is made within the UK) – also referred to for the purposes of the scheme as ‘settled status’ – or 5 years’ limited leave to enter (LTE) (where the application is made outside the UK) or 5 years’ limited leave to remain (LTR) (were the application is made within the UK) – also referred to as ‘pre-settled status’. Where eligibility for the EU Settlement Scheme is concerned, paragraph 1.15 of the Statement of Intent on the EU Settlement Scheme published on 21 June 2018 states: The Home Office will work with applicants to help them avoid any errors or omissions that may impact on the application decision. Caseworkers will have scope to engage with applicants and give them a reasonable opportunity to submit supplementary evidence or remedy any deficiencies where it appears a simple omission has taken place. A principle of evidential flexibility will apply, enabling caseworkers to exercise discretion in favour of the applicant where appropriate, to minimise administrative burdens. User-friendly guidance will be available online to guide applicants through each stage of the application process. This guidance for caseworkers has been developed to support that approach. The EU Settlement Scheme will be referred to as ‘the scheme’ for the purposes of this guidance. Where this guidance refers to the ‘specified date’, this means 11pm Greenwich Mean Time (GMT) on 31 December 2020 (except where the applicant is a family member of a qualifying British citizen, or a relevant EEA family permit case, as a different date applies in respect of those groups). The EU Settlement Scheme also provides a basis for certain family members of qualifying British citizens who have returned with them to the UK after living together in an EEA country or Switzerland to apply for the UK immigration status which the family member requires in order to remain here. For guidance on applications from the family member of a qualifying British citizen, including on the meaning in that context of ‘specified date’ and ‘required date’, see EU Settlement Scheme: Family member of qualifying British citizen. In the case of a relevant EEA family permit case, ‘specified date’ means, for the purposes specified in that definition, 11:59pm GMT on the date they arrived in the UK. Where this guidance refers to the ‘EEA Regulations’, it means (as defined in Annex 1 to Appendix EU): - (where relevant to something done before 11pm GMT on 31 December 2020) the Immigration (European Economic Area) Regulations 2016 (as they had effect immediately before that date and time) - (where relevant to something done after 11pm GMT on 31 December 2020 and before 1 July 2021) the Immigration (European Economic Area) Regulations 2016 (as, despite the revocation of those Regulations, they continued to have effect, with specified modifications, by virtue of the Citizens’ Rights (Application Deadline and Temporary Protection) (EU Exit) Regulations 2020) - (where relevant to something done on or after 1 July 2021) the Immigration (European Economic Area) Regulations 2016 (as they had effect immediately before they were revoked and, where the context requires it, on the basis that those Regulations had not been revoked) Where this guidance refers to ‘immigration status in the UK or the Islands’, this means (as defined in Annex 1 to Appendix EU): - indefinite or limited leave to enter or remain in the UK or the Islands under or outside the relevant Immigration Rules - exemption from immigration control - the entitlement to reside in the UK or the right of permanent residence in the UK under regulations 13 to 15 of the EEA Regulations - the entitlement to reside in the Islands or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man Where this guidance refers to ‘the Islands’, this means (as defined in Annex 1 to Appendix EU): - the Bailiwick of Guernsey, the Bailiwick of Jersey or the Isle of Man Where this guidance refers to ‘the UK and Islands’, this means (as defined in Annex 1 to Appendix EU): - the UK and the Islands taken together Application process Applicants must apply by using the required application process. Other than for proof of their identity and nationality or entitlement to apply from outside the UK, applicants may submit a photocopy, photograph or scanned digital image of any required evidence. You can require that they submit the original document or documents where you have reasonable doubt as to the authenticity of the copy submitted. Guidance for EUSS applicants in or outside the UK affected by restrictions associated with the coronavirus (COVID-19) pandemic is available at: [Coronavirus (COVID-19): EU Settlement Scheme – guidance for applicants](#). Also consult operational instructions on any measures in place as a result of COVID-19, in conjunction with this guidance. Cost of application There is no fee for an application under the EU Settlement Scheme. Applicants under the scheme are not required to pay the Immigration Health Surcharge. Where the application is made within the UK, a non-EEA citizen applicant required to enrol their biometrics may be required to pay a fee to a commercial partner to do so, depending on the location of the centre they choose to use (several across the UK are free to use). The best interests of a child The duty in section 55 of the [Borders, Citizenship and Immigration Act 2009](#) to have regard to the need to safeguard and promote the welfare of a child under the age of 18 in the UK, together with Article 3 of the UN Convention on the Rights of the Child, means that consideration of the child’s best interests must be a primary consideration in immigration decisions affecting them. This guidance and the Immigration Rules it covers form part of the arrangements for ensuring that we give practical effect to these obligations. Where a child or children in the UK will be affected by the decision, you must have regard to their best interests in making the decision. You must carefully consider all the information and evidence provided concerning the best interests of a child in the UK and the impact the decision may have on the child. Although the duty in section 55 only applies to children in the UK, the statutory guidance – [Every Child Matters – Change for Children](#) – provides guidance on the extent to which the spirit of the duty should be applied to children overseas. You must adhere to the spirit of the duty and make enquiries when you have reason to suspect that a child may be in need of protection or safeguarding, or presents welfare needs that require attention. In some instances, international or local agreements are in place that permit or require children to be referred to the authorities of other countries and you are to abide by these and work with local agencies in order to develop arrangements that protect children and reduce the risk of trafficking and exploitation. Further guidance can be found in paragraphs 2.34 to 2.36 of the statutory guidance. For further guidance on how to deal with applications concerning children see: Applications in respect of children. Contacts If you have any questions about the guidance and your line manager or senior caseworker cannot help you or you think that the guidance has factual errors, then email the EEA Citizens’ Rights & Hong Kong Unit. If you notice any formatting errors in this guidance (broken links, spelling mistakes and so on) or have any comments about the layout or navigability of the guidance then you can email the Guidance Rules and Forms team. Publication Below is information on when this version of the guidance was published: - version 27.0 - published for Home Office staff on 9 April 2025 Changes from last version of this guidance The guidance has been updated to take account in particular of: - the Court of Appeal judgment in R (Ali) v Secretary of State for the Home Department [2024] EWCA Civ 1546, which found that, where they were resident in the UK before the end of the transition period, the right to reside of a child aged over 21 or a dependent parent is not lost where they ceased to be dependent as a result of exercising their right to work in the UK - updated guidance where a child has been adopted from outside the UK - Statement of Changes in Immigration Rules HC 733, laid on 12 March 2025 Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Citizens’ Rights (Application Deadline and Temporary Protection) (EU Exit) Regulations 2020 Guidance for EUSS applicants in or outside the UK who have been affected by restrictions associated with coronavirus (COVID-19) Statement of changes to the Immigration Rules: HC 733 Section 55 of the Borders, Citizenship and Immigration Act 2009 Every Child Matters – Change for Children Who can apply The EU Settlement Scheme was launched at 7:00am on 30 March 2019, after several test phases. Applications from outside the UK under the EU Settlement Scheme have been possible since 7:00am on 9 April 2019. Applications under the EU Settlement Scheme by a ‘person with a Zambrano right to reside’ as defined in Annex 1 to Appendix EU have been possible since 1 May 2019. Applications under the EU Settlement Scheme by family members of a relevant person of Northern Ireland as defined in Annex 1 to Appendix EU have been possible since 24 August 2020. Applications under the EU Settlement Scheme by joining family members of a relevant sponsor as defined in Annex 1 to Appendix EU have been possible since 11:00pm on 31 December 2020. Applications under the EU Settlement Scheme by a dependent relative of a relevant European Economic Area (EEA) citizen, and joining family members of a relevant sponsor, where the relevant EEA citizen or relevant sponsor is a specified relevant person of Northern Ireland, have been possible since 1 July 2021. Where eligible, a person who is exempt from immigration control (for example, foreign diplomats, consular staff, posted members of foreign armed forces, members of staff of certain international organisations and certain family members of theirs) can apply for and be granted pre-settled or settled status under the EU Settlement Scheme whilst they remain a person exempt from immigration control. You must not treat an application to the EU Settlement Scheme from a person exempt from immigration control as void because the person is exempt. If a person applies whilst they are exempt from immigration control, you must treat them as if they were not exempt. This means you must consider the application in the same way as for other relevant EEA citizens or their family members. A person exempt from immigration control can also apply to the scheme, by the ‘required date’, once they cease to be exempt from immigration control, and in the meantime their non-exempt family members are able to apply. A person who is a British citizen, including a British citizen with dual nationality, has the right of abode in the UK, cannot be granted leave to enter or remain under the Immigration Act 1971 and therefore, if they make an application under the EU Settlement Scheme, this must be treated as void. Certain current Commonwealth citizens also have the right of abode in the UK and cannot be granted leave to enter or remain under the Immigration Act 1971. Therefore, if they make an application under the EU Settlement Scheme, this must be treated as void. Further information on the right of abode in the UK can be found at right of abode guidance. A person who holds valid indefinite leave to enter or indefinite leave to remain granted under Appendix EU may not be granted indefinite leave to enter or indefinite leave to remain again under Appendix EU. Therefore, if they make an application under the EU Settlement Scheme, this must be treated as void. A person whose indefinite leave to enter or indefinite leave to remain granted under Appendix EU has lapsed under article 13 of the Immigration (Leave to Enter and Remain) Order 2000 owing to their absence from the UK and Islands – for example, of more than 5 consecutive years where relevant circumstances covered by the 2000 Order do not apply – is not eligible for further leave under the EU Settlement Scheme. They can apply under Appendix Returning Resident to the Immigration Rules if they want to return to and settle in the UK. Further information can be found at Returning residents. EEA citizen An ‘EEA citizen’ is defined in Annex 1 to Appendix EU as a person who is (and, throughout any continuous qualifying period relied upon, was) either: - under sub-paragraph (a)(i), a national of Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden or Switzerland, and who, under sub-paragraph (a)(ii), is not also a British citizen - under sub-paragraph (b), a relevant naturalised British citizen (see Relevant naturalised British citizen) - under sub-paragraph (c), a national of a country listed in sub-paragraph (a)(i) and (where the applicant meets the criteria in paragraph 9 of Schedule 6 to the EEA Regulations as the family member (“F”) to whom that paragraph refers) a British citizen within the meaning of the person (P) to whom that paragraph refers (see Family member of a dual British and EEA citizen (McCarthy cases)) - under sub-paragraph (d), a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) Relevant EEA citizen Annex 1 to Appendix EU contains 2 definitions of ‘relevant EEA citizen’, depending on the date of the application under consideration. Applications made before 1 July 2021 Where, in respect of the application under consideration, the date of application by a relevant EEA citizen or their family member is before 1 July 2021, a ‘relevant EEA citizen’ is defined in Annex 1 to Appendix EU as either: - under sub-paragraph (a), an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) resident in the UK and Islands for a continuous qualifying period which began before the specified date • under sub-paragraph (b), an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands as described above, either: o has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) o would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application • under sub-paragraph (c), where the applicant is a family member of a relevant naturalised British citizen, an EEA citizen in accordance with sub-paragraph (b) of the definition of EEA citizen in Annex 1 to Appendix EU • under sub-paragraph (d), where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph, an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, and either: o resident in the UK and Islands for a continuous qualifying period which began before the specified date o who, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application • under sub-paragraph (e), where the applicant is a family member of a relevant person of Northern Ireland, an EEA citizen in accordance with sub-paragraph (d) of the definition in Annex 1 to Appendix EU and either: o resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date o who, having been resident in the UK and Islands as described above, and where they are a relevant person of Northern Ireland in accordance with sub-paragraph (a)(ii) of the definition in Annex 1 to Appendix EU (such as an Irish citizen), either has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application o who, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact (where they are a relevant person of Northern Ireland in accordance with sub-paragraph (a)(i) or (a)(iii) of the definition in Annex 1 to Appendix EU, such as a British citizen or a British citizen and an Irish citizen) that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - under sub-paragraph (f), where the applicant is the family member of a person exempt from immigration control, that person is either: - resident in the UK and Islands for a continuous qualifying period which began before the specified date - a person who, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - under sub-paragraph (g), where the applicant is their family member, a frontier worker For further guidance on sub-paragraph (c) see: Relevant naturalised British citizen. For further guidance on sub-paragraph (d) see: Family member of a dual British and EEA citizen (McCarthy cases). For further guidance on sub-paragraph (e) see: Family members of the people of Northern Ireland. For further guidance on sub-paragraph (f) see: Person exempt from immigration control. For further guidance on sub-paragraph (g) see: Frontier worker. Applications made on or after 1 July 2021 Where, in respect of the application under consideration, the date of application by a relevant EEA citizen or their family member is on or after 1 July 2021, a ‘relevant EEA citizen’ is defined in Annex 1 to Appendix EU as either: - under sub-paragraph (a), an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) resident in the UK and Islands for a continuous qualifying period which began before the specified date; and, where the applicant is their family member, the EEA citizen, having been resident in the UK and Islands as described above, has been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated - under sub-paragraph (b), an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) resident in the UK and Islands for a continuous qualifying period which began before the specified date; and, where the applicant is their family member, the EEA citizen, having been resident in the UK and Islands as described above, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (c), where the applicant is a family member of a person who falls within sub-paragraphs (a), (c) and (d) of the entry for ‘relevant naturalised British citizen’ in Annex 1 to Appendix EU, that relevant naturalised British citizen would, if they had made a valid application under Appendix EU before 1 July 2021, have, but for the fact that they are a British citizen, been granted: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (d), where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph, an EEA citizen (in accordance with sub-paragraph (c) of that definition in Annex 1 to Appendix EU) resident in the UK and Islands for a continuous qualifying period which began before the specified date; and the EEA citizen, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (e)(i), where the applicant is a family member of a relevant person of Northern Ireland, an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland in accordance with sub-paragraph (a)(ii) of the definition in Annex 1 to Appendix EU (such as an Irish citizen); and the EEA citizen, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (if had they made a valid application under Appendix EU before 1 July 2021), which would not have lapsed or been cancelled, revoked or invalidated before the date of application has been granted limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated would have been granted limited leave to enter or remain under paragraph EU3 of Appendix EU (if had they made a valid application under Appendix EU before 1 July 2021), which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (e)(ii), where the applicant is a family member of a relevant person of Northern Ireland, an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland in accordance with sub-paragraph (a)(i) or (a)(iii) of the definition in Annex 1 to Appendix EU (such as a British citizen or a British citizen and an Irish citizen); and the EEA citizen, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date, and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (f), where the applicant is the family member of a person exempt from immigration control, that person was resident in the UK and Islands for a continuous qualifying period which began before the specified date; and the person, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - under sub-paragraph (g) where the applicant is their family member, a frontier worker In addition, in relation to sub-paragraphs (a) to (f), as described above, of the definition of ‘relevant EEA citizen’ where, in respect of the application under consideration, the date of application is on or after 1 July 2021, it will suffice that the relevant EEA citizen is (or, as the case may be, for the relevant period was) resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date where the applicant either: - is (or, as the case may be, for the relevant period was) a family member of a relevant EEA citizen or a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen; and has completed a continuous qualifying period of 5 years under condition 3 in rule EU11 of Appendix EU - is a family member of a relevant EEA citizen or a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen; and otherwise meets the eligibility requirements for limited leave to enter or remain under condition 1 in rule EU14 of Appendix EU - relies on meeting condition 1, 2 or 6 in rule EU11 of Appendix EU For further guidance on sub-paragraph (c) of the definition see: Relevant naturalised British citizen. For further guidance on sub-paragraph (d) see: Family member of a dual British and EEA citizen (McCarthy cases). For further guidance on sub-paragraph (e) see: Family members of the people of Northern Ireland. For further guidance on sub-paragraph (f) see: Person exempt from immigration control. For further guidance on sub-paragraph (g) see: Frontier worker. Irish citizen An ‘Irish citizen’ is defined in Annex 1 to Appendix EU as a person who is an Irish citizen as a matter of Irish law. Irish citizens enjoy a right of residence in the UK that is not reliant on the UK’s membership of the EU. This means that Irish citizens do not need to apply for status under the scheme. Nonetheless, Irish citizens can make an application under the scheme, should they wish to do so. Their family members (who are not Irish citizens or British citizens and who do not have leave to enter or remain in the UK) will need to make an application for status under the EU Settlement Scheme, and they can do so whether or not the Irish citizen has done so. Non-EEA citizen A non-EEA citizen is defined in Annex 1 to Appendix EU as a person who is not an EEA citizen and is not a British citizen. To apply from outside the UK, they will need to provide the ‘required proof of entitlement to apply from outside the UK’. Family member of a relevant EEA citizen As set out in the definition in Annex 1 to Appendix EU of ‘family member of a relevant EEA citizen’, the categories of family member of a relevant EEA citizen who can apply are: - spouse - civil partner - durable partner (unmarried partnership akin to marriage or civil partnership) - child, grandchild or great-grandchild (including of the spouse or civil partner) - dependent parent, grandparent or great-grandparent (including of the spouse or civil partner) - dependent relative (including, in some cases, of the spouse or civil partner) A person can also apply: - on the basis of retaining the right of residence: see a family member who has retained the right of residence - as a person with a derivative right to reside - as a person with a Zambrano right to reside - as a family member of a qualifying British citizen To apply under the family member of a relevant EEA citizen provisions (save as a dependent relative of a specified relevant person of Northern Ireland or as a relevant EEA family permit case), an applicant must have been resident in the UK by the end of the transition period at 11pm GMT on 31 December 2020 on a basis which met the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU and thereafter not have broken the continuity of their residence. Relevant EEA family permit case The requirement that a person applying as a family member of a relevant EEA citizen must have been resident in the UK by the end of the transition period at 11pm GMT on 31 December 2020 on a basis which met the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU, does not apply where the applicant is a ‘relevant EEA family permit case’ as defined in Annex 1 to Appendix EU. Under that definition, a ‘relevant EEA family permit case’ is either: - under sub-paragraph (a)(i), a family member of a relevant EEA citizen who is a dependent relative or a durable partner who (in either case) arrived in the UK after 11pm GMT on 31 December 2020 and by 30 June 2021 with a valid EEA family permit issued under the EEA Regulations on the basis of a valid application made under the EEA Regulations before 11pm GMT on 31 December 2020 - under sub-paragraph (a)(ii), a family member of a relevant EEA citizen who is a dependent relative or (on the basis of a valid application made under the EEA Regulations before 11pm GMT on 31 December 2020) a durable partner who (in either case) arrived in the UK after 11pm GMT on 31 December 2020 with an entry clearance in the form of an EU Settlement Scheme family permit granted under Appendix EU (Family Permit) on the basis they met the definition in Annex 1 to that Appendix of ‘specified EEA family permit case’ - under sub-paragraph (b), a person with a derivative right to reside or a person with a Zambrano right to reside who (in either case) arrived in the UK after 11pm GMT on 31 December 2020 and by 30 June 2021 with a valid EEA family permit issued under the EEA Regulations on the basis of a valid application made under the EEA Regulations before 11pm GMT on 31 December 2020 - under sub-paragraph (c), a person with a derivative right to reside or a person with a Zambrano right to reside who (in either case) arrived in the UK after 11pm GMT on 31 December 2020 with an entry clearance in the form of an EU Settlement Scheme family permit granted under Appendix EU (Family Permit) on the basis they met the definition in Annex 1 to that Appendix of ‘specified EEA family permit case’ See the EU Settlement Scheme Family Permit and Travel Permit guidance for further information. In a ‘relevant EEA family permit case’, you may consider there are reasonable grounds for the person’s delay in making their application (where they do so after the 30 June 2021 deadline applicable to them) where they apply to the EU Settlement Scheme as soon as they reasonably can (and generally within 3 months) following their arrival in the UK. Concession for certain children of a ‘relevant EEA family permit case’ An application may be made, as a family member (dependent relative) of a relevant EEA citizen, for a child of a ‘relevant EEA family permit case’ where the child was granted an EU Settlement Scheme family permit outside Appendix EU (Family Permit) to accompany their parent or parents to the UK, or join them here, and either: - the child was born outside the UK before 11pm GMT on 31 December 2020 to a parent(s) who is a dependent relative who meets sub-paragraph (a) of the definition of a ‘relevant EEA family permit case’, but a valid EEA family permit application was not made for the child under the EEA Regulations before 11pm GMT on 31 December 2020 - the child was born outside the UK after 11pm GMT on 31 December 2020 to a parent(s) who is a dependent relative who meets sub-paragraph (a) of the definition of a ‘relevant EEA family permit case’, so a valid EEA family permit application could not be made for the child under the EEA Regulations before 11pm GMT on 31 December 2020 In either case: - they will be deemed to meet sub-paragraph (a)(i) of the definition of ‘dependent relative’ where the sponsoring person is concerned • the EU Settlement Scheme family permit granted to them outside Appendix EU (Family Permit) will be deemed to meet the requirement for such a document under sub-paragraph (b) of the definition of ‘dependent relative’ • the specified date, in sub-paragraph (a) of the definition of ‘continuous qualifying period’ (for the purposes of the references to such a period specified in sub-paragraph (c)(i) of the definition of ‘specified date’) and sub-paragraph (e) of the definition of ‘family member of a relevant EEA citizen’, will be treated as being 11:59pm GMT on the date they arrived in the UK • the application should be made as soon as reasonably practicable (and generally within 3 months) following their arrival in the UK Joining family member of a relevant sponsor As set out in the definition in Annex 1 to Appendix EU of ‘joining family member of a relevant sponsor’, the categories of joining family member of a relevant sponsor who can apply are: - spouse - civil partner - specified spouse or civil partner of a Swiss citizen - durable partner (unmarried partnership akin to marriage or civil partnership) - child, grandchild or great-grandchild (including of the spouse or civil partner) - dependent parent, grandparent or great-grandparent (including of the spouse or civil partner) An applicant needs to meet particular criteria to qualify under the joining family member of a relevant sponsor provisions. See [Who can apply as a joining family member of a relevant sponsor](#) for further detail. Their relationship with the relevant sponsor needs to have existed by the end of the transition period at 11pm GMT on 31 December 2020, unless they are a child, in certain circumstances, of the relevant sponsor (or of the relevant sponsor’s spouse or civil partner) or the specified spouse or civil partner of a Swiss citizen. Where a person granted pre-settled status under the EU Settlement Scheme as a joining family member of a relevant sponsor later applies for settled status and at that stage it is established by the evidence provided or otherwise available to you that they meet the requirements for settled status as a relevant EEA citizen or family member of a relevant EEA citizen (including that they were resident in the UK by the end of the transition period and maintained the required continuity of residence thereafter), they may be granted settled status on that basis instead. Relevant naturalised British citizen A family member of a relevant EEA citizen (or a joining family member of a relevant sponsor) can also apply where the relevant EEA citizen (or relevant sponsor) is a dual British and EEA citizen who exercised free movement rights in the UK prior to the acquisition of British citizenship and who retained their EEA nationality of origin after acquiring British citizenship. This reflects the Court of Justice of the European Union (CJEU) judgment in [Lounes](#). Such a ‘relevant naturalised British citizen’ is defined in Annex 1 to Appendix EU as either: - under sub-paragraph (a), an EEA citizen (in accordance with sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU) resident in the UK and Islands for a continuous qualifying period which began before the specified date - under sub-paragraph (b), an EEA citizen (in accordance with sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU) who, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application And, in addition, in either case the person also both: - under sub-paragraph (c), comes within paragraph (b) of the definition of “EEA national” in regulation 2(1) of the EEA Regulations - under sub-paragraph (d), meets the criteria contained in regulation 9A(2) or 9A(3) as the dual national (“DN”) to whom those provisions refer (save for the requirement in regulation 4(1)(c)(ii) and (d)(ii) of the EEA Regulations for comprehensive sickness insurance cover in the UK and regardless of whether, save in conditions 5 and 6 in the table in paragraph EU11 of Appendix EU and in conditions 2 and 3 in the table in paragraph EU11A, they otherwise remained a qualified person under regulation 6 of the EEA Regulations after they acquired British citizenship) To make a valid application, a family member of a relevant naturalised British citizen must apply using the relevant paper application form. In considering such an application, before assessing the family relationship, you must first be satisfied that the person on whom the applicant is relying as being a relevant EEA citizen is a relevant naturalised British citizen in accordance with the definition in Annex 1 to Appendix EU. You must be satisfied that that person: - has acquired British citizenship, for example, by the provision of a valid UK passport or naturalisation certificate - was an EEA citizen prior to also becoming a British citizen, for example, by the provision of an EEA passport or national identity card issued before they naturalised as a British citizen - has retained their EEA nationality, for example, by the provision of a valid EEA passport or national identity card And, in respect of the criteria in regulation 9A(2) or 9A(3) of the EEA Regulations, you must be satisfied that the person either: was a ‘qualified person’ under regulation 6(1) of the EEA Regulations at the time they acquired British citizenship and, where the applicant relies on meeting condition 5 or 6 in rule EU11 of Appendix EU or condition 2 or 3 in rule EU11A, has not lost the status of qualified person since they acquired British citizenship (see EEA Nationals: Qualified Persons) had acquired a right of permanent residence in the UK at the time they acquired British citizenship (see ‘Right to permanent residence for qualified persons section’ in EEA Nationals: Qualified Persons) If the applicant does not provide sufficient evidence that the person is a naturalised British citizen, you must check other information available, for example, information or a scanned copy of the person’s British passport held on Home Office records, before you contact the applicant to request they provide further evidence. Where you are satisfied that the person is a relevant naturalised British citizen, you must then consider the application as if it were from the family member of a relevant EEA citizen. See: Assessing family relationship. Family member of a dual British and EEA citizen (McCarthy cases) The CJEU judgment in McCarthy in 2011 found that a person who holds the nationality of the host EEA Member State (regardless of whether or not they hold dual nationality with another EEA Member State) and has never exercised their right of free movement does not benefit, and nor do their family members, from rights of residence under the Free Movement Directive. Transitional provisions were made in 2012 – which are now reflected in paragraph 9 of Schedule 6 to the EEA Regulations – to enable certain family members affected by the judgment to retain or obtain a residence document enabling them to remain in the UK. They will be either: - a person who on 16 July 2012 had the right of permanent residence in the UK under the EEA Regulations 2006 - a person residing in the UK on 16 July 2012 as the family member of a dual British and EEA citizen, and who held a valid registration certificate or residence card confirming this right on 16 October 2012 - they continue to be treated under the EEA Regulations as the family member of an EEA citizen for as long as they continue to be the family member of that dual national - this also applies where a person had a right of residence on this basis on 16 July 2012 and had submitted an application for a document confirming this right on or before 16 October 2012 which had not been determined by that date (or which had been refused and was then successfully appealed); they continue to have such a right where a document was subsequently issued on the basis of that application (or that appeal) - a person who submitted an application for an EEA family permit as the family member of a dual British and EEA citizen before 16 July 2012, where the application resulted in an EEA family permit being issued (including where this document was issued following a successful appeal) and the person travelled to the UK within the 6 month validity period of that EEA family permit - they continue to be treated under the EEA Regulations as the family member of an EEA citizen for as long as they continue to be the family member of that dual national - they do not need to have applied for further confirmation of a right of residence in the UK. By virtue of sub-paragraph (d) of the applicable definition of ‘relevant EEA citizen’ in Annex 1 to Appendix EU (and of sub-paragraph (c)(ii) of the definition there of ‘EEA citizen’), such a person may be eligible for settled status or pre-settled status under Appendix EU as the family member of a relevant EEA citizen, where the other relevant requirements of that category are met. Relevant person of Northern Ireland A family member of a relevant EEA citizen (or a joining family member of a relevant sponsor) can also apply where the relevant EEA citizen (or relevant sponsor) is a relevant person of Northern Ireland (as defined in Annex 1 to Appendix EU). A ‘relevant person of Northern Ireland’ is a person who both: - is either: - a British citizen - an Irish citizen - a British citizen and an Irish citizen - was born in Northern Ireland and, at the time of the person’s birth, at least one of their parents was either: - a British citizen - an Irish citizen - a British citizen and an Irish citizen - otherwise entitled to reside in Northern Ireland without any restriction on their period of residence Specified relevant person of Northern Ireland From 1 July 2021, there is provision under Appendix EU for a dependent relative of a relevant EEA citizen, or for a joining family member of a relevant sponsor, to apply under the scheme where the relevant EEA citizen (or relevant sponsor) is a ‘specified relevant person of Northern Ireland’ (as defined in Annex 1 to Appendix EU). This is a person who is a relevant person of Northern Ireland in accordance with sub-paragraph (a)(i) or (a)(iii) of that definition in Annex 1 (such as they are a British citizen or a dual British and Irish citizen) and both: - the applicant is a non-EEA citizen - the applicant is either: - a joining family member of a relevant sponsor, where the person is their relevant sponsor and the applicant has satisfied you by relevant information or evidence provided with the application that, due to compelling practical or compassionate reasons, it was not possible for the person to return to the UK before the specified date while the applicant remained outside the UK a dependent relative and the person is their sponsoring person (in the definition of ‘dependent relative’ in Annex 1 to Appendix EU) and the applicant relies, as their relevant document as the dependent relative of their sponsoring person (as described in sub-paragraph (a)(iv) of the definition of ‘relevant document’ in Annex 1 to Appendix EU), on an EU Settlement Scheme Family Permit granted to them under Appendix EU (Family Permit) as a ‘dependent relative of a specified relevant person of Northern Ireland’, as defined in Annex 1 to that Appendix Person exempt from immigration control A ‘person exempt from immigration control’ is defined in Annex 1 to Appendix EU as a person who is: - a national of an EEA country or Switzerland - not a British citizen - exempt from immigration control in accordance with section 8(2), (3) or (4) of the Immigration Act 1971 Where eligible, a person who is exempt from immigration control (for example, foreign diplomats, consular staff, posted members of foreign armed forces, members of staff of certain international organisations and certain family members of theirs) can apply for and be granted pre-settled or settled status under the EU Settlement Scheme whilst they remain a person exempt from immigration control. Their exemption from immigration control will continue to operate for the purposes of entry to and residence in the UK. However, a grant of pre-settled or settled status under the EUSS will enable them to access their rights under the Citizens’ Rights Agreements from the date status is granted. You must not treat an application to the EU Settlement Scheme from a person exempt from immigration control as void because the person is exempt. If a person applies whilst they are exempt from immigration control, you must treat them as if they were not exempt. This means you must consider the application in the same way as for other relevant EEA citizens or their family members. A person exempt from immigration control can apply to the EU Settlement Scheme whilst they are exempt, or they can wait and apply within 90 days of the date on which they cease to be exempt (or later if they have reasonable grounds for missing that deadline). The relevant family members of a person exempt from immigration control are able to apply, regardless of whether the person exempt from immigration control has obtained EU Settlement Scheme status and regardless of whether that family member is also exempt. They can apply under the family member of a relevant EEA citizen provisions (if they were resident by 11pm GMT on 31 December 2020 on a basis which met the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU and thereafter have not broken the continuity of their residence) or where eligible as a joining family member. Frontier worker A family member of a relevant EEA citizen (or a joining family member of a relevant sponsor) can also apply where the relevant EEA citizen (or relevant sponsor) is a frontier worker (as defined in Annex 1 to Appendix EU). A frontier worker is a person who: - is a national of an EEA country or Switzerland - is not a British citizen - satisfies the Secretary of State by relevant evidence of this that they fulfil the relevant conditions of being a frontier worker set out in the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020, and that they have done so continuously since the specified date - has not been (and is not to be) refused admission to, or removed from, the UK by virtue of the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020, and is not subject to a relevant restriction decision as defined by regulation 2 of those Regulations See Frontier worker permit scheme for guidance about how to consider whether a person qualifies for a frontier worker permit issued under the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020. Relevant document Where this guidance makes reference to a ‘relevant document’ it means (as defined in Annex 1 to Appendix EU) either: - under sub-paragraph (a)(i)(aa), a family permit, registration certificate, residence card, document certifying permanent residence, permanent residence card or derivative residence card issued by the UK under the EEA Regulations on the basis of an application made under the EEA Regulations before the specified date or, in the case of a family permit (where the applicant is not a dependent relative), before 1 July 2021 (or, in any case, a letter from the Secretary of State, issued after 30 June 2021, confirming their qualification for such a document, had the route not closed after 30 June 2021) - under sub-paragraph (a)(i)(bb) (where the applicant is a family member of a relevant person of Northern Ireland and is a dependent relative or durable partner), other evidence which satisfies the Secretary of State of the same matters under Appendix EU concerning the relationship and (where relevant) dependency as a document listed in sub-paragraph (a)(i)(aa); for the purposes of this provision, where the Secretary of State is so satisfied, such evidence is deemed to be the equivalent of a document to which sub-paragraph (a)(i)(aa) refers - under sub-paragraph (a)(ii), a document or other evidence equivalent to a document to which sub-paragraph (a)(i)(aa) refers, and issued by the Islands under the relevant legislation there evidencing the entitlement to enter or reside in the Islands or the right of permanent residence in the Islands, through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man - under sub-paragraph (a)(iii), a biometric residence card issued by virtue of having been granted limited leave to enter or remain under Appendix EU - under sub-paragraph (a)(iv), an entry clearance in the form of an EU Settlement Scheme Family Permit granted under or outside Appendix EU (Family Permit) And, in addition, the document: - under sub-paragraph (b), was not subsequently revoked, or fell to be so, because the relationship or dependency had never existed or the relationship or (where relevant) dependency had ceased - under sub-paragraph (c) (subject to sub-paragraphs (d) and (e)), has not expired or otherwise ceased to be effective, or which remained valid for the period of residence relied upon - under sub-paragraph (d), for the purposes of the reference to ‘relevant document’ in the first sub-paragraph (b) of the definition of ‘dependent relative’ in Annex 1 to Appendix EU, in sub-paragraph (b)(i) of the definition there of ‘durable partner’, and in sub-paragraphs (e) and (f) of the definition there of ‘required evidence of family relationship’, the relevant document may have expired, where both of the following apply: - before it expired, the applicant applied for a further relevant document (as described above in relation to sub-paragraph (a)(i)(aa) or (a)(iii)) on the basis of the same family relationship as that on which that earlier relevant document was issued - that further relevant document was issued by the date of decision on the application under Appendix EU - under sub-paragraph (e), the relevant document may have expired where all of the following apply: - it is a family permit (as described under sub-paragraph (a)(i)(aa) summarised above) or an equivalent document or other evidence issued by the Islands (as described under sub-paragraph (a)(ii) summarised above) - it expired after the specified date and before the required date - the applicant arrived in the UK before 1 July 2021 and (unless they are a durable partner or dependent relative) after the specified date - under sub-paragraph (e), the relevant document may have expired where it is a specified relevant document Under transitional provisions in the EEA Regulations, a document issued under the 2000 or 2006 Regulations is to be treated as though issued under the EEA Regulations 2016. Where Appendix EU requires that a document, card or other evidence is valid (or remained valid for the period of residence relied upon), or has not been cancelled or invalidated or has not ceased to be effective, it does not matter that the person concerned no longer has the right to enter or reside under the EEA Regulations (or under the equivalent provision in the Islands), on which basis the document, card or other evidence was issued, by virtue of the revocation of those Regulations (or equivalent provision in the Islands). Letter from the Secretary of State The requirement that a person applying as a family member of a relevant EEA citizen hold a relevant document can be met by way of a letter from the Secretary of State, issued after 30 June 2021, confirming their qualification for a document under the EEA Regulations, had the route not closed after 30 June 2021. For example, where an extended family member (a durable partner or dependent relative, as defined in Annex 1 to Appendix EU) in the UK, who applied before the end of the transition period at 11pm on 31 December 2020 for a residence card under the EEA Regulations, would have been issued with one (including on appeal) but for the closure of that route after 30 June 2021. The applicant must continue to meet all other relevant requirements under Appendix EU to qualify for status under the EU Settlement Scheme. In the case of an applicant relying on such a letter, you may consider there are reasonable grounds for the person’s delay in making their application (where they do so after the 30 June 2021 deadline applicable to them) where they apply to the EU Settlement Scheme as soon as they reasonably can (and generally within 3 months) of receiving the letter. Specified relevant document Where this guidance makes reference to a ‘specified relevant document’, it means, as defined in Annex 1 to Appendix EU, either: - within the meaning of sub-paragraph (a)(i)(aa) of the definition of ‘relevant document’, a residence card, permanent residence card or derivative residence card issued by the UK under the EEA Regulations on the basis of an application made on or after 6 April 2015, which means that it is a biometric residence card, and it has not expired by more than 18 months at the date of application - a biometric residence card (as described in sub-paragraph (a)(iii) of the definition of ‘relevant document’) issued by virtue of having been granted limited leave to enter or remain under Appendix EU, which has not expired by more than 18 months at the date of application Family member of a qualifying British citizen For guidance on a ‘family member of a qualifying British citizen’, see EU Settlement Scheme: family member of a qualifying British citizen. This route under the scheme closed at 11:59pm on 8 August 2023 to new applications from those without status under it, except where they have been granted an EU Settlement Scheme family permit as such a family member. If so, they can apply under the scheme before the expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance or after the expiry of that leave to enter where there are reasonable grounds for their delay in making their application. Person with, or who had, a derivative or Zambrano right to reside For guidance on a ‘person with a derivative right to reside’ (Chen and Ibrahim/Teixeira cases), see EU Settlement Scheme: derivative right to reside. For guidance on a ‘person with a Zambrano right to reside’, see EU Settlement Scheme: person with a Zambrano right to reside. Guidance on a ‘person who had a derivative or Zambrano right to reside’ is also provided in those documents. The ‘person with a Zambrano right to reside’ route under the scheme closed at 11:59pm on 8 August 2023 to new applications from those without status under it, except where they have been granted an EU Settlement Scheme family permit as a ‘specified EEA family permit case’ on that basis. If so, they can apply under the scheme before the expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance or after the expiry of that leave to enter where there are reasonable grounds for their delay in making their application. Related content Persons exempt from control Frontier worker permit scheme caseworker guidance EU Settlement Scheme: family permits Related external links Appendix EU to the Immigration Rules EU Settlement Scheme: family and travel permits Immigration (European Economic Area) Regulations 2016 Lounes (C-165/16) Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020 Chen and Ibrahim/Teixeira cases Making an application: validity This section tells you how to check an application is valid under rule EU9 of Appendix EU. You must check all of the following: - it has been made using the required application process - the required proof of identity and nationality has been provided, where the application is made within the UK - the required proof of entitlement to apply from outside the UK has been provided, where the application is made outside the UK - the required biometrics have been provided - it has been made by the required date, where the date of application is on or after 9 August 2023 - the applicant, if they rely on being a joining family member of a relevant sponsor and where the date of application is on or after 9 August 2023, is not a specified enforcement case Required application process: applications made online Applicants must apply by using the relevant online application form, unless they are required or have been permitted to use a paper application form, and must follow the relevant process set out in that online application form for: - providing the required proof of identity and nationality or (as the case may be) the required proof of entitlement to apply from outside the UK - providing the required biometrics Required application process: applications made on paper application form Applicants must apply using either: - the required paper application form where this is mandated on GOV.UK - a paper application form where this has been issued individually to the applicant by the Secretary of State, via the relevant process for this set out on GOV.UK In both cases, the applicant must follow the relevant process set out in that form for: - providing the required proof of identity and nationality or the required proof of entitlement to apply from outside the UK - providing the required biometrics The required paper application form must be the most recent version of that form. Where the applicant applies using an older version of the required paper application form, the transitional arrangements set out in paragraph 34Y of Part 1 of the Immigration Rules apply. This means that where an application is made on the previous version of the specified form, no more than 21 days after the date on which the new version of the specified form is issued, the application will be deemed to have been made on the correct form. Where the applicant applies using a paper application form, it must be sent by pre-paid post or courier to the Home Office address specified on the form (where one is specified), or by email to the Home Office email address specified on the form (where one is specified). Required proof of identity and nationality For a European Economic Area (EEA) citizen making an application within the UK, this will be their valid passport or valid national identity card. For a non-EEA citizen making an application within the UK, this will be their valid passport, valid specified relevant document (their biometric residence card) or valid biometric immigration document (as defined in section 5 of the UK Borders Act 2007 and known as a biometric residence permit). Where a biometric residence card or biometric residence permit is provided, it must not have expired by more than 18 months at the date of application. Unless, in either case, you agree to accept alternative evidence of identity and nationality where the applicant is unable to obtain or produce the required document due to circumstances beyond their control or due to compelling or compassionate reasons. For further guidance, see [Alternative evidence of identity and nationality or of entitlement to apply from outside the UK](#). ‘Valid’ here means that the document is genuine and has not expired (in the case of a passport or national identity card) or been cancelled or invalidated at the point it is provided. If, by the date the application is submitted (in accordance with the ‘date of application’ as defined in Annex 1 to Appendix EU, where this is later than the date the document was provided) or considered, the document has expired (or, in the case of a biometric residence card or permit, it has expired by more than 18 months), the application remains a valid application for the purposes of rule EU9 of Appendix EU. France confirmed that the validity of the secure French national identity card (laminated), issued to people aged 18 or over from 1 January 2004 to 31 December 2013, was increased from 10 years to 15 years. Therefore, any such card is to be treated as having a validity period of 15 years, regardless of the expiry date printed on the card. Evidence of the EEA citizen having been granted status under the scheme will constitute sufficient evidence of that person’s identity, nationality and continuity of residence (for the period on the basis of which they were granted status) in any subsequent application under the scheme by a person relying on their family relationship to that EEA citizen. Required proof of entitlement to apply from outside the UK For an EEA citizen making an application from outside the UK, this will be their valid passport or valid national identity card. The valid national identity card must contain an interoperable biometric chip. Unless you agree to accept alternative evidence of entitlement to apply from outside the UK where the applicant is unable to obtain or produce the required document due to circumstances beyond their control or due to compelling or compassionate reasons. For further guidance, see Alternative evidence of identity and nationality or of entitlement to apply from outside the UK. For a non-EEA citizen making an application from outside the UK, this will be their valid specified relevant document, which must not have expired by more than 18 months at the date of application. Unless you agree to accept alternative evidence of entitlement to apply from outside the UK where the applicant is unable to produce the required document due to circumstances beyond their control or due to compelling or compassionate reasons. For further guidance, see Alternative evidence of identity and nationality or of entitlement to apply from outside the UK. ‘Valid’ here means that the document is genuine and has not expired (in the case of a passport or national identity card) or been cancelled or invalidated at the point it is provided. If, by the date the application is submitted (in accordance with the ‘date of application’ as defined in Annex 1 to Appendix EU, where this is later than the date the document was provided) or considered, the document has expired (or, in the case of a specified relevant document, it has expired by more than 18 months), the application remains a valid application for the purposes of rule EU9 of Appendix EU. France confirmed that the validity of the secure French national identity card (laminated), issued to people aged 18 or over from 1 January 2004 to 31 December 2013, was increased from 10 years to 15 years. Therefore, any such card is to be treated as having a validity period of 15 years, regardless of the expiry date printed on the card. Required biometrics Under the Immigration (Provision of Physical Data) Regulations 2006 (as amended), all applicants are required to provide a passport-style facial photograph of themselves (within the meaning of “biometric information” in section 15 of the UK Borders Act 2007) as part of the required application process. In addition, in the case of a non-EEA citizen making an application from within the UK without a specified relevant document, they will also be required to provide their fingerprints (also within the meaning of “biometric information”) as part of the required application process, unless the published guidance in force at the date of application states that they are not required to provide these. See the published biometric guidance for more details. Required date An application under Appendix EU, made on or after 9 August 2023, must be made by the required date. Where the date of application is before 9 August 2023, there is no validity (or eligibility) requirement for the application to have been made by the required date, and you can move on to the next stage of the validity consideration. Where this guidance refers to the ‘required date’, this means, where the date of application is on or after 9 August 2023, the deadline to apply to the EU Settlement Scheme, as set out below. Where the applicant does not have limited leave to enter or remain (pre-settled status under the EU Settlement Scheme) or indefinite leave to enter or remain (settled status under the scheme) granted under Appendix EU: - where the applicant relies on being a joining family member of a relevant sponsor (and the applicant is not a specified spouse or civil partner of a Swiss citizen, does not have other limited leave to enter or remain and is not exempt from immigration control) and the date on which the applicant first arrived in the UK after 31 December 2020 was on or after 1 April 2021: the deadline is within 3 months of the date on which they first arrived in the UK after 31 December 2020 (or, where they arrived in the UK with more than 3 months’ validity remaining on an EU Settlement Scheme family permit, before the expiry of their leave to enter provided that leave has not been cancelled, curtailed or invalidated), unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application - where the applicant relies on being a specified spouse or civil partner of a Swiss citizen and the date on which the applicant first arrived in the UK after 31 December 2020 was on or after 1 April 2021 (and the applicant does not have other limited leave to enter or remain and is not exempt from immigration control): the deadline is within 3 months of the date on which they first arrived in the UK after 31 December 2020 (or, where they arrived in the UK with more than 3 months’ validity remaining on an EU Settlement Scheme family permit, before the expiry of their leave to enter provided that leave has not been cancelled, curtailed or invalidated), and before 1 January 2026, unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application - where the applicant relies on being a joining family member of a relevant sponsor and the applicant is a child who is born or adopted in the UK on or after 1 April 2021 (or who, on or after that date, becomes subject in the UK to one of the guardianship orders or equivalent in sub-paragraphs (a)(iii) to (a)(xi) of the definition of ‘child’ in Annex 1 to Appendix EU): the deadline is within 3 months of the date on which they were born or adopted in the UK (or became subject in the UK to such an order), unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the delay in application being made - where the applicant relies on being a family member of a qualifying British citizen, the deadline is before 9 August 2023 (or, where they were granted an EU Settlement Scheme family permit as such a family member, before the expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance, provided that leave has not been cancelled, curtailed or invalidated, or after the expiry of that leave to enter where you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application) - where the applicant relies on being a person with a Zambrano right to reside, the deadline is before 9 August 2023 (or, where they were granted an EU Settlement Scheme family permit as a ‘specified EEA family permit case’ on that basis, before the expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance, provided that leave has not been cancelled, curtailed or invalidated, or after the expiry of that leave to enter where you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application) - in all other cases (save where a joining family member of a relevant sponsor is applying from outside the UK, is not caught by any of the other deadline provisions and may therefore apply at any time): the deadline is before 1 July 2021, unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application Reasonable grounds for missing the 30 June 2021 deadline (or the applicable deadline as a joining family member of a relevant sponsor) are deemed by Appendix EU to exist in the case of an applicant who either: - has limited leave to enter or remain granted under another part of, or outside, the Immigration Rules (except where such leave is, or was, as a visitor), which has not lapsed or been cancelled, curtailed or invalidated, and the date of expiry of that leave is on or after 1 July 2021 or the applicable deadline as a joining family member of a relevant sponsor – where this occurs, the deadline is before the date of expiry of their leave (which they have held, or did hold, continuously since before 1 July 2021 or the applicable deadline as a joining family member of a relevant sponsor), unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application - ceases to be exempt from immigration control on or after 1 July 2021 – where this occurs, the deadline is within 90 days beginning on the day on which they ceased to be exempt from immigration control, unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application A ‘visitor’ is defined in Annex 1 to Appendix EU as meaning a person granted permission under paragraphs 40-56Z, 75A-M or 82-87 of the Immigration Rules in force before 24 April 2015 or Appendix V on or after 24 April 2015 or Appendix V: Visitor after 9am on 1 December 2020, or a person to whom article 4 or 6 of the Immigration (Control of Entry through Republic of Ireland) Order 1972 applies, unless (in either case) both: - they are the spouse or civil partner of a relevant sponsor (as described in subparagraph (a)(i)(bb) of the entry for ‘joining family member of a relevant sponsor’ in Annex 1 to Appendix EU) or the specified spouse or civil partner of a Swiss citizen - their leave permitted them to marry or form a civil partnership in the UK with that relevant sponsor or with that Swiss citizen and they did so Where the applicant has, or had, limited leave to enter or remain granted under Appendix EU (pre-settled status under the EU Settlement Scheme), which has, or had, not lapsed or been cancelled, curtailed or invalidated, there is no deadline for them to apply for indefinite leave to enter or remain under Appendix EU (settled status under the scheme). They are however encouraged to apply for it as soon as they qualify. Where the applicant, having had pre-settled status under the EU Settlement Scheme, has indefinite leave to enter or remain under Appendix Victim of Domestic Abuse, there is no deadline for them to apply, if they wish, for settled status under the scheme once they are eligible for it based on their continuous residence in the UK. Joining family members Where the applicant relies on being a joining family member of a relevant sponsor and the date on which the applicant first arrived in the UK after 31 December 2020 was before 1 April 2021, the deadline for them to apply to the EU Settlement Scheme was before 1 July 2021, unless that deadline was not met and you are satisfied by information provided with the application that, at the date of application, there are reasonable grounds for the person’s delay in making their application. Where a deadline other than 30 June 2021 applies to the applicant and they indicate they are applying within that deadline, they are expected to provide evidence confirming this. A joining family member of a relevant sponsor who has indicated they are applying within 3 months of arriving in the UK is required to provide evidence to support that, such as: - an inbound travel ticket stamped when they arrived - an inbound ticket without proof of arrival (for example an e-ticket) alongside supplementary evidence confirming physical presence in the UK following their arrival (for example, a letter from a government department, public body or charity confirming a physical meeting) - a copy of a stamped page in their passport confirming their entry (where applicable) You must assess whether, based on the information and evidence available, including Advance Passenger Information data or any information recorded on Home Office systems, you are satisfied that the application has been made within 3 months of their first arrival in the UK after 31 December 2020. Where, in making their first application to the EU Settlement Scheme, a person applying as a joining family member of a relevant sponsor (and to whom the 30 June 2021 deadline does not apply) has failed to provide evidence to support their declaration that they are applying within 3 months of their first arrival in the UK after 31 December 2020 and you are not able to verify that declaration, then, if the application does not fall to be rejected on a different basis, you must write to the applicant (by email or post, taking account of their preference between these where this has been specified as part of the application) and give them 14 calendar days to provide that evidence. Where you write to them by first class post, you may assume delivery on the second business day after the date of postage. Where, in light of evidence or further information provided by the applicant within that 14-day period, you are satisfied that the application has been made within 3 months of the applicant’s first arrival in the UK after 31 December 2020 (or that there are reasonable grounds for their delay in making their application), you can move on to any remaining stage of the validity consideration. Otherwise, including where the applicant does not respond within that 14-day period, the application must be rejected as invalid under rule EU10(1) of Appendix EU. If the person considers that they can establish that they are applying within 3 months of their first arrival in the UK after 31 December 2020 (or that there are reasonable grounds for their delay in making their application), they can reapply to the scheme and provide the requisite information and evidence. Where an application for a joining family member of a relevant sponsor who is a child born in the UK (or adopted in the UK) is made within 3 months of their birth (or adoption), it is necessary only to provide their birth certificate or an identity document showing their date of birth (or, in the case of adopted child, the adoption certificate) to evidence that the application is being made within the deadline. A joining family member of a relevant sponsor who has indicated they are applying within 90 days of ceasing to be exempt from immigration control or before their current permission to stay in the UK expires, is expected to provide evidence they are applying within the deadline. Home Office systems may also be used to obtain or confirm this information. Reasonable grounds for delay in making an application In line with the Citizens’ Rights Agreements, there remains scope indefinitely for a person eligible for status under the EU Settlement Scheme to make a late application to the scheme where, in light of all the circumstances and reasons, there are reasonable grounds for their delay in making their application. Where a person who has failed to meet the deadline applicable to them wishes to apply to the EU Settlement Scheme on or after 9 August 2023, they must make an application under Appendix EU – online or on the relevant paper application form – and provide information and evidence with the application setting out their grounds for their delay in making their application. The guidance below describes some circumstances in which you may be satisfied that a person has reasonable grounds for their delay in making their application. It is not exhaustive and every case must be considered in light of its particular circumstances and the evidence provided. In all cases, the relevant test is whether, on the balance of probabilities and based on all the information and evidence provided by the applicant or otherwise available to you, you are satisfied that, at the date of application, there are reasonable grounds for the person’s delay in making their application under the EU Settlement Scheme. In general, the more time which has elapsed since the deadline applicable to the person under the scheme, the harder it will be for them to satisfy you that, at the date of application, there are reasonable grounds for their delay in making their application. The person must have reasonable grounds for their delay as a whole, and not simply for failing to meet the deadline applicable to them. Whether there are such reasonable grounds will depend on the particular circumstances of the case and the evidence provided. For example, where a person subject to the 30 June 2021 deadline for applying to the scheme had a serious illness (or was undergoing significant medical treatment) around the time of that deadline, that will normally have constituted reasonable grounds for them to have missed it. However, that will not in itself constitute reasonable grounds for their delay in making their application if they now seek to make a late application to the scheme. They will need to show they have reasonable grounds, in line with this guidance, for not having applied in the intervening period. Where a person misses their deadline for applying to the scheme as a joining family member of a relevant sponsor, as a person with other limited leave to enter or remain or exempt from immigration control or as an EUSS family permit-holding family member of a qualifying British citizen, you must take into account the extent of their delay in making their application and the reasons for it. In all cases, you must make an assessment of whether there are reasonable grounds for their delay in making their application. In addition, where a person misses their deadline for applying to the scheme as a joining family member of a relevant sponsor (within 3 months of the date – where this was on or after 1 April 2021 – on which they first arrived in the UK after 31 December 2020), because they have visited the UK since 31 December 2020 and left before the expiry of their leave to enter as a visitor (or of their EUSS family permit) and without making an application to the scheme, and they are now applying to the scheme for the first time to join or remain with their relevant sponsor in the UK, you must make an assessment of whether there are reasonable grounds for their delay in making their application. There will normally be such reasonable grounds where, for example, the applicant can show that circumstances are such that they now wish to stay in the UK with their relevant sponsor – for example, so that they can work here – and they have applied to the scheme as soon as they then reasonably can (and, where they have since returned to the UK, within 3 months of their latest arrival). In all cases, you will ordinarily need to see objectively verifiable evidence to be satisfied that there are reasonable grounds for the person’s delay in making their application to the scheme (for example, a letter from a doctor). Repeat applications Where a person has already made an in-time application to the EU Settlement Scheme, and this application has been refused, they will not normally be able to make a late application to the scheme based on there being reasonable grounds for their delay in making their application, as they previously met the deadline applicable to them. Consistent with the Citizens’ Rights Agreements, the decision on their in-time application will have considered whether they qualify for status under the EU Settlement Scheme, subject to any application for appeal or (where the eligible decision was made before 5 October 2023) administrative review. They will not normally therefore be able, after the deadline applicable to them, to make a further, valid application to the scheme. However, there may be occasional circumstances in which there may be reasonable grounds for a refused, in-time applicant to make a late, further application to the scheme, such as, for example, where there is a good reason related to an underlying physical or mental condition why they did not engage with our attempts to contact them following an earlier, in-time application to obtain further information or evidence as to their eligibility for status under the scheme. Whether there are such reasonable grounds will depend on the particular circumstances of the case and the evidence provided. A person may make a further application to the EU Settlement Scheme where an application resulted in a grant of status as a joining family member of a relevant sponsor and where, despite being given a reasonable opportunity to do so before that application was decided, the person now wishes to provide evidence that they are in fact a relevant EEA citizen or the family member of a relevant EEA citizen (such as that they were resident in the UK by the end of the transition period, they maintained the required continuity of residence thereafter and, where appropriate, there are reasonable grounds why they missed the 30 June 2021 deadline). As they already have status under the EU Settlement Scheme, there is no deadline for them to make such a further application, but they are encouraged to do so as soon as practicable. Where a person has already made a late application to the EU Settlement Scheme and this application has been refused, then they will not normally be able to establish that there are reasonable grounds for them to make a further late application to the scheme. Consistent with the Citizens’ Rights Agreements, the decision on their late application will have considered whether they qualify for status under the EU Settlement Scheme, subject to any application for appeal or (where the eligible decision was made before 5 October 2023) administrative review. However, there may be occasional circumstances in which there may be reasonable grounds for a refused late applicant to make a further late application to the scheme. This may include, for example, where there is a good reason related to an underlying physical or mental condition why they did not engage in the earlier late application with the need to provide information and evidence as to the reasonable grounds for their delay in making their application. Whether they can establish such reasonable grounds will, however, depend on the particular circumstances of the case and the evidence provided. Where a person resident in the UK before the end of the transition period on 31 December 2020 has already made an in-time or late application to the EU Settlement Scheme as a child aged over 21 or a dependent parent, and this application was refused as they were not considered dependent on the relevant EEA citizen (or on their spouse or civil partner) at the date of application (or at the end of the transition period where this was earlier) because they were in paid employment or self-employment, then, where there has not been undue further delay since this guidance was updated to this effect on 9 April 2025, there will be reasonable grounds for them to make a late (or further late) application to the scheme. In doing so, they can rely on the Court of Appeal judgment in R (Ali) v Secretary of State for the Home Department [2024] EWCA Civ 1546, which found that, where they were resident in the UK before the end of the transition period, the right to reside of a child aged over 21 or a dependent parent is not lost where they ceased to be dependent as a result of exercising their right to work in the UK. Where a person has already made a late application to the EU Settlement Scheme and this application has been rejected because they did not provide the information and evidence required to establish that there are reasonable grounds for their delay in making their application, then they can make a further late application to the scheme providing that information and evidence. Where a person has already made a late application to the EU Settlement Scheme and this application has been rejected because they did not use the required application process, they did not provide the required proof of identity and nationality (or of entitlement to apply from outside the UK) or they did not provide the required biometrics, they can make a further late application rectifying that error or omission where they also provide the information and evidence required to establish that there are reasonable grounds for their delay in making their application. Examples of reasonable grounds The section describes some circumstances in which you may be satisfied that a person has reasonable grounds, such as compelling practical or compassionate circumstances, for their delay in making their application under the EU Settlement Scheme. However, it is not exhaustive and every case must be considered in light of its particular circumstances and the evidence provided, though you may give more weight to evidence which is objectively verifiable. Exempt from immigration control A person exempt from immigration control can apply for and, where they qualify for it, be granted status under the EU Settlement Scheme while they remain a person exempt from immigration control. Alternatively, they can apply to the scheme by the required date once they cease to be exempt from immigration control and in the meantime their non-exempt family members are able to apply. Where an EEA citizen or their family member resident in the UK by the end of the transition period did not cease to be exempt from immigration control until after the 30 June 2021 deadline, or where a joining family member of a relevant sponsor does not cease to be so until more than 3 months after their arrival in the UK (or their birth, adoption or the making of a relevant guardianship order in the UK), Appendix EU deems this in itself to be reasonable grounds for their failure to meet that deadline if they choose to apply to the scheme after ceasing to be exempt from immigration control. Instead, the deadline for them to apply is within the period of 90 days beginning on the day on which they ceased to be exempt from immigration control. This is consistent with the period of 90 days during which, under section 8A of the Immigration Act 1971, a person ceasing to be exempt is treated as having leave to remain in the UK, during which they can apply for the immigration status required to continue living in the UK if they wish to do so. Beyond that 90-day period, they can make a late application to the scheme where you are satisfied, in line with this guidance, that, at the date of application, there are reasonable grounds for their delay in making their application. In all late applications based on exemption from immigration control, you will need to see official evidence from the applicant or other information available to you which confirms that exemption and the date on which it ceased. Relevant evidence of this could include either: - an exempt vignette - a letter from the Foreign, Commonwealth & Development Office confirming the period of exempt status - a letter from the relevant embassy, high commission or international organisation confirming the period of the person’s relevant employment and residence in the UK For more information on exemption from immigration control, see guidance on exempt persons. Example 1 A is an EEA citizen who has been resident in the UK since 2017 and who was working as an employee of an international organisation based in the UK and was exempt from immigration control while employed in that capacity. In August 2023, she changes employment and ceases to be exempt from immigration control as a result. In September 2023, A makes an application to the EU Settlement Scheme and provides a letter from her former employer setting out the period of her employment with them and official evidence of her exemption from immigration control while in that employment. These are reasonable grounds for A’s delay in making her application to the scheme. Example 2 B arrives in the UK in March 2023 as a joining family member. Following his arrival, he works here as an employee of a relevant international organisation and is thereby exempt from immigration control. In October 2023, B ends his employment with that organisation and therefore ceases to be exempt from immigration control. In January 2024, B reaches the end of the 90-day period after ceasing to be exempt from immigration control, in which he is treated as having leave to remain, and immediately makes an application to the EU Settlement Scheme. B provides a letter from his employer setting out the period of his employment with them and official evidence of his exemption from immigration control while in that employment. These are reasonable ground for B’s delay in making his application to the scheme. Existing limited leave to enter or remain Where an EEA citizen or their family member resident in the UK by the end of the transition period has limited leave to enter or remain granted under another part of the Immigration Rules (or outside the rules, for example, Discretionary Leave, or by one of the Islands, including under its EU Settlement Scheme), other than as a visitor, which does not expire until after the 30 June 2021 deadline (and which they have held, or did hold, continuously since before that deadline), or where a joining family member of a relevant sponsor has such leave, other than as a visitor, which does not expire until more than 3 months after their arrival in the UK, Appendix EU deems this in itself to be reasonable grounds for their failure to meet that deadline. Instead, the deadline for them to apply is before the date of expiry of their existing leave. This does not apply to limited leave to enter or remain extended by section 3C of the Immigration Act 1971, where the in-time application giving rise to the 3C leave was not made under EU Settlement Scheme. In those circumstances, the deadline applicable to the person is the date of expiry of their previous limited leave to enter or remain and they are required to provide reasonable grounds for their delay in applying to the scheme since that deadline. In the case of a joining family member of a relevant sponsor who was granted an EU Settlement Scheme family permit and arrives in the UK with more than 3 months’ validity remaining on the family permit, the deadline for them to apply will be the date of expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance. Where that leave to enter has been cancelled, curtailed or invalidated, they will not be able to meet the ‘required date’ requirement and their application must be rejected. In the case of a family member of a qualifying British citizen or a person with a Zambrano right to reside who was granted an EU Settlement Scheme family permit on that basis, the deadline for them to apply will be the date of expiry of the leave to enter granted to them by virtue of having arrived in the UK with that entry clearance. Where that leave to enter has been cancelled, curtailed or invalidated, they will not be able to meet the ‘required date’ requirement and their application must be rejected. A person can make a late application to the scheme after the date of expiry of their existing leave where you are satisfied, in line with this guidance, that, at the date of application, there are reasonable grounds for their delay in making their application, ordinarily based on objectively verifiable evidence. In all late applications based on previous limited leave to enter or remain, you will need to see official evidence from the applicant or other information available to you which confirms that period of leave and the date on which it expired. Example C is a non-EEA citizen joining family member of a relevant sponsor. C was granted a visa as a skilled worker under the Immigration Rules in January 2021, which expired in July 2023. He suffered a short illness in July 2023 which resulted in a period of hospitalisation following the expiry of that leave, which is evidenced by a doctor’s letter. C makes an application to the scheme in August 2023. These are reasonable grounds for C’s delay in making his application to the scheme. --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. --- Official – sensitive: end of section Indefinite leave to enter or remain held since before the end of the transition period Where an EEA citizen or their family member resident in the UK by the end of the transition period has indefinite leave to enter or remain granted under another part of (or outside) the Immigration Rules (or automatically under the Immigration Act 1971, or by one of the Islands, including under its EU Settlement Scheme) which they have held since before the end of the transition period at 11pm GMT on 31 December 2020, there is no requirement for them to apply to the EU Settlement Scheme. They may do so if they wish, for example, as an alternative to making a “no time limit” (NTL) application, because indefinite leave to enter or remain granted under the scheme (settled status) does not lapse if the person is absent from the UK and Islands for up to 5 consecutive years (rather than 2 consecutive years as for other forms of such leave). The application deadline of 30 June 2021 applied to them. Therefore, if they do choose to make a late application to the scheme, they will need to evidence reasonable grounds for their delay in making their application in line with this guidance. However, in the case of a first-time applicant to the EU Settlement Scheme with indefinite leave to enter or remain held on another basis since before the end of the transition period, you may regard this as reasonable grounds for their delay in applying, where you are satisfied that they had a reasonable belief that they did not need to apply earlier to the EU Settlement Scheme or a reasonable basis for being unaware that they needed to apply: see Circumstances which will not generally constitute reasonable grounds for delay in making an application. Children (including children in care and care leavers) Where a parent, guardian or local authority has failed by the relevant deadline to apply to the EU Settlement Scheme on behalf of a child who was then under the age of 18, that will constitute reasonable grounds for the delay in making the application where a late application is made by the child where they remain under the age of 18 (or by a parent, guardian or local authority on their behalf). It will also generally constitute reasonable grounds for the delay in making the application where a late application is made by the person where they are now an adult (or by an appropriate third party on their behalf), in particular where a local authority has failed to support a care leave in applying in-time to the scheme. It may be some months or even years after the deadline has passed before a person who was a child at the time realises – perhaps when they first need to evidence their immigration status in order to work or study in the UK – that an application to the scheme should have been made on their behalf by a parent, guardian or local authority and was not. Where they become aware as an adult that an application to the scheme should have been made on their behalf as a child and was not, or that they are an EEA or Swiss citizen resident in the UK before the end of the transition period (or their family member) rather than a British citizen, they should then make a late application to the scheme within a reasonable period. While the time it takes to realise the need to apply will depend on the circumstances of each case, you must be satisfied the delay is reasonable and sufficiently justified. Longer delays may be harder to justify, depending on the circumstances of the case. There may be a range of circumstances in which an application to the EU Settlement Scheme by the relevant deadline has not been made for or by the child. For example: • the child’s parent or parents made an application to the scheme for themselves and did not realise that a separate application had to be made for the child, or did realise this but did not get around to making the application • the child’s parent or parents ignored the need to apply to the scheme themselves and took no action where the child was concerned • the child is in or has left local authority care and the local authority has or had legal parental responsibility for them but did not make an application to the scheme on their behalf (or the child’s parent or parents retained legal parental responsibility for them but did not make an application to the scheme on their behalf) • the EEA citizen parents, resident in the UK before the end of the transition period, of a non-British citizen child born or adopted (or becoming subject to a relevant guardianship order) in the UK after that point were not aware that they needed to make an application to the scheme for the child within 3 months of the birth, adoption or order (or by 30 June 2021 where this occurred before 1 April 2021) • the child was at school in the UK (while their parents worked overseas) and the child, school and parents were unaware of the need for the child to apply to the scheme You do not need to consider the reasons why a parent, guardian or local authority failed to apply to the scheme on behalf of the child by the relevant deadline, or why the child did not make an application on their own behalf by that deadline. You also do not need to consider the reasons why a local authority failed to support a care leaver in applying to the scheme by the relevant deadline. Evidence that may satisfy you that a parent, guardian or local authority has failed by the relevant deadline to apply to the EU Settlement Scheme on behalf of a child under the age of 18, or where a local authority has failed by the relevant deadline to support a care leaver in applying to the scheme, may include a letter from the parent, guardian or local authority confirming the relevant circumstances and appropriate evidence of the person’s age at the relevant deadline. You do not need to consider the detailed basis on which a child was in local authority care or a person is or was a care leaver. More information, including as to the relevant definition of child in care or care leaver applicable in each part of the UK, is available in EU Settlement Scheme – looked after children and care leavers: local authority and health and social care trust guidance. Example 1 The EEA citizen parents of D, also an EEA citizen, have been resident with her in the UK since September 2015. They made an application to the EU Settlement Scheme in December 2020 and were granted settled status, but mistakenly assumed that their daughter would be automatically granted this status in line with theirs without having to apply. This did not come to light until D applied to university in the UK in 2023 and was required to provide evidence of her immigration status in the UK. D then immediately applied to the EU Settlement Scheme. These are reasonable grounds for D’s delay in making her application to the scheme. Example 2 E is aged 19, has lived in the UK for 10 years and is a care leaver, having left local authority care after 6 years in care. From the information available to them, the local authority thought that E was a British citizen, but recent action to complete an application for a UK passport for him has established that he is an EEA citizen and not a British citizen. E applied to the EU Settlement Scheme shortly after learning this. These are reasonable grounds for E’s delay in making his application to the scheme. Physical or mental capacity and/or care or support needs Where a person lacks the physical or mental capacity to apply to the EU Settlement Scheme and has continued to do so since the deadline applicable to them, that will normally constitute reasonable grounds for the person’s delay in making their application to the scheme or for an appropriate third party to apply to the scheme on their behalf. Where a person has significant, ongoing care or support needs and has continued to do so since the deadline applicable to them, that will also normally constitute reasonable grounds for the person’s delay in making their application to the scheme or for an appropriate third party to apply to the scheme on their behalf. This may include adults with physical or mental capacity issues. It may also include adults with broader care or support needs, such as those who may be residing in a residential care home; receiving significant, ongoing care and support in their own home, with long-term physical or mental health needs or a disability; or receiving ongoing outreach support for addiction or other issues and who may lack permanent accommodation. Evidence that may satisfy you that a person lacks the physical or mental capacity to apply to the EU Settlement Scheme (or did so), or has significant, ongoing care or support needs (or did so), may include: - evidence that a formal arrangement, such as a Power of Attorney, is or was in place in respect of the person - a letter from a doctor, health professional, social services department, outreach worker or solicitor confirming the circumstances for the relevant period - a letter from the applicant themselves confirming the circumstances for the relevant period, which has been endorsed by a doctor, health professional, social worker, outreach worker or solicitor and which authorises an appropriate third party to act on their behalf - evidence for the relevant period of a carer relationship where an appropriate third party has been providing for the person’s care needs, for example a Department for Work and Pensions’ letter confirming the eligibility for the relevant period of the third party for Carer’s Allowance For further guidance, see Applications in respect of adults with mental capacity issues and/or care or support needs. Example 1 F is an EEA citizen, aged 75, who lives alone. His dementia means that he often struggles to complete everyday tasks and he receives local authority care and support services in his own home. A friend points out to F that he needs to make an application to the EU Settlement Scheme and offers to complete the application for him. F agrees and the friend makes an application to the scheme for him, uploading a letter signed by F, and endorsed by his doctor, explaining the circumstances and authorising the friend to act on his behalf. These are reasonable grounds for F’s delay in making his application to the scheme. Example 2 G is an EEA citizen, aged 85, and lives in a care home. She was unaware of the EU Settlement Scheme until a member of staff at the care home mentioned it to her. The member of staff helps G to complete an application herself to the scheme. These are reasonable grounds for G’s delay in making her application to the scheme. Serious medical condition or significant medical treatment Where a person has a serious medical condition or is undergoing significant medical treatment around the time of the deadline applicable to them, that may constitute reasonable grounds for their delay in making their application to the EU Settlement Scheme. A serious medical condition could include for example: - an illness or accident which meant that the person was hospitalised or bedbound around the time of the deadline applicable to them - an illness or accident which otherwise meant that the person was unable to perform day-to-day tasks around the time of the deadline applicable to them Pregnancy or maternity around the time of the applicable deadline may be a reason for a person’s delay in making their application to the EU Settlement Scheme, for example where a woman has a difficult childbirth or where a new-born child is in need of medical treatment, where they then make a late application as soon as they reasonably can. Where a person subject to the 30 June 2021 deadline for applying to the scheme had a serious medical condition (or was undergoing significant medical treatment) around the time of that deadline, that will normally have constituted reasonable grounds for them to have missed it. However, that will not in itself constitute reasonable grounds for their delay in making their application if they now seek to make a late application to the scheme. They will need to show they have reasonable grounds, in line with this guidance, for not having applied in the intervening period. It is likely to be only in the most serious circumstances that those reasonable grounds can continue to rely solely on the same serious medical condition or significant medical treatment. Where a person had a serious medical condition (or was undergoing significant medical treatment) around the time of their deadline for applying to the scheme as a joining family member of a relevant sponsor, as a person with other limited leave to enter or remain or exempt from immigration control or as an EUSS family permit-holding family member of a qualifying British citizen, that will normally have constituted reasonable grounds for them to have missed it. You must then take into account the extent of their delay in making their application and the reasons for it. You must assess whether there are reasonable grounds for their delay in making their application. Evidence that a person had a serious medical condition (or was undergoing significant medical treatment) around the time of the deadline applicable to them (and, where relevant, since then) may include: - a letter from a doctor or other health professional confirming the circumstances (including an outline of the serious medical condition or the significant medical treatment and its timing and duration) - a letter from a legal representative or other appropriate third party confirming the circumstances (including the nature, timing and duration of the serious medical condition or significant medical treatment) Where a person had a serious medical condition (or was undergoing significant medical treatment) around the time of the deadline applicable to them, that will also normally constitute reasonable grounds for their delay in making an application to the EU Settlement Scheme in respect of a child or other dependent family member reliant on them to make an application to the scheme on their behalf where the person then makes that application for them as soon as they reasonably can. Example H is an EEA citizen joining family member of a relevant sponsor. She arrived in the UK in June 2023, but suffered a broken leg in a cycling accident in August 2023. H makes an application to the EU Settlement Scheme in October 2023 and provides a letter from her GP explaining the circumstances. These are reasonable grounds for H’s delay in making her application to the scheme. Abusive or controlling relationship or situation Where a person was prevented from applying to the EU Settlement Scheme by the deadline applicable to them because they are or were a victim of domestic violence or abuse (or the family member of such a victim), or they are or were otherwise in a controlling relationship or situation which prevented them from applying by the applicable deadline, that will normally constitute reasonable grounds for the person’s delay in making their application to the scheme. The nature of that abusive or controlling relationship or situation may take one of several forms; you must take a flexible and pragmatic approach in considering each case in light of its particular circumstances and the evidence provided. Neither Appendix EU, nor any other part of the Immigration Rules, specifies any mandatory evidence to be submitted with an application to demonstrate the applicant has been a victim of domestic violence or abuse, or otherwise in a controlling relationship or situation. All the information and evidence given by the person must be considered and a conclusion drawn as to whether there is sufficient evidence to demonstrate that this is the case. Factors to be taken into account when assessing the evidence include: - the length of time since the alleged incident or incidents of domestic violence or abuse, or of other controlling behaviour, and any reasons given for this - the person may not have realised that they were experiencing domestic abuse or may not have known how or where to get support - the fact that the applicant and the perpetrator may still be living at the same address may not necessarily be taken as an indicator that the relationship has not broken down permanently as a result of abuse, as this could be due to a number of reasons – for example, the applicant’s lack of access to safety and support, their fear of losing custody of any children, their fear for their or their children’s safety, a lack of means to support themselves or their children financially, or religious or cultural beliefs or practices - previous immigration history, particularly where there is evidence that the applicant has made a number of unsuccessful attempts to secure leave to remain in the UK on different grounds - other evidence available from Home Office records - supporting letters or information from a doctor, the police, social services or a refuge For guidance on the type of evidence which may be produced and factors which are to be taken into account when considering whether the evidence is sufficient to demonstrate that the applicant is a victim of domestic violence or abuse, see the table of evidence for this in Victims of domestic violence and abuse. This is not exhaustive and all the information and evidence must be considered in the round. You must take a flexible and pragmatic approach. Each case must be considered in light of its particular circumstances, the evidence provided and in consultation with your senior caseworker. Example I is the non-EEA citizen spouse of an EEA citizen. I and her husband have lived together in the UK since 2018. Her husband regularly perpetrates physical and psychological abuse against I and keeps possession of her passport. A friend of I puts her in contact with a community organisation which assists victims of domestic abuse. In August 2023, that organisation helps I make an application to the EU Settlement Scheme, using such alternative evidence of her and her husband’s identity and nationality and such evidence of their UK residence as is available to her. These are reasonable grounds for I’s delay in making her application to the scheme. Served or serving a sentence of imprisonment An EEA citizen or their family member resident in the UK before the end of the transition period who either acquired a right of permanent residence in the UK under EU law, or resided in the UK for a continuous qualifying period of 5 years, before serving a sentence of imprisonment may be eligible for settled status under the EU Settlement Scheme. They can apply from prison (on a paper application form obtained from the Settlement Resolution Centre) or an appropriate third party can apply on their behalf, though any status granted will be invalidated if they are subsequently made subject to a deportation order. Where such a person is released from prison after the deadline applicable to them to apply, there may be reasonable grounds for their delay in making an application to the scheme. This will normally be the case where, for example, in light of information from HM Prison and Probation Service (or the equivalent body in Scotland or Northern Ireland) or other information, you are satisfied that in prison they either: - had reduced access to relevant documents required in order to make an application - were unable to enrol their biometrics - were awaiting a decision on whether they were to be made subject to a deportation order and they made their application within a reasonable period of being released. Example J is an EEA citizen who has been resident in the UK since 2014. He was sentenced to imprisonment in June 2021, was not made subject to a deportation order and was released in June 2023. J makes an application to the EU Settlement Scheme in July 2023 and provides a letter from the resettlement officer at the prison explaining that there had been practical difficulties in facilitating his EUSS application during his incarceration. These are reasonable grounds for J’s delay in making his application to the scheme. Visited the UK since 31 December 2020 A person applying to the EU Settlement Scheme for the first time may be doing so as a joining family member of a relevant sponsor after the deadline of 3 months from their first arrival in the UK after 31 December 2020 because, since that date, they have made a visit(s) to the UK and left before the expiry of their leave to enter as a visitor (or of their EUSS family permit) and without making an application to the scheme. It will normally constitute reasonable grounds for their delay in making their application where they can show that circumstances are such that they now wish to stay in the UK with their relevant sponsor and they have applied to the scheme as soon as they then reasonably can (and, where they have since returned to the UK, within 3 months of their latest arrival). This protects the position of those who have visited the UK since the end of the transition period on 31 December 2020 and relied on the previous guidance, which restarted the deadline for a joining family member application of 3 months from the date of arrival in the UK if they left the UK during that 3-month period and then returned. This does not apply to those who have previously made an in-time or late application to the scheme which was refused or rejected. Unless they have now entered the UK with an EUSS family permit and are applying before its expiry, the deadline of 3 months from their first arrival in the UK after 31 December 2020 applies and they will be required to provide information and evidence that there are reasonable grounds for their delay in making their application. Example K is an EEA citizen applying as a joining family member of a relevant sponsor. She arrived in the UK in January 2024, but has previously visited the UK for 3 weeks in January 2022 and 4 weeks in February 2023. K makes her first application to the EU Settlement Scheme in March 2024 explaining that she did not previously intend to stay in the UK, but she now wishes to remain in the UK with her relevant sponsor in order to work here. These are reasonable grounds for K’s delay in making her application to the scheme. Circumstances which will not generally constitute reasonable grounds for delay in making an application This section describes some circumstances in which you will not generally be satisfied that a person has reasonable grounds for their delay in making their application under the EU Settlement Scheme, but it is not exhaustive and every case must be considered in light of its particular circumstances and the evidence provided. Given (a) the length of time (more than 4 years) since the opening on 30 March 2019 of the EU Settlement Scheme (under which an estimated 5.7 million people had obtained a grant of status by 31 December 2023) and (more than 2 years) since the deadline of 30 June 2021 for applications by those resident in the UK by the end of the transition period; (b) the wide range of communications activity and extensive engagement work undertaken with community groups, charities, employers and local authorities to raise awareness of the scheme and encourage those eligible to apply; and (c) the wide range of support available to applicants, including via Assisted Digital, the Settlement Resolution Centre and the UK-wide network of Home Office grant-funded organisations which have helped more than 500,000 vulnerable people to apply, some grounds for a person’s delay in making their application will generally no longer be accepted. For example, a person may state that they were unaware of the requirement to apply to the EU Settlement Scheme by the relevant deadline or that they failed to make an application by that deadline because they had no internet access, limited computer literacy or limited English language skills. These will generally no longer be considered reasonable grounds for their delay in making their application to the scheme, unless there are compelling practical or compassionate reasons beyond those – such as lacking the physical or mental capacity to apply or having significant, ongoing care or support needs – which are already covered by this guidance. The following will also not generally be accepted as reasonable grounds for the person’s delay in making their application: - they were hampered in accessing the support available to help them apply by restrictions associated with the COVID-19 pandemic - they overlooked the need to apply before the 30 June 2021 deadline, or they failed to get round to applying by that deadline, in light of their general personal circumstances, such as work or study commitments However, every case must be considered in light of its particular circumstances and the evidence provided, though you may give more weight to evidence which is objectively verifiable. For example, there may be circumstances in which a person has provided information and evidence that they had a reasonable belief that they did not need to apply earlier to the EU Settlement Scheme or a reasonable basis for being unaware that they needed to apply, and in either case they have now applied without further delay. Relevant factors to take into account, based on credible information and supporting evidence, may include that the applicant: - is a first-time applicant to the EU Settlement Scheme with a residence document issued under the EEA Regulations, indefinite leave to enter or remain under another route or long continuous UK residence identified by the automated checks of tax and benefits records - has an EEA national spouse, civil partner or durable partner or other close family member or members who applied in-time to the scheme, but believed that they could rely on a residence document issued under the EEA Regulations - has a compliant positive immigration history - has received incorrect advice from an employer or landlord since the end of the grace period on 30 June 2021 as to their right to work or rent in the UK without EU Settlement Scheme status - has travelled in and out of the UK since 30 June 2021 without being signposted to the scheme The presence of such a factor in isolation may or may not be sufficient to satisfy you, on the balance of probabilities, that the applicant has reasonable grounds for their delay in making their application to the EU Settlement Scheme, but may do so when multiple factors are present and the case is considered in the round. Every case must be considered in light of its particular circumstances and the evidence provided. Example 1 L is an EEA citizen who worked in the UK from 2013 to 2021. In 2019, L applied for and was issued a document certifying the right of permanent residence under the EEA Regulations, as he had acquired the right of permanent residence in the UK under EU law. L misunderstood this to be a status which was not affected by the UK’s exit from the EU, so he did not apply to the EU Settlement Scheme by the 30 June 2021 deadline and continued to work in his existing role. L then left the UK for 2 years to look after his seriously ill mother and came back to the UK in October 2023 and began to apply for work. A potential employer requested evidence of L’s right to work in the UK and he presented his permanent residence document issued under the EEA Regulations. The employer told L that the document was no longer valid for that purpose and that he needed to apply for status under the EU Settlement Scheme, which he did without further delay. These are reasonable grounds for L’s delay in making his application to the scheme. Example 2 M is a non-EEA citizen who has been living in the UK since 2007, near her son and his EEA citizen wife who have both worked in the UK since 2005. She is dependent on them for financial support and speaks very little English. In December 2013, M applied for and was issued a permanent residence card under the EEA Regulations, valid until December 2023, as she had acquired the right of permanent residence in the UK as the family member of an EEA citizen. Before its expiry date, M applied to the Home Office to replace her permanent residence card and was informed that this was not possible and that she needed to apply for status under the EU Settlement Scheme, which she did without further delay. These are reasonable grounds for M’s delay in making her application to the scheme. Joining family members and specified enforcement case For applications under Appendix EU made on or after 9 August 2023, where an applicant relies on being a joining family member of a relevant sponsor, they must not be a ‘specified enforcement case’. Where they are, you must reject the application as invalid. A ‘specified enforcement case’ is defined in Annex 1 to Appendix EU as either: - an “illegal entrant” within the meaning given in section 33(1) of the Immigration Act 1971 (save that, in respect of the reference there to “deportation order”, the definition of ‘deportation order’ in Annex 1 to Appendix EU does not apply) - an irregular arrival Section 3(1)(a) of the Immigration Act 1971 states that a person who is not a British citizen shall not enter the UK unless given leave to do so in accordance with provisions of, or made under, that Act. Entry without leave is a breach of section 3(1)(a) and therefore constitutes illegal entry as defined by section 33(1) of the Immigration Act 1971. Checking for evidence of illegal entry or irregular arrival You must check the information on the application form and case working systems to see if there is evidence that the applicant, if relying on being a joining family member of a relevant sponsor in an application made on or after 9 August 2023, is an illegal entrant or an irregular arrival. That will require evidence the applicant previously entered or sought to enter the UK either: - in breach of a deportation order - in breach of the immigration laws - by means of deception (this includes deception by another person) - as an irregular arrival For more information, see: Irregular or unlawful entry and arrival Initial consideration and assessment of liability to administrative removal Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Breach of deportation order Where a joining family member applicant has entered or sought to enter the UK in breach of any deportation order, their application, made on or after 9 August 2023, must be rejected as invalid. The definition of ‘deportation order’ in Annex 1 to Appendix EU does not apply for these purposes. Where an applicant has been found to have entered in breach of a deportation order made before the end of the transition period at 11pm on 31 December 2020 and considers the order does not comply with the protection in the Agreements, the application must still be rejected as invalid. The appropriate course for such a person is to seek the revocation of their deportation order before they enter the UK. For more information see: Initial consideration and assessment of liability to administrative removal Breach of the immigration laws An applicant who has entered or sought to enter the UK in breach of the immigration laws may include a person who has entered the UK clandestinely or without leave. In assessing whether the applicant is in breach of immigration laws, you must note that in some circumstances, it is permissible to enter the UK without formal written leave, including: - crews of aircraft and vessels granted ‘deemed’ leave for a short period to leave on another aircraft or vessel - Australia, Canada, New Zealand, the United States of America, Japan, Singapore and South Korea (B5JSSK) nationals, as well as Irish, EU, other EEA and Swiss nationals using e-gates, granted leave to enter verbally by an immigration officer - deemed leave for eligible arrivals via the Common Travel Area Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Official – sensitive: end of section Use of deception (including deception by another person) A person who has entered or sought to enter the UK by means of deception, will include where they make or cause to be made a false representation (contrary to section 26(1)(c) of the Immigration Act 1971). Detailed guidance is available on how Immigration Officers and caseworkers have to prove whether, on the balance of probabilities, a person is an illegal entrant by deception. Where, in an application made on or after 9 August 2023, the applicant is relying on being a joining family member who has entered or sought to enter the UK by deception, their application must be rejected. Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Validity consideration If an applicant submits an application which is missing any of the components required at rule EU9(a), (b), (c), (d) or (e) of Appendix EU for it to be valid, then, subject to the sub-sections below, they must be prompted or contacted and given a reasonable opportunity to provide what is needed to validate the application. The relevant validity requirements in those sub-paragraphs of rule EU9 are: - under sub-paragraph (a), it has been made using the required application process - under sub-paragraph (b), the required proof of identity and nationality has been provided, where the application is made within the UK - under sub-paragraph (c), the required proof of entitlement to apply from outside the UK has been provided, where the application is made outside the UK - under sub-paragraph (d), the required biometrics have been provided - under sub-paragraph (e), it has been made by the required date, where the date of application is on or after 9 August 2023 - under sub-paragraph (f), the applicant, if they rely on being a joining family member of a relevant sponsor and where the date of application is on or after 9 August 2023, is not a specified enforcement case Where the validity requirements at sub-paragraph (a), (b), (c), (d) or (e) of rule EU9 are not met after the applicant, subject to the sub-sections below, has been prompted or contacted and given a reasonable opportunity to provide what is needed to validate the application, the application must be rejected as invalid under rule EU10(1) of Appendix EU. The rejection letter must explain the reason or reasons for the rejection, including, where relevant, why, by reference to any information or evidence provided by the applicant, you are not satisfied that they have reasonable grounds for their delay in making their application. Where the validity requirement at sub-paragraph (f) of rule EU9 is not met, the application must be rejected as invalid under rule EU10(1) of Appendix EU. The rejection letter must explain the reason for the rejection. Not using the required paper application form Where the validity requirement at sub-paragraph (a) of rule EU9 is not met because the applicant has made an application online instead of using the required paper application form, where this is mandated on GOV.UK, the application must be rejected as invalid under rule EU10(1) of Appendix EU. In such cases, the applicant must be advised in the rejection letter of the requirement to apply using the required paper application form and how one can be obtained, but there is no requirement to contact the applicant before rejecting the application. Fraudulent identity document Where the validity requirement at sub-paragraph (b) or (c) of rule EU9 is not met because the applicant has submitted a fraudulent identity document (or fraudulent alternative evidence), the application must be rejected as invalid under rule EU10(1) of Appendix EU. In such cases, there is no requirement to contact the applicant before rejecting the application. Non-EEA passport for EEA citizen Where the validity requirement at sub-paragraph (b) or (c) of rule EU9 is not met because the applicant relies on being an EEA citizen but provides only a non-EEA (and non-British) passport, the application must be rejected as invalid under rule EU10(1) of Appendix EU. In such cases, there is no requirement to contact the applicant before rejecting the application. No biometric residence card as claimed Where the validity requirement at sub-paragraph (d) of rule EU9 is not met because the applicant wrongly indicated in their application that they hold a biometric residence card which has not expired by more than 18 months (and was therefore not asked to provide the required biometrics), the application must be rejected as invalid under rule EU10(1) of Appendix EU. In such cases, there is no need to contact the applicant before rejecting the application, but the applicant: - where applicable, must be advised in the rejection letter of the need to indicate in any further application that they held a biometric residence permit (not a biometric residence card) - all cases, must be advised in the rejection letter to comply in any further application with the request to provide the required biometrics - can rely, where any further application is made promptly, on having made such an error as reasonable grounds for delay, or further delay, in making their application Biometric residence card lost, stolen or expired by more than 18 months Where the validity requirement at sub-paragraph (d) of rule EU9 is not met because the applicant wrongly indicated in their application that they hold a biometric residence card which has not expired by more than 18 months (and was therefore not asked to provide the required biometrics), but you establish that their biometric residence card (issued under the EEA Regulations or the EU Settlement Scheme) has been lost or stolen or has expired by more than 18 months, the application must be rejected as invalid under rule EU10(1) of Appendix EU. In such cases, there is no need to contact the applicant before rejecting the application, but the applicant: • if they do not have status under the EU Settlement Scheme, must be advised in the rejection letter of the need to indicate in any further application that they do not hold a biometric residence card and to comply with the request to provide the required biometrics • if they have pre-settled status under the EU Settlement Scheme, must be advised in the rejection letter that, if they wish to convert to settled status, they need to indicate in any further application that they do not hold a biometric residence card and to comply with the request to provide the required biometrics • if they are outside the UK and have pre-settled or settled status under the EU Settlement Scheme, must be advised in the rejection letter that they must update their UK Visas and Immigration account with their current travel document or, if they cannot do that outside the UK, they can apply for an EUSS travel permit at Apply for an EU Settlement Scheme travel permit to return to the UK - GOV.UK (www.gov.uk) Reasonable grounds for the delay in applying Where, on or after 9 August 2023, a person applies to the EU Settlement Scheme after the deadline applicable to them and does not provide any substantive information concerning their delay in making their application, or provides substantive information which, in line with this guidance, you do not consider to constitute reasonable grounds for their delay in making their application, you are not required to contact the applicant before rejecting the application and the application must be rejected as invalid under rule EU10(1) of Appendix EU. If the person considers that they have reasonable grounds for their delay in making their application, they can reapply to the scheme and provide the requisite information and evidence. Where, on or after 9 August 2023, a person applies to the EU Settlement Scheme after the deadline applicable to them and provides substantive information concerning their delay in making their application which, in line with this guidance, you consider appears to constitute reasonable grounds for their delay in making their application, but they provide no or insufficient supporting evidence or you require further information, you must write to the applicant (by email or post, taking account of their preference between these where this has been specified as part of the application) and give them 14 calendar days to provide that evidence or further information. Where you write to them by first class post, you may assume delivery on the second business day after the date of postage. Where, in light of evidence or further information provided by the applicant within that 14-day period, you consider that there are reasonable grounds for their delay in making their application, you can move on to any remaining stage of the validity consideration. Otherwise, including where the applicant does not respond within that 14-day period, the application must be rejected as invalid under rule EU10(1) of Appendix EU. If the person considers that they have reasonable grounds for their delay in making their application, they can reapply to the scheme and provide the requisite information and evidence. Where you have doubts regarding the authenticity of the evidence provided by the applicant in support of the reasonable grounds for their delay in applying because the document or documents do not meet the expected standard or comply with the published standard for an official document of that type and you are not able to objectively verify that evidence, you are not required to contact the applicant before rejecting the application. The application must be rejected as invalid under rule EU10(1) of Appendix EU and the rejection letter must explain your reasons for not accepting the evidence provided. If the person is able to substantiate the authenticity of that evidence or provide objectively verifiable alternative evidence to show there are reasonable grounds for their delay in making their application, they can reapply to the scheme with that further evidence. Where an applicant has declared as part of their application that they are applying as a joining family member of a relevant sponsor, either: - within 3 months of their first arrival in the UK after 31 December 2020 - from outside the UK and that they have not entered the UK since 31 December 2020 but they have provided no evidence of this (and this is not their first application to the EU Settlement Scheme: see [Joining family members](#)), or you have information which confirms that they have been to the UK since 31 December 2020 (or arrived on an earlier date since then than claimed) and are applying more than 3 months from their first arrival in the UK after 31 December 2020 (or after 30 June 2021 where their first arrival in the UK after 31 December 2020 was before 1 April 2021), you are not required to contact the applicant for further information or evidence. You must consider the application as having been made after the relevant deadline and assess whether there are reasonable grounds for their delay in making their application. Where such an applicant has not provided any substantive information concerning their delay in making their application (or has provided substantive information which, in line with this guidance, you do not consider to constitute reasonable grounds for their delay in making their application), you are not required to contact the applicant before rejecting the application and the application must be rejected as invalid under rule EU10(1) of Appendix EU. The rejection letter must explain your reasons for treating the application as having been made after the relevant deadline. If the person can show that they are applying within 3 months of their first arrival in the UK after 31 December 2020 or considers that they have reasonable grounds for their delay in making their application, they can reapply to the scheme and provide the requisite information and evidence. Invalid sponsor for a joining family member application Where, in an application to the EU Settlement Scheme made on or after 9 August 2023, the applicant relies on being a ‘joining family member of a relevant sponsor’, but in their application provides, whether by way of a Unique Application Number, biographical information or otherwise, an invalid sponsor, i.e. a person who cannot in any circumstances be a ‘relevant sponsor’, the application is not to be treated as a joining family member application. You must instead treat the application as one to which the 30 June 2021 deadline is applicable and consider whether, in line with the guidance above, the applicant has reasonable grounds for their delay since then in applying. In the absence of substantive information concerning their delay, which you consider does or may constitute reasonable grounds for that delay, you are not required to contact the applicant before rejecting the application and the application must be rejected as invalid under rule EU10(1) of Appendix EU. An invalid sponsor will be either: - the applicant - a fictitious person - a person who is unidentifiable based on the limited information provided by the applicant (for example, the applicant only provided the name of the sponsor and you are unable to confirm that they are a relevant sponsor with status granted under rule EU2 or EU3 of Appendix EU or that they are a relevant person of Northern Ireland) - a non-EEA citizen (other than a British citizen) who the applicant does not establish is also an EEA citizen - an EEA citizen (other than an Irish citizen or who is relied on by the applicant as being a person exempt from immigration control or a frontier worker) who has a pending valid EU Settlement Scheme application or appeal but has not been granted status as a relevant EEA citizen (under rule EU2 or EU3 of Appendix EU) - an EEA citizen whose status under the EU Settlement Scheme was granted as a joining family member (under rule EU2A or EU3A of Appendix EU) - an EEA citizen whose status under the EU Settlement Scheme has been cancelled, curtailed or revoked - a person relied on by the applicant as being a family member who cannot in any circumstances be a relevant sponsor of a joining family member (for example, an uncle, aunt or sibling) - a person relied on by the applicant as being a family member who cannot in any circumstances be a relevant sponsor for that joining family member because, for example, their date of birth confirms that the claimed family relationship is not possible (for example, a parent or grandparent who claims to be 5 years older than their claimed child or grandchild) and no evidence has been submitted with the application to substantiate the family claimed relationship - a person relied on by the applicant as being a family member who cannot be a relevant sponsor of a joining family member because they have already been relied on by another person as the sponsor of such a family member (for example, a spouse, civil partner or durable partner) under the EU Settlement Scheme or for an EUSS family permit, and no evidence has been submitted with the application to substantiate the claimed relationship - a person relied on by the applicant as being a joining family member and the applicant has already made an application to the EU Settlement Scheme based on that family relationship, and that application was refused because they failed to provide any evidence of that family relationship, and they have not provided any evidence of it with their current application Any rejection letter must explain the reasons for the rejection, including why the sponsor on whom the joining family member application relied is not a valid sponsor and why, by reference to any information or evidence provided by the applicant, you are not satisfied that they have reasonable grounds for their delay in making their application since the 30 June 2021 deadline which is otherwise applicable. If the applicant considers that they have a relevant sponsor for a joining family member application, they can reapply to the scheme and provide the requisite information and evidence. Void applications Under rules 34KA and 34KB of Part 1 of the Immigration Rules, an application is void where it would not be possible to grant the applicant the permission for which they applied and, if an application is void, it will not be considered. Examples of where an application to the EU Settlement Scheme is void include where: - the applicant is a British citizen (including a dual British citizen) or otherwise has the right of abode in the UK - the applicant has been granted settled status under the EU Settlement Scheme and this status remains valid - the applicant dies before their application is decided Certificate of application A certificate of application under the EU Settlement Scheme is issued by the Home Office to confirm that the applicant has submitted a valid application under the scheme. It does not confirm that the person has immigration status in the UK, but it does confirm the temporary protection of their rights in the UK pending the outcome of their application and any valid administrative review or appeal. A certificate of application will be issued to the applicant on receipt of a valid application by them under the scheme. Multiple applications There may be occasions where an applicant has made more than one application to the scheme at the same time. In particular, they may have submitted an online application (with a view to submitting the required proof of identity and nationality by post) but subsequently opted to apply via the ‘EU Exit: ID Document Check’ app (which enables them to provide that proof via the app). Where this is the case, you must take the action set out below depending on the particular circumstances: - where 2 or more invalid applications to the scheme are submitted because the required proof of identity and nationality has not yet been provided, you must contact the applicant and give them a reasonable opportunity to provide that proof and to withdraw the other application or applications: - if they provide that proof in respect of one application but fail to withdraw the other application(s), you must reject any invalid application or applications under rule EU10(1) of Appendix EU - the other application must be considered in the normal way - if they provide the required proof of identity and nationality but fail to specify which application they would like to proceed with and fail to withdraw the other(s), you must validate their most recent application (where the other requirements of a valid application are met) and reject the other application(s) as invalid under rule EU10(1) of Appendix EU - if they do not provide that proof after being given a reasonable opportunity to do so, you must reject all the applications received as invalid under rule EU10(1) of Appendix EU • where 2 or more late applications to the scheme are submitted on or after 9 August 2023 and have the required evidence of identity and nationality but require assessment of reasonable grounds for the delay in applying, you must first assess the information and evidence provided with both (or all) applications to establish whether you can validate one of the applications: - if the combined information and evidence satisfies you the applicant has reasonable grounds for their delay in making their application, you must validate the most recent application and reject the other or others as invalid under rule EU10(1) of Appendix EU - if the combined information and evidence is insufficient to satisfy you the applicant has reasonable grounds for their delay in making their application, but the applicant has provided substantive information concerning their reasonable grounds, you must contact the applicant and give them a reasonable opportunity to provide the required evidence of these. If they do so, you must validate the most recent application and reject the other(s) as invalid under rule EU10(1) of Appendix EU. If they do not do so, you must reject all the applications as invalid under rule EU10(1) of Appendix EU - otherwise, you must reject all the applications as invalid under rule EU10(1) of Appendix EU • where 2 or more applications to the scheme are made, where one is valid and the other(s) invalid, and it is identifiable at the validity consideration stage that the valid application would result in a grant of settled status, or where the valid application is the most recent application (and the invalid application or applications are earlier applications), you must decide the valid application and reject the other application or applications as invalid under rule EU10(1) of Appendix EU - where it is not possible to identify at the validity consideration stage whether an application will result in a grant of settled status, or where an invalid application is the latest application and where the earlier valid application would not result in a grant of settled status or has been made on a different basis under the scheme (for example one of the applications is made as a person with a derivative right to reside and the other is not), you must contact the applicant inviting them to withdraw the invalid application or applications, giving a deadline of 10 working days, after which (if the applicant has not agreed to withdraw) you must reject any invalid application or applications under rule EU10(1) of Appendix EU and the valid application must be considered in the normal way - if the applicant validates the second application, this will then vary the first valid application and you should proceed as per the bullet point below - where 2 or more applications to the scheme are made, on different days or on the same day, and all are valid but not yet decided, the latest application must be treated as an application to vary the earlier application or applications and only the latest application will be considered, in line with rule EU10(2) of Appendix EU - where 2 applications are made, on different days or on the same day, and where one is under the scheme and the other under another part of, or outside, the Immigration Rules and both are valid but not yet decided, both applications must be considered - see Variation of applications Automated conversion from pre-settled to settled status There may be occasions where an applicant has made a valid application to convert from pre-settled status to settled status, but, before that application is decided, their case is considered for automated conversion to settled status. Where this is so, the automated consideration must be concluded before any further action is taken on the manual application. If the automated process results in settled status being granted, the manual application must be treated as void. If the automated process does not result in settled status being granted, the manual application must be considered in the normal way. Further applications Where a further valid application under the EU Settlement Scheme has been made after an earlier application under it has been decided: - if the earlier application resulted in refusal, rejection, withdrawal, treatment as void or in any outcome other than a grant of leave under the scheme, then the latest application must be considered in the normal way (including, where the further application is made after the applicable deadline, whether there are reasonable grounds for a late application: see Making an application: deadline) - if the earlier application resulted in settled status being granted, the further application must be treated as void - if the earlier application resulted in pre-settled status being granted, the further application must be considered in the normal way If you grant settled status where the applicant has pre-settled status, then it will vary (replace) the earlier grant of pre-settled status. If you grant pre-settled status where the applicant has pre-settled status, then it will vary (replace) the earlier grant of pre-settled status. The date of the first grant of pre-settled status will remain the start date of their pre-settled status. Where a person who has pre-settled status under the EU Settlement Scheme (which has not been cancelled, curtailed or invalidated) makes a valid application for leave to enter or remain under another part of the Immigration Rules (not outside the rules, such as under the Migrant Victims of Domestic Abuse Concession) and, following caseworker consideration, that further application falls to be granted, you must contact the applicant to explain that the grant of leave under another part of the Immigration Rules will vary (replace) their pre-settled status and ask them to confirm in writing within 14 calendar days whether they wish you to proceed to grant them that alternative leave. If the person does not respond to the contrary within that period, you must grant them the alternative leave that will vary (replace) their pre-settled status. Related content Contents Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Alternative evidence of identity and nationality or of entitlement to apply from outside the UK There may be reasons why an applicant in the UK cannot provide the required proof of identity and nationality in the form of (for a European Economic Area (EEA) or non-EEA citizen) a valid passport, (for an EEA citizen) a valid national identity card, or (for a non-EEA citizen) a valid biometric residence card or a valid biometric residence permit. You may accept alternative evidence of identity and nationality where the applicant cannot obtain or produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons. There may also be reasons why an applicant outside the UK cannot provide the required proof of their entitlement to apply from outside the UK in the form of (for an EEA citizen) a valid passport or a valid national identity card, where this contains an interoperable biometric chip; or (for a non-EEA citizen) a valid biometric residence card. You may accept alternative evidence of identity and nationality where the applicant (if they are an EEA citizen) cannot obtain or (if they are an EEA or non-EEA citizen) cannot produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons. Likewise, there may be reasons why a non-EEA citizen applicant without a documented right of permanent residence cannot provide the required evidence of the identity and nationality of their EEA citizen (or qualifying British citizen) family member in the form (which can be a copy and not the original document, unless you have reasonable doubt as to the authenticity of the copy submitted) of a valid passport or (for an EEA citizen) a valid national identity card. You may accept alternative evidence of identity and nationality where the applicant cannot obtain or produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons. If the applicant provides a valid passport or national identity card from a country that is not recognised by the UK, such as the Turkish Republic of Northern Cyprus, you may accept this as evidence of their identity and nationality providing there are no indications to the contrary. In these circumstances you must discuss the case with a senior caseworker who may refer to the EEA Citizens’ Rights & Hong Kong Unit for further advice. Each case must be considered on its individual merits and you must refer to a senior caseworker in all instances where the applicant seeks to rely on alternative evidence of identity and nationality or of entitlement to apply from outside the UK. Circumstances where alternative evidence may be accepted The following lists are not exhaustive and there may be other circumstances beyond the control of the applicant, or other compelling practical or compassionate reasons, why they cannot obtain or produce the required document. Each case must be considered on its individual merits and you must refer to a senior caseworker in all instances where this guidance is engaged. Document unobtainable from national authority This section lists some circumstances where an applicant may be unable to obtain the required document due to circumstances beyond their control: - the applicant’s passport has expired or has been permanently lost or stolen and there is no functioning national government to issue a replacement - there is a national authority to apply to for a document, but they have run out of documents In these circumstances the applicant is to be requested to provide as much information as possible, including details of any applications for documentation they may have made to their national authority (if applicable), and provide alternative evidence of their identity and nationality (see Other supporting information or evidence). Document exists but cannot be produced If the Home Office or another government department is holding the required document, you must contact the relevant section or department to confirm the details. If you are satisfied that this establishes the applicant’s identity and nationality, no further supporting evidence is required. If the applicant states that the required document has been retained by a person in circumstances which have led to the applicant being the subject of a positive conclusive grounds decision made by a competent authority under the National Referral Mechanism (they are a victim of trafficking), you must discuss this with a senior caseworker who must refer to your local safeguarding lead for further advice. If the applicant is not the subject of a positive conclusive grounds decision under the National Referral Mechanism but states that the required document is being withheld from them by a third party, such as an employer or a family member, you must discuss this with a senior caseworker and your local safeguarding lead. This also applies if the applicant states that they are a victim of domestic violence or abuse and they are unable to produce the required document as a result. Domestic violence or abuse victims are to be asked to produce supporting evidence of their circumstances from a third party, such as the police or social services. In both of the scenarios immediately above, and after referring to a senior caseworker and your local safeguarding lead, you must make a decision on whether to accept alternative evidence of identity and nationality of the applicant (and, where applicable, of the relevant EEA citizen or qualifying British citizen of whom the applicant is, or for the relevant period was, a family member) based on all the information and evidence available, taking into account the sensitivities of the case. In all circumstances where you have agreed to consider alternative evidence of identity and nationality, the applicant is to be requested to provide as much information and evidence as possible, including details of any applications for documentation made to their national authority (see Other supporting information or evidence). Refugee status or humanitarian protection There is a lower standard of proof for establishing identity and nationality in protection claims (asylum and humanitarian protection) than for the EU Settlement Scheme. Nonetheless, if the applicant is a person in the UK with refugee status or humanitarian protection, no further evidence of identity and nationality is required provided there is no evidence: - this identity or nationality was confirmed in error - the identity or nationality was fraudulently claimed or accepted - the identity or nationality has materially changed - the applicant has ceased to be a refugee or a person in need of humanitarian protection, which would mean they are now in a position to obtain and produce the required document The applicant must be asked to produce alternative evidence of their identity and nationality (see Other supporting information or evidence), where you accept that they cannot obtain or produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons, and where either: - the applicant does not have, or no longer requires, refugee status or humanitarian protection - there is reason to doubt their previously accepted identity or nationality Other reasons document cannot be obtained or produced There may be other reasons why the applicant cannot obtain or produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons. Each case must be considered on its individual merits and you must refer to a senior caseworker in all instances where this guidance is engaged. Those other reasons may arise from the impact of the COVID-19 pandemic or the war in Ukraine. For example, the closure of, or inability to travel to, an embassy or high commission may have prevented an applicant from renewing their passport or national identity card, or may have meant they could not finalise an application for a new document. These may be acceptable reasons to provide alternative evidence of identity and nationality or of entitlement to apply from outside the UK. If the applicant claims that it would be impossible or unreasonable for them to obtain or produce the required document due to a serious medical condition or due to their mental capacity, they or the person acting for them must be requested to provide confirmation of their condition or capacity, and why it prevents them from obtaining or producing the required document, from their GP or other appropriately qualified medical professional. There may also be occasions where other factors that are not in and of themselves considered a serious medical condition, such as an applicant’s age, that may still be a barrier to them being able to travel to their home country’s embassy or consulate as required in order to obtain the required document. In these circumstances, you may request a letter from their GP or other appropriately qualified medical professional confirming the barrier or barriers to travel, but you must discuss the circumstances with a senior caseworker before doing so. If you are satisfied that it would be impossible or unreasonable for the applicant to obtain or produce the required document, for example because their mental capacity falls under the Mental Capacity Act 2005 (for England and Wales), the Adults with Incapacity (Scotland) Act 2000 or common law in Northern Ireland, and there is no one reasonably able to do so on their behalf, then the applicant is to be asked to produce alternative evidence of their identity and nationality (see Other supporting information or evidence). The applicant is to be asked to produce alternative evidence of their identity and nationality (see Other supporting information or evidence), where the applicant is a child under the age of 18 in local authority care and both: - the required document has been lost or destroyed, or was never obtained or provided - either: - there is satisfactory evidence that it is not in the best interests of the child for the local authority to obtain the required document on their behalf, such as where doing so may risk the child, contrary to their own best interests, leaving local authority care - there are significant practical barriers to obtaining the required document, such as the national authority requiring the consent of both parents, but the parents are absent or un-cooperative Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Other supporting information or evidence This section lists examples of other supporting information or evidence of identity and nationality, or of entitlement to apply from outside the UK, that an applicant may provide, alongside any other information or evidence you have gathered, where you have accepted that the applicant cannot obtain or produce the required document due to circumstances beyond their control or due to compelling practical or compassionate reasons. Each case must be considered on its own merits and you must work flexibly with the applicant to try to obtain sufficient supporting information or evidence to satisfy you of their identity and nationality or of their entitlement to apply from outside the UK. There may be cases where an applicant will need to produce more than one piece of evidence from the list below in order to satisfy you of this, for example, alongside other information you may be satisfied that a UK-issued driving licence confirms an applicant’s identity but not their nationality. This list is not exhaustive: more than one piece of evidence can be requested on a case by case basis and each case must be considered on its own merits to help you build a picture of the applicant’s identity and nationality or of their entitlement to apply from outside the UK: - documents previously issued by the Home Office (such as a document issued for emergency travel purposes) provided there is no evidence that this identity or nationality was confirmed in error, fraudulently, or has significantly changed - an expired passport or other required document, bearing the applicant’s name and photograph - an official document issued by the authorities of the applicant’s country of origin which confirms their identity and nationality, including birth certificate, marriage certificate, driving licence, tax / social security statement, national service document, or emergency travel document or similar – this is not an exhaustive list and other similar documents may be considered - an official document issued by the UK authorities which confirms the applicant’s identity and, if possible, nationality – and this can include a UK driving licence, National Insurance number card, or tax or pension statement – this is not an exhaustive list and other similar documents may be considered - an official document issued by the authorities of an EEA country which confirms the applicant’s identity and nationality, including a document confirming permanent residence in that state or registration as the family member of an EEA citizen exercising Treaty rights in that state - the applicant’s biometrics (facial photograph and, in the case of a non-EEA citizen, fingerprints) which match an existing government record confirming their identity and nationality Where you have followed this guidance and all other steps to ascertain an applicant’s identity and nationality have been exhausted, you may refer to the embassy, consulate or high commission in the UK of the applicant’s claimed country of origin seeking confirmation as to any records held about the claimed identity and nationality. You must use the cover letter and proforma available to you to do so, to ensure that the General Data Protection Regulation is followed. You must be satisfied that such an approach would not put the applicant or their family at risk and must consult your senior caseworker in all cases before proceeding. You may also invite the applicant to an interview to assess their ties to their claimed country of origin, including knowledge of its geography, culture and language. Such an interview can be held in person, by telephone, by videolink or over the internet as long as you are satisfied that the person to whom you are speaking is the applicant. Should the validity requirement at sub-paragraph (b) or (c) of rule EU9 not be met after the applicant’s inability to obtain or produce the required document has been considered in accordance with this guidance (including that the applicant has been prompted or contacted and given a reasonable opportunity to provide what is needed to validate the application), the application must be rejected as invalid under rule EU10(1) of Appendix EU. Irish citizens In the case of an Irish citizen, where there are circumstances beyond their control or compelling practical or compassionate reasons why they cannot provide the required document, alternative evidence may include their full Irish birth certificate or an Irish certificate of naturalisation. This can be accompanied by a photographic identity document (such as a driving licence or Irish Public Service Card) as evidence of identity. Other documentation (see [Other supporting information and evidence](#)) may also be considered if necessary. --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. --- Official – sensitive: end of section Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Withdrawing an application An applicant may request to withdraw their application at any time after it has been submitted but before, where it is a valid application, a decision has been made on the application and this decision has been recorded on the caseworking system. Requesting to withdraw an application An applicant can withdraw their application by written request online or by post. This applies to applications made in the UK and from overseas. If the request is ambiguous, you must confirm the withdrawal request with the applicant. A request for withdrawal must generally be made by the applicant named on the application form. Where the applicant is aged under 18 or was unable to submit their application themselves, you may accept a request for withdrawal from the person or organisation named on the application form as having provided assistance to them or as having completed the application on their behalf. Requesting to withdraw online The applicant must request to withdraw an application in writing. To do this online, they must use the online ‘ask a question about applying for settled status’ form found at https://eu-settled-status-enquiries.service.gov.uk/start, selecting the option for asking a question about ‘An application submitted and in progress’. The date of withdrawal is the date the request is received by the Home Office, calculated in line with the information set out in ‘Date of application: original application’. Requesting to withdraw by post The applicant must request to withdraw an application in writing. To do this by post, they must send a withdrawal request to: EU Settlement Scheme PO BOX 2075 Liverpool L69 3YG The date of withdrawal is the date the request is received by the Home Office, calculated in line with the information set out in ‘Date of application: original application’. Withdrawn applications The case of Qadeer v SSHD clarified that the Secretary of State does not have to agree to withdraw an application and may still consider and decide the application even where that might lead to a refusal. For example, where there is a suspicion that deception has been used by the applicant if they have submitted fraudulent documents in support of their application. If you do not think that it is appropriate to agree to a request to withdraw an application, you must discuss this with your senior caseworker. Date of application: original application The date of application, as defined in Annex 1 to Appendix EU, is the date on which the application is submitted under the required application process, which means: - for on-line applications: the date on which the form is submitted on-line - for paper applications, either: - the date of posting to the Home Office address specified on the form (where one is specified), as shown on the tracking information provided by Royal Mail or, if not tracked, by the postmark date on the envelope - where the paper application form is sent by courier, or other postal services provider, the date on which it is delivered to the Home Office address specified on the form (where one is specified) - where the paper application form is sent by email, the date on which it is recorded by Home Office email software as received at the Home Office email address specified on the form (where one is specified) If the envelope in which the application was posted is missing, or if the postmark is illegible, you must take the date of posting to be at least one working day before it is received by the Home Office. If there is also accompanying correspondence with the application that matches the likely date of posting, and that date is earlier than the date of posting calculated using the above method, you must take this earlier date as the application date. If you withdraw a decision to treat an application as invalid and instead accept it as valid, the date of application is the date the application was originally made. If an application, or variation, was previously rejected as invalid and the applicant then submits a valid application, the date of application, or variation, is the date the valid application is submitted. Confirmation of withdrawal Once a request to withdraw an application has been actioned, you must use the relevant information provided by the applicant as their correspondence address to confirm to them that their application has been withdrawn and note on the caseworking system that this has been done. Travel outside the Common Travel Area An application made under Appendix EU will not be treated as automatically withdrawn if the applicant travels outside the Common Travel Area before the application has been decided. Related content Related external links Appendix EU to the Immigration Rules Qadeer v SSHD Variation of applications This section tells you how to deal with variation of an application in accordance with sub-paragraphs (2), (3) and (4) of rule EU10 of Appendix EU. Paragraph 34BB of the Immigration Rules does not apply to applications made under Appendix EU. Where 2 or more applications to the scheme are made, and all are valid but not yet decided, the latest application must be treated as an application to vary the earlier application(s) and only the latest application will be considered, in line with rule EU10(2) of Appendix EU. You must check Home Office systems to ensure that any other pending application, other than the latest scheme application, is identified. Where it is, you must contact the relevant casework team to ensure that the other application is also dealt with in accordance with sub-paragraphs (3) and (4) of rule EU10 and this guidance. Generally, the casework team identifying the second application will be responsible for ensuring it, and the first application, are dealt with in accordance with this guidance. Where an applicant has a valid application pending under the scheme and then makes a subsequent valid application for leave under another part of, or outside, the Immigration Rules (or vice versa), both applications will be considered and then dealt with as follows: - where one application falls to be refused, this can be done without having to wait for the outcome of the consideration of the other application – otherwise, one application must not be granted before the other application has reached the point of decision - where both applications fall to be granted, the applicant must be informed in writing that they satisfy the relevant criteria in respect of both applications and asked to confirm in writing within 14 days (or longer where, following consultation with your senior caseworker, you are satisfied there is good reason for this in the particular circumstances of the case) which application they want to be decided and which they want to be treated as withdrawn - if the applicant does not so confirm by then, or contact you by then to advise that they need more time to respond (for example where they wish to seek immigration advice), the latest application will be decided and the other treated as withdrawn Related content Contents Related external links Appendix EU to the Immigration Rules Making an application: eligibility Where a valid application has been made to the EU Settlement Scheme, this section tells you the requirements for eligibility for indefinite leave which is also referred to for the purposes of the scheme as ‘settled status’, or 5 years’ limited leave which is also referred to as ‘pre-settled status’. Where they meet the relevant criteria, applicants who make an application within the UK will be granted either indefinite leave to remain (ILR) or limited leave to remain (LTR), and applicants who make an application outside the UK (from 7.00am on 9 April 2019) will be granted either indefinite leave to enter (ILE) or limited leave to enter (LTE). Where the applicant is a European Economic Area (EEA) citizen resident in the UK before the specified date as a family member of an EEA citizen resident here, the applicant will be able to rely on their own continuity of residence as a relevant EEA citizen to apply for status under the scheme, or they can apply as a family member if they prefer: see family members. Where a person granted LTE or LTR under the EU Settlement Scheme as a Joining family member of a relevant sponsor later applies for ILE or ILR and at that stage it is established by the evidence provided or otherwise available to you that they meet the requirements for ILE or ILR as a relevant EEA citizen or family member of a relevant EEA citizen (including that they were resident in the UK by the end of the transition period on 31 December 2020 and maintained the required continuity of residence thereafter), they may be granted ILE or ILR on that basis instead. EEA citizens Documented right of permanent residence An EEA citizen will be eligible for ILE or ILR under the scheme, as a relevant EEA citizen under condition 1 in rule EU11, where, at the date of application, they have a documented right of permanent residence, and since they did, no supervening event has occurred in respect of the applicant. This means that you are satisfied from the information available to you that the applicant has been issued with either: - a document certifying permanent residence under regulation 19 of the EEA Regulations - a residence permit or residence document under the Immigration (European Economic Area) Order 1994 endorsed to show permission to remain in the UK indefinitely And in addition: • this document is not invalid under regulation 19(4)(c) • this document has not been revoked, and its renewal has not been refused, under regulation 24 (except where the revocation or refusal occurred because the person had been absent from the UK for a period of more than 2, and no more than 5, consecutive years) • the person’s right to reside has not been cancelled under regulation 25 Or as regards the Islands, this means that you are satisfied from the information available to you that the applicant has either been: • given notice in writing under paragraphs 256 to 257A of the Immigration Rules of the Bailiwick of Guernsey showing that they may remain indefinitely, and this notice has not been revoked or otherwise ceased to be effective • issued by the relevant Minister with a document in accordance with paragraphs 255 to 258 of the Immigration Rules of the Bailiwick of Jersey in an appropriate form certifying permanent residence, and this document has not been revoked or otherwise ceased to be effective • issued with a letter certifying permanent residence, or their passport has been stamped to that effect, under the Immigration (European Economic Area) Regulations of the Isle of Man, and this has not been revoked, invalidated or cancelled It also means both that: • the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years, at any point since they last acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations (or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the EEA Regulations of the Isle of Man) or since they last completed a continuous qualifying period of 5 years • none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: o any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) o a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) o an exclusion decision o a deportation order, other than by virtue of the EEA Regulations o an Islands deportation order o an Islands exclusion decision Indefinite leave to enter or remain held since before the end of the transition period An EEA citizen will be eligible for ILE or ILR under the scheme, as a relevant EEA citizen under condition 2 in rule EU11, where, at the date of application, there is ‘valid evidence of their indefinite leave to enter or remain’, as defined in Annex 1 to Appendix EU. This means either: - a valid biometric immigration document (as defined in section 5 of the UK Borders Act 2007, and known as a biometric residence permit), a valid stamp or endorsement in a passport (whether or not the passport has expired) or other valid document issued by the Home Office, confirming that, at 11pm GMT on 31 December 2020, the applicant had indefinite leave to enter or remain in the UK, which has not since lapsed or been revoked or invalidated - you are otherwise satisfied from the evidence or information available to you (including from Home Office records) that, at 11pm GMT on 31 December 2020, the applicant had indefinite leave to enter or remain in the UK or the Islands, and this status both: - has not since lapsed through absence from the UK and Islands for a period of more than 2 consecutive years - has not since been revoked or invalidated Continuous qualifying period of 5 years An EEA citizen will be eligible for ILE or ILR under the scheme, as a relevant EEA citizen under condition 3 in rule EU11, where, at the date of application, they have completed a continuous qualifying period of residence in the UK and Islands of 5 years which began before the specified date – as a relevant EEA citizen, a family member of a relevant EEA citizen, a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, a person with a derivative right to reside, a person with a Zambrano right to reside, or a person who had a derivative or Zambrano right to reside, or in any combination of those categories. Where an applicant relies on more than one of those categories in order to complete their continuous qualifying period of 5 years, there can be no gap between the periods of qualification under each category relied upon. This does not affect the absences from the UK and Islands which are permitted during a continuous qualifying period. And where no supervening event has occurred in respect of the applicant, which means both that since completing that 5 year period: - they have not been absent from the UK and Islands for a period of more than 5 consecutive years - none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) an exclusion decision a deportation order, other than by virtue of the EEA Regulations an Islands deportation order an Islands exclusion decision Ceased activity An EEA citizen will be eligible for ILE or ILR under the scheme, as a relevant EEA citizen under condition 4 in rule EU11, having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began before the specified date, where, at the date of application, they either: - were a worker or self-employed person in the UK (within the meaning of the EEA Regulations) and then terminated that activity, having reached the age of entitlement to a state pension or, in the case of a worker, having taken early retirement and immediately before that they had both: - been a worker or self-employed person in the UK for at least the preceding 12 months - resided in the UK and Islands for a continuous qualifying period of more than 3 years which began before the specified date - stopped being a worker or self-employed person in the UK owing to permanent incapacity to work and either: - had resided in the UK and Islands for a continuous qualifying period of more than the preceding 2 years which began before the specified date - the incapacity resulted from an accident at work or an occupational disease that entitles the person to a pension payable in full or in part by an institution in the UK - resided in the UK for a continuous qualifying period of at least 3 years as a worker or self-employed person which began before the specified date, immediately before becoming a worker or self-employed person in an EEA country or Switzerland (see: the countries listed in sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU), while retaining a place of residence in the UK to which they return, as a rule, at least once a week The conditions as to length of residence and length of employment in the first 2 provisions above do not apply where you are satisfied (including by the required evidence of family relationship) that the relevant EEA citizen is the spouse or civil partner of a British citizen. And, in any case, no supervening event has occurred, which means both that since the relevant EEA citizen ceased activity: they have not been absent from the UK and Islands for a period of more than 5 consecutive years none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision For further information on how to consider an application that meets these requirements see consideration of applications for indefinite leave to enter (ILE) or indefinite leave to remain (ILR). Child under the age of 21 An EEA citizen will be eligible for ILE or ILR under the scheme as a child under the age of 21 under condition 7 in rule EU11, including where they have a continuous qualifying period of residence in the UK and Islands of less than 5 years which began before the specified date, where, at the date of application: - you are satisfied, including by the required evidence of family relationship, that they are a family member of a relevant EEA citizen and a child under the age of 21 of a relevant EEA citizen or of their spouse or civil partner (see assessing family relationship) and either: - the marriage was contracted or the civil partnership was formed before the specified date - the person who is now the spouse or civil partner of the relevant EEA citizen was their durable partner before the specified date and the partnership remained durable at the specified date In addition, where the date of application by the child is before 1 July 2021, either the relevant EEA citizen (or, as the case may be, their spouse or civil partner): - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - is an Irish citizen who, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application (where the applicant is the family member ("F") to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of the relevant definition in Annex 1 to Appendix EU) Or, in addition, where the date of application by the child is on or after 1 July 2021, either the relevant EEA citizen (or, as the case may be, their spouse or civil partner): - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (a), (c) and (d) of the relevant definition in Annex 1 to Appendix EU) who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member ("F") to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application Continuous qualifying period of less than 5 years An EEA citizen who, at the date of application, has completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began before the specified date, and who does not qualify under one of the routes to ILE or ILR for those with a continuous qualifying period of residence in the UK and Islands of less than 5 years, will be eligible for 5 years' limited leave to enter or remain as a relevant EEA citizen under condition 1 in rule EU14. For further information on how to consider an application that meets these requirements see consideration of applications - limited leave to enter (LTE) or remain (LTR). Related content Contents Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Eligibility: family members of a relevant EEA citizen Who can apply as a family member of a relevant EEA citizen? To apply under the family member of a relevant European Economic Area (EEA) citizen provisions (save as a dependent relative of a specified relevant person of Northern Ireland), an applicant must have been resident by 11pm GMT on 31 December 2020 on a basis which met the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU and thereafter not have broken the continuity of their residence. The following EEA citizen or non-EEA citizen family members of an EEA citizen who do not meet the definition of ‘joining family member of a relevant sponsor’ may be eligible to apply: - spouse, where either: - the marriage was contracted before the specified date - the applicant was the durable partner of the relevant EEA citizen before the specified date (the definition of ‘durable partner’ in Annex 1 to Appendix EU being met before that date rather than at the date of application) and the partnership remained durable at the specified date - civil partner, where either: - the civil partnership was formed before the specified date - the applicant was the durable partner of the relevant EEA citizen before the specified date (the definition of ‘durable partner’ in Annex 1 to Appendix EU being met before that date rather than at the date of application) and the partnership remained durable at the specified date - durable partner (unmarried partner whose relationship is akin to marriage or civil partnership, and the applicant holds a relevant document in this capacity, where they rely on residence in the UK in that capacity before the specified date), where both: - the partnership was formed and was durable before the specified date - the partnership remains durable at the date of application (or did so for the relevant period or immediately before the death of the relevant EEA citizen) - child under 21 of the EEA citizen or of the spouse or civil partner and the family relationship existed before the specified date - dependent child over 21 of the EEA citizen or of the spouse or civil partner and the family relationship existed before the specified date - dependent parent of the EEA citizen or of the spouse or civil partner and the family relationship existed before the specified date - dependent relative of the EEA citizen or of the spouse or civil partner (in either case) before the specified date, and both: - the applicant holds a relevant document in this capacity - the dependency (or, as the case may be, their membership of the household or their strict need for personal care on serious health grounds) continues to exist at the date of application (or did so for the period of residence relied upon) In addition, where the applicant does not rely on meeting condition 1, 3 or 6 in rule EU11, or on being a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, the family relationship continues to exist at the date of application. Documented right of permanent residence A family member will be eligible for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) under the scheme, under condition 1 in rule EU11, as the family member of a relevant EEA citizen (or as a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen), where, at the date of application, they have a documented right of permanent residence, and since they did, no supervening event has occurred in respect of the applicant. This means that you are satisfied from the information available to you that the applicant has been issued with either: - a document certifying permanent residence under regulation 19 of the EEA Regulations - a permanent residence card (issued or renewed within the last 10 years) under regulation 19 of the EEA Regulations - a residence permit or residence document under the Immigration (European Economic Area) Order 1994 endorsed to show permission to remain in the UK indefinitely And in addition: - this document or card is not invalid under regulation 19(4)(c) - this document or card has not been revoked, and its renewal has not been refused, under regulation 24 (except where the revocation or refusal occurred because the person had been absent from the UK for a period of more than 2, and no more than 5, consecutive years) - the person’s right to reside has not been cancelled under regulation 25 Or as regards the Islands, this means that you are satisfied from the information available to you that the applicant has either been: - given notice in writing under paragraphs 256 to 257A of the Immigration Rules of the Bailiwick of Guernsey showing that they may remain indefinitely, and this notice has not been revoked or otherwise ceased to be effective - issued by the relevant Minister with a document in accordance with paragraphs 255 to 258 of the Immigration Rules of the Bailiwick of Jersey in an appropriate form certifying permanent residence or a permanent residence card, and this document or card has not been revoked or otherwise ceased to be effective - issued with a letter certifying permanent residence, or their passport has been stamped to that effect, under the Immigration (European Economic Area) Regulations of the Isle of Man, and this has not been revoked, invalidated or cancelled. It also means both that: - the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years, at any point since they last acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations (or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the EEA Regulations of the Isle of Man) or since they last completed a continuous qualifying period of 5 years - none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision Where the applicant has a documented right of permanent residence, their family relationship with a relevant EEA citizen, or the period in which they retained a right of residence by virtue of that relationship, may be in the past; it does not need to remain extant at the date of application. They do not therefore need to provide the required evidence of family relationship as this will have been confirmed when their right of permanent residence was documented under the EEA Regulations. Indefinite leave to enter or remain held since before the end of the transition period A family member will be eligible for ILE or ILR under the scheme, under condition 2 in rule EU11, as a family member of a relevant EEA citizen (or as [a family member who has retained the right of residence](#) by virtue of a relationship with a relevant EEA citizen), where, at the date of application, there is ‘valid evidence of their indefinite leave to enter or remain’, as defined in Annex 1 to Appendix EU. This means either: - a valid biometric immigration document (as defined in section 5 of the UK Borders Act 2007), a valid stamp or endorsement in a passport (whether or not the passport has expired) or other valid document issued by the Home Office, confirming that, at 11pm GMT on 31 December 2020, the applicant had indefinite leave to enter or remain in the UK, which has not since lapsed or been revoked or invalidated - you are otherwise satisfied from the evidence and information available to you (including from Home Office records) that, at 11pm GMT on 31 December 2020, the applicant had indefinite leave to enter or remain in the UK or the Islands, and this status both: - has not since lapsed through absence from the UK and Islands for a period of more than 2 consecutive years - has not since been revoked or invalidated It also means that you must be satisfied, including by the required evidence of family relationship, that, at the date of application, the applicant is the family member of a relevant EEA citizen (see assessing family relationship). Continuous qualifying period of 5 years A family member will be eligible for ILE or ILR under the scheme, as the family member of a relevant EEA citizen (or as a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen) under condition 3 in rule EU11, where, at the date application: - you are satisfied, including by the required evidence of family relationship, that the applicant is the family member of a relevant EEA citizen (see assessing family relationship) - they have completed a continuous qualifying period of residence in the UK and Islands of 5 years which (unless they are the dependent relative of a specified relevant person of Northern Ireland) began before the specified date as such a family member (or as a relevant EEA citizen, as a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, as a person with a derivative right to reside, as a person with a Zambrano right to reside, or as a person who had a derivative or Zambrano right to reside, or in any combination of those categories) - since completing that 5 year period, they have not been absent from the UK and Islands for a period of more than 5 consecutive years - since completing that 5 year period, none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision Where the applicant has completed a continuous qualifying period of residence in the UK and Islands of 5 years which (unless they are the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, as the family member of a relevant EEA citizen (or as a family member who has retained the right of residence by virtue of their relationship with a relevant EEA citizen), the family relationship or the period in which they retained a right of residence by virtue of that relationship, may be in the past; it does not need to remain extant at the date of application. Child under the age of 21 A child under the age of 21 will be eligible for ILE or ILR under the scheme under condition 7 in rule EU11, including where they have completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began before the specified date, where, at the date of application: - you are satisfied, including by the required evidence of family relationship, that they are a family member of a relevant EEA citizen and a child under the age of 21 of a relevant EEA citizen or of their spouse or civil partner (see assessing family relationship) and either: - the marriage was contracted or the civil partnership was formed before the specified date - the person who is now the spouse or civil partner of the relevant EEA citizen, was their durable partner before the specified date and the partnership remained durable at the specified date In addition, where the date of application by the child is before 1 July 2021, either the relevant EEA citizen (or, as the case may be, their spouse or civil partner): - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - is an Irish citizen who, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of the relevant definition in Annex 1 to Appendix EU) Or, in addition, where the date of application by the child is on or after 1 July 2021, either the relevant EEA citizen (or, as the case may be, their spouse or civil partner): - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (a), (c) and (d) of the relevant definition in Annex 1 to Appendix EU) who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application The relevant EEA citizen has ceased activity A family member will be eligible for ILE or ILR under the scheme – as the family member of a relevant EEA citizen who has ceased activity, under condition 5 in rule EU11 – having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began before the specified date, provided that, at the date of application, the relevant requirements set out below are met. Where the date of application is before 1 July 2021, the [relevant EEA citizen](#) either: - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application (where the applicant is the family member ("F") to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU Where the date of application is on or after 1 July 2021, the relevant EEA citizen either: - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen in accordance with sub-paragraphs (a), (c) and (d) of that definition in Annex 1 to Appendix EU who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member ("F") to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application In addition, whatever the date of application: - you are satisfied, including by the required evidence of family relationship, that the applicant was a family member of the relevant EEA citizen at the point at which the relevant EEA citizen became a person who has ceased activity (see assessing family relationship) - the applicant was also resident in the UK and Islands for a continuous qualifying period which (unless they are the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, immediately before the relevant EEA citizen became a person who has ceased activity And you are also satisfied that the relevant EEA citizen is a person who has ceased activity because one of the following applies: - the relevant EEA citizen was a worker or self-employed person in the UK (within the meaning of the EEA Regulations) and then terminated that activity, having reached the age of entitlement to a state pension or, in the case of a worker, having taken early retirement; and immediately before that they had both: - been a worker or self-employed person in the UK for at least the preceding 12 months - resided in the UK and Islands for a continuous qualifying period of more than 3 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - the relevant EEA citizen stopped being a worker or self-employed person owing to permanent incapacity to work and either: - had resided in the UK and Islands for a continuous qualifying period of more than the preceding 2 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - the incapacity resulted from an accident at work or an occupational disease that entitles the person to a pension payable in full or in part by an institution in the UK - the relevant EEA citizen resided in the UK for a continuous qualifying period of at least 3 years as a worker or self-employed person which, unless they are a specified relevant person of Northern Ireland, began before the specified date, immediately before becoming a worker or self-employed person in an EEA country or Switzerland (see: the countries listed in sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU), while retaining a place of residence in the UK to which they return, as a rule, at least once a week The conditions as to length of residence and of employment in the first and second provisions above do not apply where you are satisfied that (including by the required evidence of family relationship) that the relevant EEA citizen is the spouse or civil partner of a British citizen. And since the relevant EEA citizen became a person who has ceased activity, it is the case both that: - the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years - none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) an exclusion decision a deportation order, other than by virtue of the EEA Regulations an Islands deportation order an Islands exclusion decision The relevant EEA citizen has died A family member will be eligible for ILE or ILR under the scheme – as the family member of a relevant EEA citizen who has died, under condition 6 in rule EU11 – having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which (unless they were the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, where, at the date of application, the criteria in this section are met. To be eligible for ILE or ILR as a family member of a relevant EEA citizen who has died, all the following must be met: - you are satisfied, including by the required evidence of family relationship, that the applicant is a family member of a relevant EEA citizen (see assessing family relationship) and the relevant EEA citizen has died - the relevant EEA citizen must have been resident in the UK as a worker or self-employed person (within the meaning of the EEA Regulations) at the time of their death - the relevant EEA citizen must have been resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they were a specified relevant person of Northern Ireland, began before the specified date, immediately before dying, or the death must have been the result of an accident at work or an occupational disease - the applicant must have been resident in the UK with the relevant EEA citizen immediately before their death - since the death of the relevant EEA citizen, the applicant must not have been absent from the UK and Islands for a period of more than 5 consecutive years - since the death of the relevant EEA citizen, none of the following events must have occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision If the applicant does not meet these criteria, you must consider if they have retained a right of residence. A family member who has retained the right of residence Where the applicant is a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, they can qualify for ILE or ILR under condition 1 (documented right of permanent residence) or condition 2 (existing evidence of indefinite leave to enter or remain) in rule EU11, as set out above. Otherwise, where the applicant is a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, they will be eligible for ILE or ILR, under condition 3 in rule EU11, on the basis of having completed a continuous qualifying period of residence in the UK and Islands of 5 years, which (unless they were the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, as such a family member where the criteria in this section are met (or, prior to that, as a family member of a relevant EEA citizen, as a relevant EEA citizen, as a person with a derivative right to reside, as a person with a Zambrano right to reside or as a person who had a derivative or Zambrano right to reside, or in any prior combination of those categories). You must also be satisfied that since satisfying those criteria, the ‘required continuity of residence’ has been maintained by the applicant. This means that, where the applicant has not completed a continuous qualifying period of 5 years (and does not have valid evidence of their indefinite leave to enter or remain, and has not acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man), then, since the point at which (where they do so) they began to rely on being in the UK and Islands as a family member who has retained the right of residence and while they continued to do so, one of the events referred to in subparagraph (b)(i) or (b)(ii) in the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU has not occurred. To be eligible to apply for ILE or ILR as a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, on the basis of having completed a continuous qualifying period of residence in the UK and Islands of 5 years which (unless they were the dependent relative of a specified relevant person of Northern Ireland) began before the specified date (as set out above), you must be satisfied, including by the required evidence of family relationship (see assessing family relationship), that, at the date of application, the applicant is either: • an EEA citizen who was the family member of a relevant EEA citizen and that person died • a non-EEA citizen who was the family member of a relevant EEA citizen and that person died, and who was resident in the UK as the family member of that relevant EEA citizen for a continuous qualifying period of at least a year which (unless they were the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, immediately before the death of that person Or that the applicant is either: • an EEA or non-EEA citizen who is the child of a relevant EEA citizen who has died, or of their spouse or civil partner immediately before their death • an EEA or non-EEA citizen who is the child of a person who ceased to be a relevant EEA citizen on ceasing to reside in the UK, or of their spouse or civil partner at that point And, in either of the 2 bullet points immediately above, the child must have been attending a general educational course, apprenticeship or vocational training course in the UK immediately before the relevant EEA citizen died or ceased to be a relevant EEA citizen on ceasing to reside in the UK, and the child must continue to attend such a course. Or that the applicant is: • an EEA or non-EEA citizen who is the parent with custody of such a child (meaning that the child normally lives with them or does so part of the time, and includes arrangements which have been agreed informally and those which are subject to a court order for determining with whom the child is to live and when) Or that the following requirements are met: • the applicant is an EEA or non-EEA citizen who has ceased to be a family member of a relevant EEA citizen on the termination of the marriage or civil partnership of that relevant EEA citizen – and, for these purposes, where, after the initiation of the proceedings for that termination, that relevant EEA citizen ceased to be a relevant EEA citizen, they will be deemed to have remained a relevant EEA citizen until that termination • the applicant was resident in the UK at the date of the termination of the marriage or civil partnership • where the applicant is a non-EEA citizen, they meet one of the following: o prior to the initiation of the proceedings for the termination of the marriage or civil partnership, the marriage or civil partnership had lasted for at least 3 years and during its duration the parties to the marriage or civil partnership had been resident in the UK for a continuous qualifying period of at least one year which began before the specified date o the applicant has custody of a child of the relevant EEA citizen o the applicant has the right of access to a child of the relevant EEA citizen, where the child is under the age of 18 years and where a court has ordered that such access must take place in the UK the continued right of residence in the UK of the applicant is warranted by particularly difficult circumstances, such as where the applicant or another family member has been a victim of domestic violence or abuse whilst the marriage or civil partnership was subsisting Or that the applicant both: - is an EEA or non-EEA citizen who provides evidence that a relevant family relationship with a relevant EEA citizen has broken down permanently as a result of domestic violence or abuse - was resident in the UK when the relevant family relationship broke down permanently as a result of domestic violence or abuse, and the continued right of residence in the UK of the applicant is warranted where the applicant or another family member has been a victim of domestic violence or abuse before the relevant family relationship broke down permanently 'Relevant family relationship' means here a family relationship with a relevant EEA citizen such that the applicant is, or (immediately before the relevant family relationship broke down permanently as a result of domestic violence or abuse) was, a family member of a relevant EEA citizen. Where, following the permanent breakdown of the relevant family relationship as a result of domestic violence or abuse, the applicant remains a family member of a relevant EEA citizen, they will be deemed to have ceased to be such a family member for the purposes of Appendix EU once the permanent breakdown occurred. Where the applicant is applying on the basis that their continued right of residence in the UK is warranted where they or another family member have been a victim of domestic violence or abuse before the relevant family relationship broke down permanently, the applicant does not need to provide evidence which satisfies you that they remain dependent on the relevant EEA citizen or (where relevant) on the spouse or civil partner, if the applicant is either: - a child aged 21 or over of a relevant EEA citizen (or of their spouse or civil partner) and was not previously granted limited leave to enter or remain under Appendix EU (or under its equivalent in the Islands) as a child under the age of 21 (and has not turned 21 since the specified date) - the dependent parent of a relevant EEA citizen who is aged under 18 And, in any case, to be eligible for ILE or ILR on the basis of a continuous qualifying period of 5 years which (unless they were the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, including as a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, then since completing that 5 year period both the following must apply: - the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years - none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision For further information on how to consider an application that meets any of these requirements for ILE or ILR, see consideration of applications for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) below. Continuous qualifying period of less than 5 years A family member of a relevant EEA citizen, or a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, who, at the date of application, has completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which (unless they are the dependent relative of a specified relevant person of Northern Ireland) began before the specified date, and who does not qualify under one of the routes to ILR or ILE for those who have completed such a continuous qualifying period of less than 5 years, will – in the case of a family member of a relevant EEA citizen, where there has been no supervening event in respect of the relevant EEA citizen – be eligible for 5 years' limited leave to enter or limited leave to remain (LTE or LTR), under condition 1 in rule EU14. For further information on how to consider an application that meets these requirements see consideration of applications - limited leave to enter (LTE) or remain (LTR). --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Eligibility: joining family members of a relevant sponsor Who can apply as a joining family member of a relevant sponsor? The following European Economic Area (EEA) citizen or non-EEA citizen family members of an EEA citizen who is a relevant sponsor may be eligible to apply as a joining family member of a relevant sponsor: - spouse, where both: - the marriage was contracted before the specified date or the applicant was the durable partner of the relevant sponsor before the specified date (the definition of ‘durable partner’ in Annex 1 to Appendix EU being met before that date rather than at the date of application) and the partnership remained durable at the specified date - the marriage continues to exist at the date of application, unless the applicant relies on meeting condition 1 in rule EU11A of Appendix EU (and if they do, the marriage existed for the relevant period), or on meeting condition 3 in rule EU11A (and if they do, the marriage existed immediately before the death of the relevant sponsor) or on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - civil partner, where both: - the civil partnership was formed before the specified date or the applicant was the durable partner of the relevant sponsor before the specified date (the definition of ‘durable partner’ in Annex 1 to Appendix EU being met before that date rather than at the date of application) and the partnership remained durable at the specified date - the civil partnership continues to exist at the date of application, unless the applicant relies on meeting condition 1 of paragraph EU11A of Appendix EU (and if they do, the civil partnership existed for the relevant period), or on meeting condition 3 in rule EU11A (and if they do, the civil partnership existed immediately before the death of the relevant sponsor) or on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - specified spouse or civil partner of a Swiss citizen, where both: - the marriage was contracted or the civil partnership was formed after the specified date and before 1 January 2026 - the marriage or civil partnership continues to exist at the date of application, unless the applicant relies on meeting condition 1 in rule EU11A of Appendix EU (and if they do, the marriage or civil partnership existed for the relevant period), or on meeting condition 3 in rule EU11A (and if they do, the marriage or civil partnership existed immediately before the death of the relevant sponsor) or on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - durable partner, where both: the partnership was formed and was durable before the specified date - the durable partnership remains durable at the date of application, unless the applicant relies on meeting condition 1 in rule EU11A of Appendix EU (and if they do, the durable partnership remained durable for the relevant period), or condition 3 in rule EU11A (and if they do, the durable partnership remained durable immediately before the death of the relevant sponsor) or on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - child under 21 of the relevant sponsor or of the spouse or civil partner, where the family relationship or relationships existed before the specified date (unless the child, after that date, was born or was adopted in accordance with a relevant adoption decision or became a child within the meaning of that definition in Annex 1 to Appendix EU on the basis of one of sub-paragraphs (a)(iii) to (a)(xi)) and continue or continues to exist at the date of application (or did so for the period of residence relied upon) - dependent child over 21 of the relevant sponsor or of the spouse or civil partner, where the family relationship or relationships existed before the specified date (unless the child, after that date, was born or was adopted in accordance with a relevant adoption decision or became a child within the meaning of that definition in Annex 1 to Appendix EU on the basis of one of sub-paragraphs (a)(iii) to (a)(xi)) and continue or continues to exist at the date of application (or did so for the period of residence relied upon) - dependent parent of the relevant sponsor or of the spouse or civil partner, where the family relationship(s) existed before the specified date and continue or continues to exist at the date of application (or did so for the period of residence relied upon) In addition, the applicant must meet one of the following requirements: - under sub-paragraph (a) (where sub-paragraph (c) or (d) as described below does not apply), they were not resident in the UK and Islands on a basis which met the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU (where that relevant EEA citizen is their relevant sponsor) at any time before the specified date - under sub-paragraph (b) (where sub-paragraph (c) or (d) as described below does not apply), they were resident in the UK and Islands before the specified date, and either: - one of the events referred to in sub-paragraph (b)(i) or (b)(ii) in the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU has occurred, and after that event occurred they were not resident in the UK and Islands again before the specified date - the event referred to in sub-paragraph (a) in the definition of ‘supervening event’ in Annex 1 to Appendix EU has occurred, and after that event occurred they were not resident in the UK and Islands again before the specified date - they are the specified spouse or civil partner of a Swiss citizen, and they do not rely on any period of residence in the UK and Islands before the marriage was contracted or the civil partnership was formed - under sub-paragraph (c) (where sub-paragraph (d) as described below does not apply), where the person is a child born after the specified date or adopted after that date in accordance with a relevant adoption decision, or after the specified date became a child within the definition in Annex 1 to Appendix EU on the basis of one of sub-paragraphs (a)(iii) to (a)(xi) of that entry (with the references below to ‘parents’ construed to include the guardian or other person to whom the order or other provision referred to in the relevant sub-paragraph of (a)(iii) to (a)(xi) of that entry relates), one of the following requirements is met: - both of their parents are a relevant sponsor - one of their parents is a relevant sponsor and the other is a British citizen who is not a relevant sponsor - one of their parents is a relevant sponsor who has sole or joint rights of custody of them, in accordance with the applicable rules of family law of the UK, of the Islands or of an EEA country or Switzerland (including applicable rules of private international law under which rights of custody under the law of a third country are recognised in the UK, in the Islands or in an EEA country or Switzerland, in particular as regards the best interests of the child, and without prejudice to the normal operation of such applicable rules of private international law) - under sub-paragraph (d), where the person is a child born after the specified date to (or adopted after that date in accordance with a relevant adoption decision by or after that date became, within the meaning of the entry for ‘child’ in Annex 1 to Appendix EU and on the basis of one of sub-paragraphs (a)(iii) to (a)(xi) of that entry, a child of) a Swiss citizen or their spouse or civil partner (as described above in relation to sub-paragraph (a)), the Swiss citizen or their spouse or civil partner is a relevant sponsor Relevant sponsor Where the date of application is after the specified date and before 1 July 2021, a relevant sponsor is either: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) either: - resident in the UK and Islands for a continuous qualifying period which began before the specified date - having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (b) of that definition in Annex 1 to Appendix EU): a relevant naturalised British citizen, in accordance with sub-paragraph (a) or (b), together with sub-paragraphs (c) and (d), of that definition in Annex 1 - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU): a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, either: - resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date - is an Irish citizen who, having been resident in the UK and Islands as described above, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control either: - resident in the UK and Islands for a continuous qualifying period which began before the specified date - having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a frontier worker, in accordance with that definition in Annex 1 to Appendix EU Where the date of application is on or after 1 July 2021, a relevant sponsor is either: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated - an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (b) of that definition in Annex 1 to Appendix EU) who is a relevant naturalised British citizen, in accordance with sub-paragraphs (a), (c) and (d) of that definition in Annex 1, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland in accordance with sub-paragraph (a)(ii) of the definition in Annex 1 to Appendix EU (such as an Irish citizen) and who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (if had they made a valid application under Appendix EU before 1 July 2021), which would not have lapsed or been cancelled, revoked or invalidated before the date of application - has been granted limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated - would have been granted limited leave to enter or remain under paragraph EU3 of Appendix EU (if had they made a valid application under Appendix EU before 1 July 2021), which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland in accordance with sub-paragraph (a)(i) or (a)(iii) of the definition in Annex 1 to Appendix EU (such as a British citizen or a British citizen and an Irish citizen) and who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date, and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - a frontier worker, in accordance with that definition in Annex 1 to Appendix EU In addition: - save for the purposes of condition 3 in rule EU11A and of sub-paragraphs (a) and (b) of the definition of ‘family member who has retained the right of residence’ in Annex 1 to Appendix EU, the relevant sponsor has not died - where the date of application by a joining family member of a relevant sponsor is on or after 1 July 2021, it will suffice that the relevant sponsor is or (as the case may be) was resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date where the applicant either: - on the basis of events which occurred during the period to which subparagraph (a)(ii)(aa) or (a)(iii)(aa) of the definition of ‘required date’ in Annex 1 to Appendix EU refers, relies on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, or has limited leave to enter or remain granted on that basis under rule EU3A - relies on meeting condition 3 in rule EU11A - has limited leave to enter or remain granted under rule EU3A and would have been eligible for indefinite leave to enter or remain under condition 1, 2 or 3 in rule EU11A, had they made a further valid application under Appendix EU (subsequently to that which led to the grant of that limited leave) before the indefinite or limited leave to enter or remain granted under rule EU2 or EU3 to their relevant sponsor lapsed or was cancelled, curtailed, revoked or invalidated (or, where relevant, would have done so or been so) Not in the UK as a visitor Where the application is made within the UK and was decided before 6 October 2021 (the date that relevant changes to Appendix EU made in Statement of Changes in Immigration Rules: HC 617 came into effect), then, to meet the eligibility requirements for indefinite leave to remain (under rule EU11A) or limited leave to remain (under rule EU14A) as a joining family member of a relevant sponsor, the applicant must not have been in the UK at the date of application as a ‘visitor’, in accordance with the relevant definition then in Annex 1 to Appendix EU. This meant that, subject to limited exceptions, the applicant must not have been granted leave under paragraphs 40-56Z, 75A-M or 82-87 of the Immigration Rules in force before 24 April 2015 or Appendix V on or after 24 April 2015 or Appendix V: Visitor after 9am on 1 December 2020, and was not a person to whom article 4 or 6 of the Immigration (Control of Entry through Republic of Ireland) Order 1972 applied. For applications decided from 6 October 2021, the requirement not to be in the UK as a visitor was removed from Appendix EU (by virtue of the changes made in Statement of Changes in Immigration Rules: HC 617). This means that applicants are no longer required not to be in the UK as a visitor to qualify for leave under Appendix EU as a joining family member of a relevant sponsor. The requirement that, in an application decided before 6 October 2021 (the date that relevant changes to Appendix EU made in Statement of Changes in Immigration Rules: HC 617 came into effect), a person applying as a joining family of a relevant sponsor must not have been in the UK at the date of application as a ‘visitor’, in accordance with the relevant definition then in Annex 1 to Appendix EU, was disapplied, as a temporary concession outside Appendix EU, where the applicant entered the UK as a visitor on or after 1 January 2021. Continuous qualifying period of 5 years In an application made after the specified date, an applicant will be eligible for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) under the scheme, as the joining family member of a relevant sponsor (or as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor) under condition 1 in rule EU11A, where at the date of application: - you are satisfied, including by the required evidence of family relationship, that the applicant is the joining family member of a relevant sponsor (see assessing family relationship) - they have completed a continuous qualifying period of residence in the UK and Islands of 5 years which began after the specified date as such a joining family member (or as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, or in any combination of those categories) - since completing that 5 year period, they have not been absent from the UK and Islands for a period of more than 5 consecutive years - since completing that 5 year period, none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision Where the applicant has completed a continuous qualifying period of residence in the UK and Islands of 5 years as the joining family member of a relevant sponsor (or as a family member who has retained the right of residence by virtue of their relationship with a relevant sponsor), the family relationship or the period in which they retained a right of residence by virtue of that relationship, may be in the past; it does not need to remain extant at the date of application. Where the applicant arrived in the UK as a joining family member and at that point had another form of immigration leave or was exempt from immigration control, their continuous qualifying period of residence in the UK as a joining family member (or as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor) can include the period in the UK in which they held that other form of immigration leave or were exempt from immigration control. Child under the age of 21 In an application made after the specified date, a child under the age of 21 will be eligible for ILE or ILR under the scheme under condition 4 in rule EU11A, including where they have completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began after the specified date, where, at the date of application, you are satisfied, including by the required evidence of family relationship, that they are the joining family member of a relevant sponsor and the relevant requirements below are met. Where the date of application is before 1 July 2021, either: - they are a child under the age of 21 of a relevant sponsor (see assessing family relationship), and the relevant sponsor is: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - an Irish citizen who is an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU): a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU): a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application a relevant naturalised British citizen, in accordance with sub-paragraphs (b), (c) and (d), of that definition in Annex 1 to Appendix EU they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: meets the requirements of sub-paragraph (a) of the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU, substituting ‘relevant sponsor’ for each reference in that sub-paragraph to ‘relevant EEA citizen’ has been or is being granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: meets the requirements of the first sub-paragraph (a), together with either the second sub-paragraph (a) or sub-paragraph (b)(i) or (b)(ii), of the definition of ‘joining family member of a relevant sponsor’ in Annex 1 to Appendix EU has been or is being granted indefinite leave to enter or remain under paragraph EU2A of Appendix EU Where the date of application is on or after 1 July 2021, either: - they are a child under the age of 21 of a relevant sponsor (see assessing family relationship), and the relevant sponsor is: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen who, having resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (a), (c) and (d), of that definition in Annex 1 to Appendix EU, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated; or, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: - meets the requirements of sub-paragraph (a) of the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU, substituting ‘relevant sponsor’ for each reference in that sub-paragraph to ‘relevant EEA citizen’ - has been or is being granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU - they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: - meets the requirements of the first sub-paragraph (a), together with either the second sub-paragraph (a) or sub-paragraph (b)(i) or (b)(ii), of the definition of ‘joining family member of a relevant sponsor’ in Annex 1 to Appendix EU - has been or is being granted indefinite leave to enter or remain under paragraph EU2A of Appendix EU The relevant sponsor has ceased activity In an application made after the specified date, an applicant will be eligible for ILE or ILR under the scheme – as the joining family member of a relevant sponsor who has ceased activity, under condition 2 in rule EU11A – having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began after the specified date and the relevant requirements below are met. Where the date of application is before 1 July 2021, the relevant sponsor is either: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU): a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU Where the date of application is on or after 1 July 2021, the relevant sponsor is either: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen who, having resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (a), (c) and (d), of that definition in Annex 1 to Appendix EU, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application In addition, whatever the date of application, both: - you are satisfied, including by the required evidence of family relationship, that the applicant was a joining family member of the relevant sponsor at the point at which the relevant sponsor became a person who has ceased activity (see assessing family relationship) - immediately before the relevant sponsor became a person who has ceased activity, the applicant was resident in the UK and Islands for a continuous qualifying period which began after the specified date And you are also satisfied that the relevant sponsor is a person who has ceased activity because one of the following applies: - the relevant sponsor was a worker or self-employed person in the UK (within the meaning of the EEA Regulations) and then terminated that activity, having reached the age of entitlement to a state pension or, in the case of a worker, having taken early retirement; and immediately before that they had both: - been a worker or self-employed person in the UK for at least the preceding 12 months - resided in the UK and Islands for a continuous qualifying period of more than 3 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - the relevant sponsor stopped being a worker or self-employed person owing to permanent incapacity to work and either: had resided in the UK and Islands for a continuous qualifying period of more than the preceding 2 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - the incapacity resulted from an accident at work or an occupational disease that entitles the person to a pension payable in full or in part by an institution in the UK - the relevant sponsor resided in the UK for a continuous qualifying period of at least 3 years as a worker or self-employed person which, unless they are a specified relevant person of Northern Ireland, began before the specified date, immediately before becoming a worker or self-employed person in an EEA country or Switzerland (see: the countries listed in sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU), while retaining a place of residence in the UK to which they return, as a rule, at least once a week. The conditions as to length of residence and of employment in the first and second provisions above do not apply where you are satisfied that (including by the required evidence of family relationship) that the relevant sponsor is the spouse or civil partner of a British citizen. And since the relevant sponsor became a person who has ceased activity, it is the case both that: - the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years - none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision The relevant sponsor has died In an application made after the specified date, an applicant will be eligible for ILE or ILR under the scheme – as the joining family member of a relevant sponsor who has died, under condition 3 in rule EU11A – having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years which began after the specified date, where the criteria in this section are met. To be eligible for ILE or ILR as a joining family member of a relevant sponsor who has died, all the following must be met: • you are satisfied, including by the required evidence of family relationship, that the applicant is a joining family member of a relevant sponsor (see assessing family relationship) and the relevant sponsor has died • the relevant sponsor must have been resident in the UK as a worker or self-employed person (within the meaning of the EEA Regulations) at the time of their death • the relevant sponsor must have been resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they were a specified relevant person of Northern Ireland, began before the specified date, immediately before dying, or the death must have been the result of an accident at work or an occupational disease • the applicant must have been resident in the UK with the relevant sponsor after the specified date and immediately before their death • since the death of the relevant sponsor, the applicant must not have been absent from the UK and Islands for a period of more than 5 consecutive years • since the death of the relevant sponsor, none of the following events must have occurred in respect of the applicant, unless it has been set aside or revoked: o any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) o a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) o an exclusion decision o a deportation order, other than by virtue of the EEA Regulations o an Islands deportation order o an Islands exclusion decision If the applicant does not meet these criteria, you must consider if they have retained a right of residence. A family member who has retained the right of residence Where the applicant is a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, they will be eligible for ILE or ILR, under condition 1 in rule EU11A, on the basis of having completed a continuous qualifying period of residence in the UK and Islands of 5 years which began after the specified date, as such a family member where the criteria in this section are met (or, prior to that, as a joining family member of a relevant sponsor, or in any combination of those categories). You must also be satisfied that since satisfying those criteria, the ‘required continuity of residence’ has been maintained by the applicant. This means that, where the applicant has not completed a continuous qualifying period of 5 years (and does not have valid evidence of their indefinite leave to enter or remain, and has not acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man), then, since the point at which (where they do so) they began to rely on being in the UK and Islands as a family member who has retained the right of residence and while they continued to do so, one of the events referred to in sub-paragraph (b)(i) or (b)(ii) in the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU has not occurred. Where the date of application by a joining family member of a relevant sponsor is on or after 1 July 2021, it will suffice that the relevant sponsor is or (as the case may be) was resident in the UK and Islands for a continuous qualifying period which began before the specified date where the applicant – on the basis of events which occurred during the period to which sub-paragraph (a)(ii)(aa) or (a)(iii)(aa) of the definition of ‘required date’ in Annex 1 to Appendix EU refers – relies on being a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, or has limited leave to enter or remain granted on that basis under rule EU3A. To be eligible to apply for ILE or ILR as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, on the basis of having completed a continuous qualifying period of residence in the UK and Islands of 5 years which began after the specified date (as set out above), you must be satisfied, including by the required evidence of family relationship (see assessing family relationship), that, at the date of application, the applicant is either: - an EEA citizen who was the joining family member of a relevant sponsor and that person died - a non-EEA citizen who was the joining family member of a relevant sponsor and that person died, and who was resident in the UK as the joining family member of that relevant sponsor for a continuous qualifying period of at least a year which began after the specified date, immediately before the death of that person Or that the applicant is either: - an EEA or non-EEA citizen who is the child of a relevant sponsor who has died, or of their spouse or civil partner immediately before their death - an EEA or non-EEA citizen who is the child of a person who ceased to be a relevant sponsor on ceasing to reside in the UK, or of their spouse or civil partner at that point And, in either of the 2 bullet points immediately above, the child must have been attending a general educational course, apprenticeship or vocational training course in the UK immediately before the relevant sponsor died or ceased to be a relevant sponsor on ceasing to reside in the UK, and the child must continue to attend such a course. Or that the following requirements are met: - the applicant is an EEA or non-EEA citizen who has ceased to be a joining family member of a relevant sponsor on the termination of the marriage or civil partnership of that relevant sponsor – and, for these purposes, where, after the initiation of the proceedings for that termination, that relevant sponsor ceased to be a relevant sponsor, they will be deemed to have remained a relevant sponsor until that termination - the applicant was resident in the UK at the date of the termination of the marriage or civil partnership - where the applicant is a non-EEA citizen, they meet one of the following: - prior to the initiation of the proceedings for the termination of the marriage or civil partnership, the marriage or civil partnership had lasted for at least 3 years and during its duration the parties to the marriage or civil partnership had been resident in the UK for a continuous qualifying period of at least one year - the applicant has custody of a child of the relevant sponsor - the applicant has the right of access to a child of the relevant sponsor, where the child is under the age of 18 years and where a court has ordered that such access must take place in the UK - the continued right of residence in the UK of the applicant is warranted by particularly difficult circumstances, such as where the applicant or another family member has been a victim of domestic violence or abuse whilst the marriage or civil partnership was subsisting Or that the applicant both: - is an EEA or non-EEA citizen who provides evidence that a relevant family relationship with a relevant sponsor has broken down permanently as a result of domestic violence or abuse - was resident in the UK when the relevant family relationship broke down permanently as a result of domestic violence or abuse, and the continued right of residence in the UK of the applicant is warranted where the applicant or another family member has been a victim of domestic violence or abuse before the relevant family relationship broke down permanently ‘Relevant family relationship’ means here a family relationship with a relevant sponsor such that the applicant is, or (immediately before the relevant family relationship broke down permanently as a result of domestic violence or abuse) was, a joining family member of a relevant sponsor. Where, following the permanent breakdown of the relevant family relationship as a result of domestic violence or abuse, the applicant remains a joining family member of a relevant sponsor, they will be deemed to have ceased to be such a family member for the purposes of Appendix EU once the permanent breakdown occurred. Where the applicant is applying on the basis that their continued right of residence in the UK is warranted where they or another family member have been a victim of domestic violence or abuse before the relevant family relationship broke down permanently, the applicant does not need to provide evidence which satisfies you that they remain dependent on the relevant sponsor or (where relevant) on the spouse or civil partner, if the applicant is either: • a child aged 21 or over of a relevant sponsor (or of their spouse or civil partner) and was not previously granted limited leave to enter or remain under Appendix EU (or under its equivalent in the Islands) as a child under the age of 21 • the dependent parent of a relevant sponsor who is aged under 18 And, in any case, to be eligible for ILE or ILR on the basis of a continuous qualifying period of 5 years which began after the specified date, including as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, then since completing that 5 year period both the following must apply: • the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years • none of the following events has occurred in respect of the applicant, unless it has been set aside or revoked: o any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) o a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) o an exclusion decision o a deportation order, other than by virtue of the EEA Regulations o an Islands deportation order o an Islands exclusion decision For further information on how to consider an application that meets any of these requirements for ILE or ILR, see consideration of applications for indefinite leave to enter (ILE) or indefinite leave to remain (ILR). Continuous qualifying period of less than 5 years Where the application is made within the UK, and in an application made after the specified date, a joining family member of a relevant sponsor, or a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, will – in the case of a joining family member of a relevant sponsor, where there has been no supervening event in respect of the relevant sponsor – be eligible for 5 years’ limited leave to remain (LTR) under the condition in rule EU14A if they are not eligible for ILR under rule EU11A solely because, at the date of application, they have completed a continuous qualifying period of residence in the UK and Islands, which began after the specified date, of less than 5 years. Where the application is made outside the UK, and in an application made after the specified date, a joining family member of a relevant sponsor, or a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, who, at the date of application, is not eligible for ILE under rule EU11A, will – in the case of a joining family member of a relevant sponsor, where there has been no supervening event in respect of the relevant sponsor – be eligible for 5 years’ limited leave to enter (LTE) under the condition in rule EU14A. For further information on how to consider an application that meets these requirements see consideration of applications - limited leave to enter (LTE) or remain (LTR). Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Assessing family relationship Where the applicant is a European Economic Area (EEA) citizen resident in the UK by 11pm GMT on 31 December 2020 as a family member of an EEA citizen also resident here by 11pm GMT on 31 December 2020, the applicant will be able to rely on their own continuity of residence as a relevant EEA citizen to apply for status. They will not need to provide evidence of their family relationship to that EEA citizen unless: - they are relying on that relationship in one of the categories eligible for settled status having completed a continuous qualifying period of residence in the UK and Islands of less than 5 years - they are applying as a child under the age of 21 of a relevant EEA citizen (or of their spouse or civil partner) under condition 7 in rule EU11 - they are applying as a family member of a relevant person of Northern Ireland - they are relying on a retained right of residence by virtue of a relationship with a relevant EEA citizen after that relationship has ended - they became an EEA citizen within a period of continuous residence in which they otherwise rely on having been a non-EEA citizen family member of an EEA citizen Otherwise, the following family members of a relevant EEA citizen (or qualifying British citizen, under rules EU12 and EU14 of Appendix EU, or relevant sponsor under rules EU11A and EU14A) will be eligible to apply for status under the scheme on the basis of their relationship to that relevant EEA citizen (or qualifying British citizen or relevant sponsor). The following detailed criteria apply in respect of each of these categories of family member at the date the person applies under the scheme. Spouse The applicant is (or for the relevant period was) party to a marriage with the relevant EEA citizen (or qualifying British citizen or relevant sponsor) and the marriage is recognised under the law of England and Wales, Scotland or Northern Ireland or of the Islands; and it is (or for the relevant period was) not a marriage of convenience; and neither spouse has (or for the relevant period had) another spouse, a civil partner or a durable partner with immigration status in the UK or the Islands based on that person’s relationship with that spouse. Where the applicant does not already hold a permanent residence document, a spouse must provide evidence of the family relationship for the relevant period, namely a relevant document as the spouse of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or a valid document of record of a marriage recognised under the law of England and Wales, Scotland or Northern Ireland or of the Islands. Where the marriage to the relevant EEA citizen (or the relevant sponsor) was contracted after the specified date and the applicant is not the specified spouse or civil partner of a Swiss citizen, they must also provide either: • a relevant document as the durable partner of the relevant EEA citizen • where the applicant is the joining family member of a relevant sponsor or relies on the relevant EEA citizen being a relevant person of Northern Ireland, evidence which satisfies you that the durable partnership was formed and was durable before the specified date Where the marriage to the qualifying British citizen was contracted after the date and time of withdrawal, they must also provide evidence which satisfies you that the durable partnership was formed and was durable before the date and time of withdrawal. Civil partner The applicant is (or for the relevant period was) in a valid civil partnership (which exists or existed under or by virtue of the Civil Partnership Act 2004 or under any equivalent legislation in the Islands) or in a relationship registered overseas (entitled to be treated as a civil partnership under that act or under any equivalent legislation in the Islands) with the relevant EEA citizen (or qualifying British citizen or relevant sponsor); it is (or for the relevant period was) not a civil partnership of convenience; and neither civil partner has (or for the relevant period had) another civil partner, a spouse or a durable partner with immigration status in the UK or the Islands based on that person’s relationship with that civil partner. Where the applicant does not already hold a permanent residence document, a civil partner must provide evidence of the family relationship for the relevant period, namely a relevant document as the civil partner of the relevant EEA citizen (or qualifying British citizen or relevant sponsor); a valid civil partnership certificate recognised under the law of England and Wales, Scotland or Northern Ireland or under any equivalent legislation in the Islands; or the valid overseas registration document for a relationship which is entitled to be treated as a civil partnership under the Civil Partnership Act 2004 or under any equivalent legislation in the Islands. Where the civil partnership to the relevant EEA citizen (or the relevant sponsor) was formed after the specified date and the applicant is not the specified spouse or civil partner of a Swiss citizen, they must also provide either: • a relevant document as the durable partner of the relevant EEA citizen • where the applicant is the joining family member of a relevant sponsor or relies on the relevant EEA citizen being a relevant person of Northern Ireland, evidence which satisfies you that the durable partnership was formed and was durable before the specified date Where the civil partnership to the qualifying British citizen was formed after the date and time of withdrawal, they must also provide evidence which satisfies you that the durable partnership was formed and was durable before the date and time of withdrawal. Specified spouse or civil partner of a Swiss citizen The applicant meets the applicable requirements above as the spouse or civil partner of a relevant sponsor who is a national of Switzerland and not also a British citizen, and the marriage was contracted or the civil partnership was formed after the specified date and before 1 January 2026. Durable partner The applicant is (or for the relevant period was) in a durable relationship with the relevant EEA citizen (or qualifying British citizen or relevant sponsor), with the couple having lived together in a relationship akin to a marriage or civil partnership for 2 years or more, unless there is other significant evidence of the durable relationship. The reference to the couple having lived together in a relationship akin to a marriage or civil partnership for at least 2 years is a rule of thumb, not a requirement. In circumstances where the couple have not lived together in a relationship akin to a marriage or civil partnership for at least for 2 years, you must consider whether there is other significant evidence of the durable relationship. Other significant evidence of the durable relationship may include for example evidence of joint responsibility for a child (a birth certificate or a custody agreement showing they are cohabiting and sharing parental responsibility), evidence of shared financial responsibilities or business ventures, or evidence of regular communication and visits while living apart alongside definite plans concerning the practicalities of living together in the UK. For a relationship to be akin to a marriage or civil partnership the couple must usually have lived together as a couple (not just as friends) and shown an ongoing commitment to one another. However, in some circumstances there may be evidence of a durable relationship akin to a marriage or civil partnership where the couple have not, or currently do not, live together. An applicant can show cohabitation by evidence of shared living arrangements, such as mortgage agreements, tenancy arrangements or utility bills which show both partners living at the same address over the same period of time. Such evidence does not need to be in both names if it covers the same time period and the same address. A relationship can still be recognised as meeting the requirement for a durable relationship where, for example, there is a good reason the partners were or are living apart which is still consistent with them having a relationship akin to a marriage or civil partnership. For example, they may have lived apart or currently do so because one party was or is studying or working elsewhere. In such circumstances you will need to be satisfied the relationship is durable even though they were or are living apart. For example, there may be evidence that although they are currently living apart, they have lived together in a durable relationship in the past and intend to do so again in the future. However, in some cases the couple may not have lived together and you will need to be satisfied the relationship is akin to a marriage or civil partnership. In some countries, religious or cultural norms may prevent unmarried partners living together and you will need to assess whether the relationship is similar to a marriage or civil partnership, in that it is more than a boyfriend/girlfriend type relationship. Instead of evidence of cohabitation, you will want to see other evidence of a durable relationship such as evidence of regular communication, visits, holidays, events attended, financial support, joint care of any children the partners have together or any other evidence showing a durable relationship. Where a same-sex couple have entered into their relationship in the UK or in a country where same-sex relationships are accepted, they will normally be expected to have cohabited unless there is a good reason they live apart. But in some countries same-sex relationships might not be recognised or accepted by the society, which in turn might make prevent same-sex partners living together. Where an applicant says this is the case, you must check the relevant Country Policy and Information Notes, to confirm this is consistent with the information available. Applicants are not encouraged to provide photographic evidence or evidence of interaction over email, WhatsApp or other social media as they can be falsified and are difficult to verify. However, this does not mean that such evidence has no weight at all. You must consider all the information and evidence provided by the applicant in the round. Where the couple have not lived together in a relationship akin to a marriage or civil partnership for at least for 2 years, you must consider in each case whether there is other significant evidence of a durable relationship, based on all the information and evidence provided by the applicant. The durable partnership must not be (or have been) one of convenience; and neither durable partner has (or for the relevant period had) another durable partner, a spouse or a civil partner with immigration status in the UK or the Islands based on that person’s relationship with that durable partner. Resident in the UK by 11pm on 31 December 2020 Where the applicant relies on being resident in the UK by 11pm on 31 December 2020 as the durable partner of the relevant EEA citizen (or qualifying British citizen) and does not hold a permanent residence document, the applicant must provide evidence of the family relationship for the relevant period, namely: - a relevant document as the durable partner of the relevant EEA citizen (or qualifying British citizen) for the period of residence relied upon, and evidence which satisfies you that the durable partnership remains durable at the date of application (or did so for the period of residence relied upon) - this evidence might, for example, take the form of: - evidence of cohabitation (such as bank statements or utility bills in joint names at the same address, residential tenancy or rental agreements or mortgage statements, official correspondence which links them at the same address) evidence of joint finances, business ventures or commitments (such as tax returns, business contracts, investments) This is not an exhaustive list and applications must be considered on a case by case basis. Where the applicant is a durable partner of a relevant person of Northern Ireland, a relevant document means, in accordance with sub-paragraph (a)(i)(bb) of the definition in Annex 1 to Appendix EU, other evidence which satisfies the Secretary of State of the same matters under Appendix EU concerning the relationship as a document to which sub-paragraph (a)(i)(aa) refers. For the purposes of this provision, where the Secretary of State is so satisfied, such evidence is deemed to be the equivalent of a document to which sub-paragraph (a)(i)(aa) refers. Where the applicant applies for a relevant document (as described in sub-paragraph (a)(i)(aa) or (a)(ii) of that definition in Annex 1 to Appendix EU) as the durable partner of the relevant EEA citizen (or qualifying British citizen) before the specified date and their relevant document is issued on that basis after the specified date, they are deemed to have held the relevant document since immediately before the specified date. Joining on or after 1 January 2021 Where the applicant is applying after the specified date as a joining family member who is the durable partner of a relevant sponsor (or of a qualifying British citizen), they can provide a relevant document as the durable partner of the relevant sponsor (or qualifying British citizen) for the period of residence relied upon, and evidence which satisfies you that the durable partnership remains durable at the date of application (or did so for the period of residence relied upon). Otherwise, the applicant must either: - not have been resident in the UK and Islands in any capacity before the specified date - not have been resident in the UK and Islands as the durable partner of the relevant EEA citizen (where that relevant EEA citizen is their relevant sponsor) on a basis which met the entry for ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU (or as the durable partner of the qualifying British citizen), at (in either case) any time before the specified date, unless (in the former case) the reason why they were not so resident is that they did not hold a relevant document as the durable partner of that relevant EEA citizen for that period and they otherwise had a lawful basis of stay in the UK and Islands (for example as a student) for that period – this means that a durable partner who did not hold a relevant document as the durable partner of a relevant EEA citizen for a period of residence in the UK and Islands before the specified date, and who did not otherwise have a lawful basis of stay in the UK and Islands for that period, cannot qualify as a joining family member on this basis - have been resident in the UK and Islands before the specified date, but their continuous qualifying period was interrupted by one of the following events, after which they were not resident in the UK and Islands again before the specified date, either: - absence or absences from the UK and Islands which exceeded a total of 6 months in any 12-month period, unless the absence absences fell within one or more of the specified exceptions - the applicant served a sentence of imprisonment of any length in the UK and Islands - have been resident in the UK and Islands before the specified date, and the applicant has then been absent from the UK and Islands for a period of more than 5 consecutive years (at any point since they last acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man, or since they last completed a continuous qualifying period of 5 years) and, after that, they were not resident in the UK and Islands again before the specified date. When considering whether a person with another lawful basis of stay in the UK and Islands before the specified date was the durable partner of a relevant EEA citizen before the specified date, only the period for which the person had another lawful basis of stay in the UK and Islands before that date can be considered for the purposes of assessing whether the partnership was durable before that date. Where the above criteria are met, you must be satisfied by evidence provided by the applicant that the partnership was formed and was durable before the specified date (or before the date and time of withdrawal, where the applicant relies on being the durable partner of a qualifying British citizen before that point), and that the durable partnership remains durable at the date of application (or did so for the period of residence relied upon). The effect of the above provisions is that, where, at the specified date, a person was continuously resident in the UK and Islands as the durable partner of a relevant EEA citizen (where that relevant EEA citizen is their relevant sponsor) and did not hold a relevant document as that durable partner, they must (unless they otherwise had a lawful basis of stay in the UK and Islands for that period, for example as a student) break their continuity of residence in the UK and Islands before they can apply as a joining family member and the durable partner of the relevant sponsor. They can then rely on the evidence referred to in the previous paragraph. In such a case, the person’s continuous qualifying period as a joining family member of a relevant sponsor can only have commenced on or after 1 January 2021. Example A is a non-EEA citizen who formed a partnership relationship with B, an EEA citizen resident in the UK, in September 2018. A was subsequently granted 30 months’ leave to remain in the UK on 1 February 2019 under Appendix FM to the Immigration Rules. Before that, A had been in the UK for several years without a lawful basis of stay. 1 February 2019 will therefore be the point from which you can assess whether, in respect of A’s application to the scheme as the family member of a relevant EEA citizen, A’s partnership relationship with B was durable before the specified date. Civil partnership, durable partnership or marriage of convenience A civil partnership, durable partnership or marriage of convenience is defined as a civil partnership, durable partnership or marriage entered into as a means to circumvent either: - any criterion the party would have to meet in order to enjoy a right to enter or reside in the UK under the EEA Regulations - any other provision of UK immigration law or any requirement of the Immigration Rules - any criterion the party would otherwise have to meet in order to enjoy a right to enter or reside in the UK under EU law - any criterion the party would otherwise have to meet in order to enjoy a right to enter or reside in the Islands under the Islands law Child under the age of 21 Where they are under the age of 21, the applicant must be either: - the direct descendant under the age of 21 (or who has turned 21 since the specified date) of the relevant EEA citizen or of their spouse or civil partner, which includes a grandchild or great-grandchild - the direct descendant under the age of 21 of a qualifying British citizen or relevant sponsor, or of their spouse or civil partner, which includes a grandchild or great-grandchild In addition, ‘child’ includes here (and, where appropriate, in the next section), as set out in sub-paragraphs (a)(i) to (a)(xi) of that entry in Annex 1 to Appendix EU: - an adopted child (adopted in accordance with a ‘relevant adoption decision’ as defined in Annex 1 to Appendix EU) of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child born through surrogacy (where recognised in UK law or Islands law) for the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom a special guardianship order (within the meaning of section 14A(1) of the Children Act 1989) is in force appointing as their special guardian the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom an order has been made under section 5 of the Children Act 1989 appointing as their guardian the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child subject to a permanence order made under section 80 of the Adoption and Children (Scotland) Act 2007 vesting parental responsibilities and parental rights in a person who is the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child who has a guardian appointed under section 7 of the Children (Scotland) Act 1995, or who is living with a person pursuant to an order made under section 11 of that act and that guardian or other person is the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom an order has been made under Article 159 of the Children (Northern Ireland) Order 1995, or in respect of whom an appointment has been made under Article 160 of that Order appointing as their guardian a person who is the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child who has a guardian appointed under section 12 or 14 of the Children (Guernsey and Alderney) Law 2008 or section 12 or 13 of the Children (Sark) Law 2016, or who is living in the care of a person pursuant to an order made under section 14 of the 2008 Law or section 13 of the 2016 Law, and the guardian or other person is the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom an order under Article 7 of the Children (Jersey) Law 2002 is in force appointing as their guardian the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom a special guardianship order (within the meaning of section 17A of the Children and Young Persons Act 2001 of Tynwald) has been made appointing as their special guardian the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner - a child in respect of whom an order has been made under section 6 or 7 of the Children and Young Persons Act 2001 of Tynwald appointing as their guardian the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or their spouse or civil partner It does not include a child cared for by the EEA citizen (or the qualifying British citizen or relevant sponsor) or by their spouse or civil partner solely by virtue of a formal or informal fostering arrangement, but this does not prevent an application being made by or on behalf of a ‘looked after’ child whom a local authority has placed in foster care. ‘Looked after’ in this context means the care comes within the meaning of section 22(1) of the Children Act 1989, section 17(6) of the Children (Scotland) Act 1995, section 74(1) of the Social Services and Well-being (Wales) Act 2014 or article 25(1) of the Children (Northern Ireland) Order 1995. A ‘relevant adoption decision’ is defined in Annex 1 to Appendix EU as an adoption decision taken either: - by the competent administrative authority or court in the UK or the Islands - by the competent administrative authority or court in a country whose adoption orders are recognised by the UK or the Islands - in a particular case in which that decision in another country has been recognised in the UK or the Islands as an adoption Where the applicant does not already hold a permanent residence document, the applicant must provide evidence of the family relationship for the relevant period, namely either: - a relevant document issued on the basis of the relevant family relationship - the full birth certificate or certificates or other documents which you are satisfied evidences that the applicant is the direct descendant of (or otherwise a child of) the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of their spouse or civil partner Where such an applicant is applying on the basis that they are the child under the age of 21 (or who has turned 21 since the specified date) of the spouse or civil partner of a relevant EEA citizen, or on the basis that they are the child under the age of 21 of the spouse or civil partner of a qualifying British citizen or relevant sponsor, you must also be satisfied that the marriage or civil partnership between the spouse or civil partner and the relevant EEA citizen (or the qualifying British citizen or relevant sponsor) continues to exist (or did so for the period of residence relied upon). Where, in the case of a joining family member of a relevant sponsor, the applicant is a child born after the specified date or adopted after that date in accordance with a relevant adoption decision, or after the specified date became a child within the meaning of that definition in Annex 1 to Appendix EU on the basis of one of the guardianship orders or equivalent in sub-paragraphs (a)(iii) to (a)(xi) of that entry, set out above (with the references below to ‘parents’ construed to include the guardian or other person to whom the order or other provision referred to in the relevant sub-paragraph of (a)(iii) to (a)(xi) of that entry relates), you must also be satisfied that one of the following requirements is met: - both of the applicant’s parents are a relevant sponsor - one of the applicant’s parents is a relevant sponsor and the other is a British citizen who is not a relevant sponsor - one of the applicant’s parents is a relevant sponsor who has sole or joint rights of custody of them, in accordance with the applicable rules of family law of the UK, of the Islands or of an EEA country or Switzerland (including applicable rules of private international law under which rights of custody under the law of a third country are recognised in the UK, in the Islands or in an EEA country or Switzerland, in particular as regards the best interests of the child, and without prejudice to the normal operation of such applicable rules of private international law) Where the person is a child born after the specified date to (or adopted after that date in accordance with a relevant adoption decision by or after that date became, within the meaning of the definition of ‘child’ in Annex 1 to Appendix EU and on the basis of one of sub-paragraphs (a)(iii) to (a)(xi) of that entry, a child of) a Swiss citizen or their spouse or civil partner (as described in the first sub-paragraph (a) in this entry), the Swiss citizen or their spouse or civil partner is a relevant sponsor. (Note that they cannot be the child of the specified spouse or civil partner of a Swiss citizen). In the case of an adopted child, surrogate child or a child subject to any of the guardianship orders or equivalent referred to above, you must discuss the case with your senior caseworker who may refer to the EEA Citizens’ Rights & Hong Kong Unit for further advice. Child aged 21 or over Where they are aged 21 or over, the applicant must be the direct descendant of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of their spouse or civil partner, and this includes a grandchild or great-grandchild, and (unless the applicant (i) is the direct descendant of the relevant EEA citizen, or of their spouse or civil partner, who has turned 21 since the specified date or (ii) was previously granted limited leave to enter or remain under paragraph EU3 or EU3A of Appendix EU, or its equivalent in the Islands, as a child under the age of 21) the applicant must be dependent on either: - the relevant EEA citizen (or qualifying British citizen) or their spouse or civil partner at the date of application or, where the date of application is after the specified date, at the specified date - the relevant sponsor or their spouse or civil partner at the date of application ‘Dependent’ means that, as demonstrated by relevant financial, medical or other documentary evidence: - having regard to their financial and social conditions, or health, the applicant cannot, or for the relevant period could not, meet their essential living needs (in whole or in part) without the financial or other material support of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of the spouse or civil partner - such support is, or was, being provided to the applicant by the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or by the spouse or civil partner - there is no need to determine the reasons for that dependence or for the recourse to that support Family relationship Where the applicant does not already hold a permanent residence document, the applicant must provide evidence of the family relationship for the relevant period, namely either: - a relevant document issued on the basis of the relevant family relationship - the full birth certificate or certificates or other documents which you are satisfied evidences that the applicant is the direct descendant of (or otherwise a child of) the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of their spouse or civil partner Where such an applicant is applying on the basis that they are the child aged 21 or over of the spouse or civil partner of a relevant EEA citizen (or of a qualifying British citizen or of a relevant sponsor), you must also be satisfied that the marriage or civil partnership between the spouse or civil partner and the relevant EEA citizen (or the qualifying British citizen or the relevant sponsor) continues to exist (or did so for the period of residence relied upon). In the case of an adopted or surrogate child you must discuss the case with your senior caseworker who may refer to the EEA Citizens’ Rights & Hong Kong Unit for further advice. Dependency Where the applicant (i) is not the direct descendant of the relevant EEA citizen, or of their spouse or civil partner, who has turned 21 since the specified date or (ii) was not previously granted limited leave to enter or remain under paragraph EU3 or EU3A of Appendix EU, or its equivalent in the Islands, as a child under the age of 21, they must also provide evidence which satisfies you that the applicant is (or for the relevant period or at the relevant time was) dependent on the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or on the spouse or civil partner. This evidence might take the form of for example: - evidence of their financial dependency, such as bank statements or money transfers to the applicant from the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or the spouse or civil partner - evidence that the applicant needs and receives (or for the relevant period did so) the personal care of the relevant EEA citizen (or qualifying British citizen or relevant sponsor), or of their spouse or civil partner, on serious health grounds, such as a letter from a hospital consultant Where the applicant was resident in the UK before the specified date, and was in paid employment or self-employment before they turned 21 and remained so, having turned 21, through to the date of application (or the specified date where this was earlier), their right to reside as the dependent child of the relevant EEA citizen (or of that person’s spouse or civil partner) is not lost by virtue of having exercised their right to work in the UK. Likewise, where the applicant was resident in the UK before the specified date, and was dependent on the relevant EEA citizen (or on that person’s spouse or civil partner) when they turned 21 and then took up paid employment or self-employment which they retained through to the date of application (or the specified date where this was earlier), their right to reside as the dependent child of the relevant EEA citizen (or of that person’s spouse or civil partner) is not lost by virtue of having exercised their right to work. Where, in either case, the paid employment or self-employment ceased before the date of application (or before the specified date where this was earlier), then, where the applicant has not, by the date of application, completed a 5 year continuous qualifying period in which the relevant requirements were met, they are required to show that they were dependent on the relevant EEA citizen (or on that person’s spouse or civil partner) between the date the employment or self-employment ended and the date of application (or the specified date where this was earlier). This reflects the Court of Appeal judgment in R (Ali) v Secretary of State for the Home Department [2024] EWCA Civ 1546, which found that, where they were resident in the UK before the specified date, the right to reside of a dependent child aged over 21 is not lost where they exercise their right to work in the UK. The judgment does not apply to those applying to the EU Settlement Scheme as a joining family member or as an extended family member dependent relative. Example 1 In September 2017, aged 17, A, a non-EEA citizen child of an EEA citizen working in the UK and their non-EEA citizen spouse, arrived in the UK and started living with his parents while he attended college here. In July 2020, aged 20, A started and remained in full-time employment in the UK. In September 2020, A moved into his own rented accommodation and stopped receiving financial support from his parents. In December 2020, A turned 21 and then applied to the EU Settlement Scheme as the dependent child aged over 21 of his parents. A was not required to show that he was dependent on his parents before he turned 21 and by then he had exercised his right to work in the UK by starting in full-time employment here. A therefore remained eligible for the scheme as a dependent child aged over 21 and was granted pre-settled status on that basis. Example 2 In September 2017, aged 17, B, a non-EEA citizen child of an EEA citizen working in the UK and their non-EEA citizen spouse, arrived in the UK and started living with his parents while he attended college here. In July 2020, aged 20, B left college, got married, moved in with his spouse (who was and has remained in full-time employment in the UK) in their own rented accommodation, and stopped receiving any financial support from his parents. In September 2020, B turned 21 and, in November 2020, B started and remained in full-time employment in the UK. In December 2020, B applied to the EU Settlement Scheme as the dependent child aged over 21 of his parents. B was not required to show that he was dependent on his parents before he turned 21, but by then he had ceased to be dependent on them as he was wholly supported by his spouse who was and remained in full-time employment. B did not exercise his right to work in the UK until after he had turned 21 and by then had already ceased to be dependent on his parents. B therefore did not remain eligible for the scheme as a dependent child aged over 21 and his application was refused. Example 3 In September 2016, aged 17, C, a non-EEA citizen child of an EEA citizen working in the UK and their non-EEA citizen spouse, arrived in the UK and started living with his parents while he attended school here. In October 2017, aged 18, C started university whilst he continued to live with his parents and they continued to support him financially. C turned 21 before completing his degree in June 2020 and he took up full-time employment in July 2020. C also moved into rented accommodation with a friend in July 2020 and stopped receiving any financial support from his parents. His employment ended in November 2020. In June 2021, C applied to the EU Settlement Scheme as the dependent child aged over 21 of his parents. C was not required to show that he was dependent on his parents before he turned 21, he was dependent on his parents when he turned 21 and he did not lose his status as a dependant because he exercised his right to work in the UK by taking up full-time employment in July 2020. However, as C had not, by the date of application, completed a 5 year continuous qualifying period in which the relevant requirements were met, he needed to show that he was dependent on his parents between the date his employment ended in November 2020 and the specified date. C was able to provide evidence that he received financial support from them during that period and was granted pre-settled status. Dependent parent The applicant must be the direct relative in the ascending line of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of their spouse or civil partner, and includes a grandparent or great-grandparent and an adoptive parent of an adopted child. Dependency There is no requirement as to dependency where either: - the applicant was previously granted limited leave to enter or remain under paragraph EU3 or EU3A of Appendix EU as a dependent parent, and that leave has not lapsed or been cancelled, curtailed or invalidated - the spouse, civil partner or durable partner of the applicant (and with whom they reside) has been granted indefinite leave to enter or remain or limited leave to enter or remain under paragraph EU2, EU2A, EU3 or EU3A of Appendix EU as a dependent parent of the relevant EEA citizen (or of the qualifying British citizen or of the relevant sponsor) or of their spouse or civil partner, and that indefinite or limited leave has not lapsed or been cancelled, curtailed, revoked or invalidated In relation to the reference above to the spouse, civil partner or durable partner of the applicant, the entry for (as the case may be) ‘spouse’, ‘civil partner’ or ‘durable partner’ in Annex 1 to Appendix EU applies, except that in the applicable entry ‘applicant’ is to be substituted for ‘relevant EEA citizen’ and sub-paragraph (b) of the entry for ‘durable partner’ in Annex 1 is to be disregarded. Otherwise, the applicant must be dependent on: - the relevant EEA citizen or the qualifying British citizen (or on their spouse or civil partner) at the date of application (or, where the date of application is after the specified date, at the specified date) and: - where the relevant EEA citizen (or qualifying British citizen) is over the age of 18 at the date of application (or, where the date of application is after the specified date, at the specified date), the applicant’s dependency on the relevant EEA citizen (or qualifying British citizen), or on the spouse or civil partner, is assumed, and the applicant is not required to provide evidence of this - where the relevant EEA citizen (or qualifying British citizen) is under the age of 18 at the date of application (or, where the date of application is after the specified date, at the specified date), evidence of the applicant’s dependency on the relevant EEA citizen (or qualifying British citizen), or on the spouse or civil partner, must be provided - the relevant sponsor (or on their spouse or civil partner) at the date of application and: - where the relevant sponsor is over the age of 18 and the date of application is before 1 July 2021, the applicant’s dependency on that relevant sponsor or on the spouse or civil partner is assumed and the applicant is not required to provide evidence of this - where the relevant sponsor is under the age of 18 years or the date of application is on or after 1 July 2021, evidence of the applicant’s dependency on the relevant sponsor or on the spouse or civil partner must be provided ‘Spouse or civil partner’ means (as the case may be) the person described in sub-paragraph (a)(i) or (a)(ii) of the entry for ‘family member of a qualifying British citizen’ in Annex 1 to Appendix EU, or in sub-paragraph (a) of the entry for ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU or in the first sub-paragraph (a) (together with either the second sub-paragraph (a) or sub-paragraph (b)(i) or (b)(ii)) of the entry for ‘joining family member of a relevant sponsor’ in Annex 1 to Appendix EU. ‘Dependent’ means that, as demonstrated by relevant financial, medical or other documentary evidence: - having regard to their financial and social conditions, or health, the applicant cannot, or for the relevant period could not, meet their essential living needs (in whole or in part) without the financial or other material support of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of their spouse or civil partner - such support is or was, being provided by the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or by their spouse or civil partner - there is no need to determine the reasons for that dependence or for the recourse to that support Evidence of dependency might take the form of for example: - evidence of their financial dependency, such as bank statements or money transfers to the applicant from the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or the spouse or civil partner - evidence that the applicant needs and receives (or for the relevant period did so) the personal care of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) on serious health grounds, such as a letter from a hospital consultant Where the applicant was resident in the UK before the specified date, and is in paid employment or self-employment at the date of application (or the specified date where this was earlier), their right to reside as a dependent parent of the relevant EEA citizen (or of that person’s spouse or civil partner) is not lost by virtue of having exercised their right to work in the UK. This reflects the Court of Appeal judgment in R (Ali) v Secretary of State for the Home Department [2024] EWCA Civ 1546, which found that, where they were resident in the UK before the specified date, the right to reside of a dependent parent is not lost where they exercise their right to work in the UK. The judgment does not apply to those applying to the EU Settlement Scheme as a joining family member or extended family member dependent relative. Example 1 In September 2017, A, a non-EEA citizen dependent parent of a non-EEA citizen spouse living in the UK with her EEA citizen spouse who is working in the UK, arrived in the UK (from the non-EEA country in which A had been living and, unable to work for health reasons, had been receiving their financial support in meeting his essential living needs) and started living with his daughter and her husband. In September 2020, his health having improved significantly, A started and remained in full-time employment in the UK and, in October 2020, A moved into his own rented accommodation and stopped receiving financial support from his daughter and her husband. In December 2020, A applied to the EU Settlement Scheme as the dependent parent of his non-EEA citizen daughter and her EEA citizen spouse. As long as A remained dependent on the EEA citizen or his daughter at the point he took up employment, and continued to be employed at the date of application, he did not lose his status as dependent on them. A therefore remained eligible for the scheme as a dependent parent and was granted pre-settled status on that basis. Family relationship Where the applicant does not already hold a permanent residence document, the applicant must provide evidence of the family relationship for the relevant period, namely either: - a relevant document issued on the basis of the relevant family relationship - the full birth certificate or certificates or other documents which you are satisfied evidences that the applicant is the direct relative in the ascending line of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or of the spouse or civil partner Where such an applicant is applying on the basis that they are the dependent parent of the spouse or civil partner of a relevant EEA citizen (or of a qualifying British citizen or of a relevant sponsor), you must also be satisfied that the marriage or civil partnership between the spouse or civil partner and the relevant EEA citizen (or the qualifying British citizen) continues to exist (or did so for the period of residence relied upon). Dependent relative A dependent relative is defined in Annex 1 to Appendix EU as either: - under sub-paragraph (a)(i), a relative (other than a spouse, civil partner, durable partner, child or dependent parent) of their sponsoring person, and the person is (or for the relevant period was) a dependant of the sponsoring person, a member of their household or in strict need of their personal care on serious health grounds - under sub-paragraph (a)(ii), a ‘person who is subject to a non-adoptive legal guardianship order’ (as defined in Annex 1 to Appendix EU) in favour (solely or jointly with another party) of their sponsoring person - under sub-paragraph (a)(iii), a person under the age of 18 years who either: - is the direct descendant of the durable partner of their sponsoring person - has been adopted by the durable partner of their sponsoring person, in accordance with a ‘relevant adoption decision’ (as defined in Annex 1 to Appendix EU) An applicant (who is not a family member of a qualifying British citizen as described in sub-paragraph (a)(viii) of that entry in Annex 1 to Appendix EU, where you are satisfied that there are reasonable grounds for the person’s failure to meet the deadline to which that sub-paragraph refers) must hold a relevant document as the dependent relative of their sponsoring person for the period of residence relied upon and, unless this confirms the right of permanent residence in the UK under regulation 15 of the EEA Regulations (or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man), they must also provide evidence which satisfies you that the relationship and the dependency (or, as the case may be, their membership of the household or their strict need for personal care on serious health grounds) continue to exist at the date of application (or did so for the period of residence relied upon). In the case of a family member of a qualifying British citizen as described in sub-paragraph (a)(viii) of that entry in Annex 1 to Appendix EU (where you are satisfied that there are reasonable grounds for the person’s failure to meet the deadline to which that sub-paragraph refers), the applicant must provide evidence which satisfies you that the relationship and the dependency (or, as the case may be, their membership of the household or their strict need for personal care on serious health grounds) existed before the specified date and continue to exist at the date of application (or did so for the period of residence relied upon). Where the applicant is a dependent relative of a relevant person of Northern Ireland, a relevant document means, in accordance with sub-paragraph (a)(i)(bb) of the definition in Annex 1 to Appendix EU, other evidence which satisfies the Secretary of State of the same matters under Appendix EU concerning the relationship and dependency as a document a document listed in sub-paragraph (a)(i)(aa). For the purposes of this provision, where the Secretary of State is so satisfied, such evidence is deemed to be the equivalent of a document to which sub-paragraph (a)(i)(aa) refers. Where the applicant applies for a relevant document (as described in sub-paragraph (a)(i)(aa) or (a)(ii) of that definition in Annex 1 to Appendix EU) as the dependent relative of their sponsoring person before the specified date and their relevant document is issued on that basis after the specified date (or where the person relies as their relevant document, as described in sub-paragraph (a)(iv) of that definition in Annex 1 to Appendix EU, on an EU Settlement Scheme Family Permit granted to them under Appendix EU (Family Permit) as a ‘dependent relative of a specified relevant person of Northern Ireland’, as defined in Annex 1 to that Appendix), they are deemed to have held the relevant document since immediately before the specified date. Their ‘sponsoring person’ means: - where the first sub-paragraph (a)(i) and the first sub-paragraph (b) of the definition of ‘dependent relative’ in Annex 1 to Appendix EU apply, either: - a relevant EEA citizen (in accordance with the definition in Annex 1) or their spouse or civil partner - a qualifying British citizen or their spouse or civil partner - where the first sub-paragraph (a)(ii) and the first sub-paragraph (b), or the first sub-paragraph (a)(iii) and the first sub-paragraph (b), of the definition of ‘dependent relative’ in Annex 1 to Appendix EU apply, either: - a relevant EEA citizen (in accordance with the definition in Annex 1) - a qualifying British citizen Where such an applicant is applying on the basis that they are the dependent relative of the spouse or civil partner of a relevant EEA citizen (or of a qualifying British citizen), you must be satisfied that the marriage or civil partnership between the spouse or civil partner and the relevant EEA citizen (or the qualifying British citizen) continues to exist (or did so for the period of residence relied upon). A ‘person who is subject to a non-adoptive legal guardianship order’ is defined in Annex 1 to Appendix EU as a person who has satisfied the Secretary of State that, before the specified date, they: - are under the age of 18 years - are subject to a non-adoptive legal guardianship order in favour (solely or jointly with another party) of a relevant EEA citizen or of a qualifying British citizen (who is their ‘sponsoring person’ as described above) that: - is recognised under the national law of the state in which it was contracted - places parental responsibility on a permanent basis on the relevant EEA citizen or on the qualifying British citizen (in either case, solely or jointly with another party) - have lived with the relevant EEA citizen (or with the qualifying British citizen) since their placement under the guardianship order - have created family life with the relevant EEA citizen (or with the qualifying British citizen) - have a personal relationship with the relevant EEA citizen (or with the qualifying British citizen) that involves dependency on the relevant EEA citizen (or on the qualifying British citizen) and the assumption of parental responsibility, including legal and financial responsibilities, for that person by the relevant EEA citizen (or by the qualifying British citizen) You may rely on the relevant document issued to the applicant on the basis that they are the dependent relative of their sponsoring person as evidence that these requirements have been met. Where the applicant does not hold a permanent residence document, they will also need to provide evidence which satisfies you that the relationship continues to subsist (or did so for the period of residence relied upon) – the circumstances must be considered on a case by case basis. Family members who hold pre-settled status based on dependency Rule EU4 of Appendix EU provides, in part, that where a person has been granted pre-settled status (limited leave to enter or remain under Appendix EU) as a child, dependent parent or dependent relative, they do not need to continue to meet the eligibility requirements for that leave which they met at the date of application where these related to their dependency, in order to retain their leave and remain eligible in due course for settled status (indefinite leave to enter or remain), where they apply on the basis of the same family relationship. For example, where a person has been granted pre-settled status on the basis of being a dependent parent of a relevant EEA citizen, they will not lose this status solely because they cease to be dependent on the relevant EEA citizen, and they will remain eligible in due course for indefinite leave to enter or remain as a dependent parent of that relevant EEA citizen, where they apply on the basis of the same family relationship. Other evidence In addition to the criteria set out above, where the family member applying for status under the scheme is either: - a non-EEA citizen without a documented right of permanent residence - an EEA citizen without a documented right of permanent residence who relies on being (or for the relevant period on having been) a family member of a qualifying British citizen, a family member of a relevant EEA citizen, a family member who has retained the right of residence or a joining family member of a relevant sponsor their application depends on their current or past family relationship to a relevant EEA citizen (or qualifying British citizen or relevant sponsor). The applicant will need to provide proof of the identity and nationality of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) of whom the applicant is the family member (or was for the relevant period). This will be either: - in the case of a relevant EEA citizen (who is not a relevant naturalised British citizen, a [dual British and EEA citizen: McCarthy cases](#)) or relied on by the applicant as being a relevant person of Northern Ireland) or of a qualifying British citizen, or in the case of a relevant sponsor (who is not a relevant naturalised British citizen or relied on by the applicant as being a relevant person of Northern Ireland), their valid passport - in the case of a relevant EEA citizen (who is not a relevant naturalised British citizen, a dual British and EEA citizen: McCarthy cases or relied on by the applicant as being a relevant person of Northern Ireland), or in the case of a relevant sponsor (who is not a relevant naturalised British citizen or relied on by the applicant as being a relevant person of Northern Ireland), their valid national identity card or confirmation that they have been or are being granted indefinite or limited leave to enter or remain under (as the case may be) paragraph EU2 or EU3 of Appendix EU - in the case of a relevant EEA citizen who is a relevant naturalised British citizen or a dual British and EEA citizen: McCarthy cases, or of a relevant sponsor who is a relevant naturalised British citizen, their valid passport or valid national identity card as an EEA citizen, and information or evidence which is provided by the applicant, or is otherwise available to you, which satisfies you that the person is a British citizen - in the case of a relevant EEA citizen (or relevant sponsor) who is relied on by the applicant as being a relevant person of Northern Ireland either: - (where they are a British citizen) information or evidence which is provided by the applicant, or is otherwise available to you, which satisfies you that the person is a British citizen - (where the person is an Irish citizen) their valid passport or their national identity card as an Irish citizen, or confirmation that they have been or are being granted indefinite or limited leave to enter or remain under (as the case may be) paragraph EU2 or EU3 of Appendix EU - (where they are a British citizen and an Irish citizen, and are not relied on by the applicant as being a specified relevant person of Northern Ireland) the evidence required by either of the preceding 2 bullet points In each case, the applicant must also provide the ‘required evidence of being a relevant person of Northern Ireland’ in respect of the person: see Family members of the people of Northern Ireland. ‘Valid’ means that the document is genuine and has not expired or been cancelled or invalidated. You can agree to accept alternative evidence of the identity and nationality of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) where the applicant is unable to obtain or produce the required document due to circumstances beyond their control or to compelling practical or compassionate reasons. For example, in cases where you are satisfied that there has been a permanent breakdown in the relationship between the applicant and the relevant EEA citizen (or qualifying British citizen or relevant sponsor), it may not be possible for the applicant to obtain or produce the required document. You must consider each case on its merits as to whether you are satisfied that the applicant cannot obtain or produce the required document, having made every reasonable effort to do so or having shown why it is not possible for them to do so. For guidance, see [Alternative evidence of identity and nationality or of entitlement to apply from outside the UK](#). Where the date of application is before 1 July 2021, the applicant will also need to provide evidence about the residence or status of the relevant EEA citizen (or about the residence of the qualifying British citizen or relevant sponsor) which satisfies you that either: - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, that EEA citizen both: - is (or for the relevant period was) a relevant EEA citizen as described in sub-paragraph (a) in the definition in Annex 1 to Appendix EU – such as an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1) resident in the UK and Islands for a continuous qualifying period which began before the specified date - is (or was) such a relevant EEA citizen throughout any continuous qualifying period on which the applicant relies as being a family member of a relevant EEA citizen - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (b) of the definition in Annex 1 to Appendix EU – such as an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a relevant naturalised British citizen, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (c) of that definition in Annex 1 to Appendix EU – see [relevant naturalised British citizen](#) - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person who is a [dual British and EEA citizen: McCarthy cases](#), that EEA citizen is a relevant EEA citizen as described in sub-paragraph (d) of that definition in Annex 1 to Appendix EU – see [Family member of a dual British and EEA citizen (McCarthy cases)](#) – either: - resident in the UK and Islands for a continuous qualifying period which began before the specified date - who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person of Northern Ireland, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (e) of that definition in Annex 1 to Appendix EU, with one of the following applying in respect of the relevant person of Northern Ireland: - they are (or were) resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date - having been resident in the UK and Islands as described above and where they are an Irish citizen, they have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or are being granted that leave under that paragraph of this Appendix or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - having been resident in the UK and Islands as described above and where they are a British citizen or a British citizen and an Irish citizen, and if they had made a valid application under Appendix EU before 1 July 2021, they would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person exempt from immigration control, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (f) of that definition in Annex 1 to Appendix EU, with one of the following applying in respect of the person exempt from immigration control: - they are (or for the relevant period were) resident in the UK and Islands for a continuous qualifying period which began before the specified date - having been resident in the UK and Islands as described above, they would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a frontier worker, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (g) of that definition in Annex 1 to Appendix EU, with the frontier worker meeting (or for the relevant period having met) the requirements of the definition of ‘frontier worker’ in Annex 1 to Appendix EU - where the applicant is (or for the relevant period was) a family member of a qualifying British citizen, that British citizen both: - is (or for the relevant period was) a qualifying British citizen is (or was) a qualifying British citizen throughout any continuous qualifying period on which the applicant relies as being a family member of a qualifying British citizen - where the applicant is (or for the relevant period was) a joining family member of a relevant sponsor, that relevant sponsor both: - is (or for the relevant period was) a relevant sponsor - is (or was) a relevant sponsor throughout any continuous qualifying period on which the applicant relies as being a joining family member of a relevant sponsor Where the date of application is on or after 1 July 2021, the applicant will also need to provide evidence about the residence or status of the relevant EEA citizen (or about the residence of the qualifying British citizen or relevant sponsor) which satisfies you that either: - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (a) in the applicable definition in Annex 1 to Appendix EU – such as an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1) resident in the UK and Islands for a continuous qualifying period which began before the specified date; and the EEA citizen, having been resident in the UK and Islands as described above, has been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - limited leave to enter or remain under paragraph EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed or invalidated - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (b) of the applicable definition in Annex 1 to Appendix EU – such as an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted either: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a relevant naturalised British citizen, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (c) of the applicable definition in Annex 1 to Appendix EU who falls within sub-paragraphs (a), (c) and (d) of the entry for ‘relevant naturalised British citizen’ in Annex 1 to Appendix EU, and would, if they had made a valid application under Appendix EU before 1 July 2021, have, but for the fact that they are a British citizen, been granted: indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person who is a dual British and EEA citizen: McCarthy cases, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (d) of the applicable definition in Annex 1 to Appendix EU who was resident in the UK and Islands for a continuous qualifying period which began before the specified date; and the EEA citizen, having been resident in the UK and Islands as described above and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted: - indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - limited leave to enter or remain under paragraph EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person of Northern Ireland, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (e) of the applicable definition in Annex 1 to Appendix EU who was resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date; and the EEA citizen, having been resident in the UK and Islands as described above: - is an Irish citizen who has been granted indefinite or limited leave to enter or remain under paragraph EU2 or (as the case may be) EU3 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, curtailed, revoked or invalidated - is an Irish citizen who, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite or limited leave to enter or remain under paragraph EU2 or (as the case may be) EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed, revoked or invalidated before the date of application - is a British citizen, or a British citizen and an Irish citizen, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite or limited leave to enter or remain under paragraph EU2 or (as the case may be) EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a person exempt from immigration control, that EEA citizen is a relevant EEA citizen as described in sub-paragraph (f) of the applicable definition in Annex 1 to Appendix EU who was resident in the UK and Islands for a continuous qualifying period which began before the specified date; and the EEA citizen, having been resident in the UK and Islands as described above, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite or limited leave to enter or remain under paragraph EU2 or (as the case may be) EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed, revoked or invalidated before the date of application - where the applicant is (or for the relevant period was) a family member of a relevant EEA citizen, and where the applicant is a family member of a frontier worker, that EEA citizen is a relevant EEA citizen as described in subparagraph (g) of the applicable definition in Annex 1 to Appendix EU, with the frontier worker meeting (or for the relevant period having met) the requirements of the definition of ‘frontier worker’ in Annex 1 to Appendix EU - where the applicant is (or for the relevant period was) a family member of a qualifying British citizen, that British citizen both: - is (or for the relevant period was) a qualifying British citizen - is (or was) a qualifying British citizen throughout any continuous qualifying period on which the applicant relies as being a family member of a qualifying British citizen - where the applicant is (or for the relevant period was) a joining family member of a relevant sponsor, that relevant sponsor both: - is (or for the relevant period was) a relevant sponsor - is (or was) a relevant sponsor throughout any continuous qualifying period on which the applicant relies as being a joining family member of a relevant sponsor Where, in order to meet the requirements of required evidence of identity and nationality and of residence or status for their family member, the applicant submits: - a copy (and not the original) of a document (including by uploading this as part of the application process), you can require the applicant to submit the original document where you have reasonable doubt as to the authenticity of the copy submitted - a document which is not in English, you can require the applicant to provide a certified English translation of (or a Multilingual Standard Form to accompany) the document, where this is necessary for the purposes of deciding whether the applicant meets the eligibility requirements for leave to be granted under the scheme Where the eligibility requirements to be met for leave to be granted under the scheme relate to the death of a person, the required evidence of family relationship must include their death certificate or other evidence which you are satisfied evidences the death. A family member of a relevant EEA citizen (or qualifying British citizen or relevant sponsor) is able to apply under the EU Settlement Scheme from outside the UK where they are able to provide the required proof of entitlement to apply from outside the UK. An EEA citizen or non-EEA citizen family member (other than a dependent relative of a relevant EEA citizen) who does not have the required proof of entitlement to apply from outside the UK (or does not wish to apply to the scheme from overseas) can apply for an EU Settlement Scheme Family Permit to join the relevant EEA citizen (or qualifying British citizen or relevant sponsor) in, or accompany them to, the UK, and will be able to apply to the scheme once in the UK, if they wish to remain here. Family members of the people of Northern Ireland In addition to the ‘other evidence’ section above – which is required where the family member applying for status under the scheme is either a non-EEA citizen without a documented right of permanent residence, or an EEA citizen without a documented right of permanent residence who relies, in this case, on being (or for the relevant period on having been) a family member of a relevant EEA citizen or a joining family member of a relevant sponsor – where such an applicant is a family member of a relevant EEA citizen or relevant sponsor who is a relevant person of Northern Ireland, you will need to see, in respect of the relevant EEA citizen or relevant sponsor, the ‘required evidence of being a relevant person of Northern Ireland’ (as defined in Annex 1 to Appendix EU). This means both: - the person’s birth certificate showing that they were born in Northern Ireland, or their passport where this shows that they were born in Northern Ireland - evidence which satisfies you that, at the time of the person’s birth, at least one of their parents was a British citizen, an Irish citizen, a British citizen and an Irish citizen, or otherwise entitled to reside in Northern Ireland without any restriction on their period of residence You must see evidence of A and B below, and evidence of at least one of C, D or E. Non-exhaustive examples of the evidence which may be provided in respect of B, C, D and E are set out below. If you are unsure whether the evidence provided is sufficient, you must discuss this with your senior caseworker who may refer to the EEA Citizens’ Rights & Hong Kong Unit for further advice. A. Evidence that the person was born in Northern Ireland Either: - the person’s birth certificate showing that they were born in Northern Ireland - the person’s British or Irish passport, where this shows that they were born in Northern Ireland B. Evidence of the person’s relationship to their parent - the person’s birth certificate which names their parent and which both: - is linked to the person through a valid photographic identity document C. Evidence that one of the person’s parents was a British citizen at the time of the person’s birth The most reliable evidence that a person’s parent was a British citizen at the time of the person’s birth will be the parent’s British passport which was valid at the time. If this is not available, then you will need to see other evidence to satisfy you that one of the person’s parents was a British citizen at the time of the person’s birth. The parent may have become a British citizen at birth or they may have applied for British citizenship. Whether or not the person’s parent was a British citizen at birth depends on the rules that were in force at the time. The types of evidence you need to see to establish that a person’s parent was a British citizen at birth are set out on pages 13 and 14 of British citizenship: automatic acquisition guidance and you must consider any evidence submitted by the applicant in line with that guidance. If the person’s parent applied to become a British citizen, you can rely on Home Office records of naturalisation or registration as long as you are satisfied that the record relates to the parent. If you cannot locate a Home Office record, you will need to ask the applicant to provide the parent’s naturalisation certificate or registration certificate and a valid photographic identity document that links the parent to the certificate so you can be sure it belongs to them. In all circumstances, if you are satisfied that the parent had British citizenship before the person’s birth, you must check that there is no record of British citizenship having been renounced or otherwise lost before that birth. D. Evidence that one of the person’s parents was an Irish citizen at the time of the person’s birth The most reliable evidence that a person’s parent was an Irish citizen at the time of the person’s birth will be the parent’s Irish passport which was valid at the time. If this is not available, then you will need to see other evidence to satisfy you that one of the person’s parents was an Irish citizen at the time of the person’s birth. The parent may have become an Irish citizen at birth, or they may have applied for Irish citizenship. Whether or not the person’s parent was an Irish citizen at birth depends on the rules that were in force at the time. You can find information about this on the website of the Irish Government’s Department of Foreign Affairs and Trade at www.dfa.ie/citizenship. If the person’s parent applied to become an Irish citizen, you will need to ask the applicant to provide the parent’s certificate of Irish citizenship and a valid photographic identity document that links the parent to the certificate so you can be sure it belongs to them. In all circumstances, if there is information suggesting that the evidence provided may not be authentic or that Irish citizenship may have been renounced or otherwise lost before the child’s birth, you must make reasonable, relevant enquiries to establish whether, on the balance of probabilities, the parent was an Irish citizen at the time of the person’s birth. However, such enquiries do not need to be made if you are satisfied that the parent (or the person’s other parent) was a British citizen, or otherwise entitled to reside in Northern Ireland without any restriction on their period of residence, at the time of the person’s birth. E. Evidence that one of the person’s parents was otherwise entitled to reside in Northern Ireland without any restriction on their period of residence at the time of the person’s birth A person’s parent will have been otherwise entitled to reside in the UK without any restriction on their period of residence if they: - had the right of abode in the UK - had indefinite leave to enter or remain in the UK - had a right of permanent residence in the UK under the EU Free Movement Directive – this applies if the person was born on or after 29 April 2006 - were a non-Irish EEA citizen and a self-employed person who had ceased activity or a family member of such a person, a family member of an EEA citizen who had died, or a person who had rights under Regulation EU 1251-70 (for example as a retired non-Irish EEA worker) – this applies if the person was born between 2 October 2000 and 28 April 2006 - were a citizen of a country that was in the EU or the EEA (other than Ireland) and they were exercising free movement rights in the UK – this applies if the person was born between 1 January 1973 and 1 October 2000 You can rely on Home Office records showing that the parent was entitled to reside in the UK (and therefore Northern Ireland) without any restriction on their period of residence at the time of the person’s birth as long as you are satisfied that the record relates to the parent. If you cannot locate a Home Office record, you will need to ask the applicant to provide one of the following together with a valid photographic identity document that links the parent to the document so you can be sure it belongs to them: - a UK passport describing the parent as a British subject with the right of abode - the parent’s passport endorsed with a ‘certificate of entitlement’ which proves the holder had the right of abode - a document issued under the Windrush Scheme - the parent’s biometric residence permit or biometric residence card showing indefinite leave to enter or remain, or ‘no time limit’, under UK immigration law or a right of permanent residence under EU law which was valid at the time of the person’s birth an immigration officer’s stamp, which was valid at the time of the person’s birth, in the parent’s passport showing they had been given leave to enter for an indefinite period - a Home Office stamp, which was valid at the time of the person’s birth, in the parent’s passport showing they had indefinite leave to remain in the UK or that there was no time limit on their stay here - a UK residence permit affixed to the parent’s passport or immigration status document showing indefinite leave to enter or remain on ‘no time limit’ - a Home Office letter confirming that the parent had been granted indefinite leave to remain in the UK - where the person was born between 2 October 2000 and 29 April 2006, evidence that the parent was either: - a non-Irish EEA citizen and a self-employed person who had ceased activity or a family member of such a person - a family member of a non-Irish EEA citizen who had died - a person who had rights under Regulation EU 1251-70 (for example as a retired non-Irish EEA worker) - where the person was born between 1 January 1973 and 1 October 2000, evidence that the parent was a citizen of a country that was in the EU or the EEA (other than Ireland) and they were exercising free movement rights in the UK Where one of the documents listed above is provided, you must arrange for authenticity checks, including assessing whether the document was issued during their relevant period of use by the UK authorities. Further guidance about how to consider whether a person has or had indefinite leave to enter or remain can be found here: No time limit. Where, in order to meet the requirements of ‘required evidence of being a relevant person of Northern Ireland, the applicant submits: - a copy (and not the original) of a document (including by uploading this as part of the application process), you can require the applicant to submit the original document where you have reasonable doubt as to the authenticity of the copy submitted - a document which is not in English, you can require the applicant to provide a certified English translation of (or a Multilingual Standard Form to accompany) the document, where this is necessary for the purposes of deciding whether the applicant meets the eligibility requirements for leave to be granted under the scheme Specified relevant person of Northern Ireland Where the applicant relies on their relevant EEA citizen or relevant sponsor being a ‘specified relevant person of Northern Ireland’, you will need to be satisfied, having followed the guidance immediately above, that that person is a relevant person of Northern Ireland and is either a British citizen or a dual British and Irish citizen (such as they are not solely an Irish citizen). You must also be satisfied that the applicant is a non-EEA citizen. You must also be satisfied that the applicant is either: - a joining family member of a relevant sponsor (where the specified relevant person of Northern Ireland is the relevant sponsor) and the applicant must have satisfied you by relevant information or evidence provided with the application that, due to compelling practical or compassionate reasons, it was not possible for that person to return to the UK before the specified date while the applicant remained outside the UK - the dependent relative of the specified relevant person of Northern Ireland, who is the applicant’s ‘sponsoring person’ (under the definition of ‘dependent relative’ in Annex 1 to Appendix EU), and the applicant relies, as their relevant document as the dependent relative of their sponsoring person (as described in sub-paragraph (a)(iv) of the definition of ‘relevant document’ in Annex 1 to Appendix EU), on an EU Settlement Scheme Family Permit granted to them under Appendix EU (Family Permit) as a ‘dependent relative of a specified relevant person of Northern Ireland’, as defined in Annex 1 to that Appendix Family members of persons exempt from immigration control In addition to the ‘other evidence’ section above – which is required where the family member applying for status under the scheme is either a non-EEA citizen without a documented right of permanent residence, or an EEA citizen without a documented right of permanent residence who relies, in this case, on being (or for the relevant period on having been) a family member of a relevant EEA citizen or a joining family member of a relevant sponsor – where such an applicant relies on being a family member of a person exempt from immigration control who does not hold EU Settlement Scheme status, you will need both: - to see evidence from the applicant or which is otherwise available to you that the relevant EEA citizen or relevant sponsor is (or for the relevant period was) exempt from immigration control in accordance with section 8(2), (3) or (4) of the Immigration Act 1971 - (where the date of application is before 1 July 2021) to be satisfied that the person exempt from immigration control is either: - resident in the UK and Islands for a continuous qualifying period which began before the specified date - a person who, having been resident in the UK and Islands as described above, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the date of application is on or after 1 July 2021) to be satisfied that the person exempt from immigration control is generally both: - resident in the UK and Islands for a continuous qualifying period which began before the specified date a person who, having been resident in the UK and Islands as described above, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite or limited leave to enter or remain under paragraph EU2 or (as the case may be) EU3 of Appendix EU, which would not have lapsed or been cancelled, curtailed, revoked or invalidated before the date of application. A person exempt from immigration control is defined in Annex 1 to Appendix EU as a person who is: - a national of an EEA country or Switzerland - not a British citizen - exempt from immigration control in accordance with section 8(2), (3) or (4) of the Immigration Act 1971 See Persons exempt from control for further guidance. Family members of frontier workers In addition to the ‘other evidence’ section above – which is required where the family member applying for status under the scheme is either a non-EEA citizen without a documented right of permanent residence, or an EEA citizen without a documented right of permanent residence who relies, in this case, on being (or for the relevant period on having been) a family member of a relevant EEA citizen or a joining family member of a relevant sponsor – where such an applicant is a family member of a frontier worker, you will need either: - to see evidence from the applicant or which is otherwise available to you that the relevant EEA citizen or relevant sponsor holds a valid frontier worker permit issued under the [Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020](#) - to be satisfied by evidence provided by the applicant that the relevant EEA citizen or relevant sponsor fulfils the relevant conditions of being a frontier worker set out in the [Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020](#) and has done so continuously since the specified date You also need to be satisfied, in either case, that the relevant EEA citizen or relevant sponsor has not been (and is not to be) refused admission to, or removed from, the UK by virtue of the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020. A frontier worker is defined in Annex 1 to Appendix EU as a person who: - is a national of an EEA country or Switzerland - is not a British citizen - satisfies the Secretary of State by relevant evidence of this that they fulfil the relevant conditions of being a frontier worker set out in the [Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020](#), and that they have done so continuously since the specified date - has not been (and is not to be) refused admission to, or removed from, the UK by virtue of the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020, and is not subject to a relevant restriction decision as defined by regulation 2 of those Regulations See Frontier worker permit scheme for guidance about how to consider whether a person qualifies for a frontier worker permit issued under the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020. Related content Contents British citizenship: automatic acquisition No time limit Persons exempt from control Frontier worker permit scheme caseworker guidance Related external links Appendix EU to the Immigration Rules Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020 Applications in respect of children Under section 55 of the Borders, Citizenship and Immigration Act 2009, the Home Office has a duty to have regard to the need to safeguard and promote the welfare of children under the age of 18 who are in the UK. In respect of this guidance, the section 55 duty means you need to identify and act on any concerns about the welfare of any child of whom you become aware while considering an application under the scheme. A child does not need the consent of their parent or guardian to make an application under the EU Settlement Scheme. However, where a child in the UK (who is under the age of 18) makes an application under the EU Settlement Scheme in their own right (such as where an application has not been made on their behalf by a parent or guardian) and which does not list a related application by a parent or guardian, you have a duty of care to carry out checks to ensure the safeguarding of that child. It would normally be expected that an adult with responsibility for a child under the age of 18 would act on their behalf in respect of administrative matters, such as an immigration application. Therefore, in accordance with our section 55 duty and in line with the statutory guidance “Every Child Matters”, additional checks must be undertaken on any application under the scheme where a child under the age of 18 is applying without a parent or guardian to ensure that there are no obvious welfare concerns. This applies even where a child has provided sufficient evidence to be granted settled status or pre-settled status based on their own UK residence (for example, they have provided school letters confirming attendance for 5 years). These checks do not affect eligibility for leave under the scheme and, where, on the basis of the application, status can be granted in accordance with Appendix EU, it must be. The purpose of these checks is solely to establish whether a child applicant has appropriate living arrangements and to ensure their overall safety and welfare. Referral to Children’s Services or other agencies In certain circumstances, a formal referral to Children’s Services or other agencies may be required, including for example where, in respect of a child under the age of 18, one or more of the following apply: - the child appears to be living alone or to have no fixed abode - the child is, or appears to be, being cared for as part of a non-local authority fostering arrangement - the child may have been trafficked or is at risk of exploitation - the child may be at risk of harm or abuse in their current situation - a Certificate of Eligibility to Adopt has not been issued - see the section Children adopted from outside the UK You must refer to guidance on making child safeguarding referrals to local authorities. Requesting further information or evidence You may determine whether additional information, evidence or further checks are required by contacting the child to confirm their circumstances (where it is appropriate to do so, for example depending on the child’s age). You must only request further information or evidence which is necessary to inform a decision as to whether any safeguarding referral needs to be made, and where the information or evidence does not appear from Home Office records to have been previously provided and/or where updating information is necessary to enable the Home Office to comply with its statutory duties. --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. --- Official – sensitive: end of section If the child’s living arrangements are not apparent from the information or evidence provided or otherwise available to you as part of the application or as a result of additional checks, you must establish the living arrangements for the child. Where there is already some evidence provided or otherwise available to you as part of the application as to the child’s living arrangements, you must consider whether further information or evidence about these are needed and, if so, what is needed. Evidence which may be helpful in determining the living arrangements for the child (usually in combination) may include: - proof of identity of the parent or guardian, such as a passport, national identity card or driving licence (if a document has expired, it may still satisfy you of the parent or guardian’s identity) - evidence of relationship between the child and parent or guardian, such as a full birth certificate, adoption certificate, guardianship order - proof of the parent’s or guardian’s address, such as a utility bill, bank statement or NHS medical card - proof of the child’s address The examples above are not prescriptive or exhaustive. It may be that the child does not themselves directly possess such evidence or that they are unable, due to estrangement or other welfare reasons, to approach the person who may possess the relevant documentation. If so, alternative avenues, such as enquiries with the parent, guardian or other third parties, are to be pursued where possible. Enquiries with the parent, guardian or other third parties Depending on the age of the child, you may be able to get the information or evidence you need from the child themselves through additional enquiries. Otherwise, it may be necessary to speak to the parent or guardian or other third parties in order to obtain the relevant information or evidence. Documentation is not the only source of information or evidence which may help in determining the living arrangements for the child. Enquiries with other third parties who have a formal relationship with the child, for example teachers or social or healthcare workers, may be helpful for clarification or confirmation. Generally, if appropriate, the child is to be advised in advance of any enquiries which are to be carried out and who is to be contacted. You must also take account of any known parental issues such as mental or physical illness, parental separation or potential threats to the child (which may be the reason for them making the application without a parent or guardian). If the child objects to you contacting their parent, guardian or other third parties, you must seek advice from your senior caseworker or the Office of the Children’s Champion. --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Making a referral If you do not receive sufficient information or evidence to be satisfied that the applicant is being cared for by a parent or guardian and continue to have concerns about the child’s living arrangements in the UK, you must discuss the case with a senior caseworker, who will assess whether further enquiries are to be made or whether a referral is needed to the Children’s Services Department of the local authority where the child is living. The Office of the Children’s Champion can also provide case advice if there are any welfare or safeguarding concerns that have emerged following contact with the child, parent or guardian or other third parties. Where you continue to have doubts about who is caring for a child in the UK, or the information provided by the child indicates that they may be at risk of harm, then a referral must be made to Children’s Services. Where a child aged between 16 and 18 is living on their own, you must make further enquiries and, where appropriate, a referral, if you continue to have concerns about the child’s living arrangements in the UK. For example, if there are any indications that those living arrangements are not the child’s choice, the child has care or support needs or you suspect the child is otherwise at risk. Deciding the application The child’s application under the EU Settlement Scheme can generally be decided without undue delay, even where a referral to Children’s Services is required. Where the applicant has provided sufficient information and evidence to be granted settled status or pre-settled status, or such information and evidence is otherwise available, you must only consider delaying the decision if your enquiries have led you to believe there is reason to suspect that the child may be in need of protection or safeguarding and where concluding the case could put the child at continued or additional risk. For example, if there is reason to suspect that a child applying under the scheme may be a potential victim of modern slavery, you must consult your senior caseworker and refer to guidance contained in Victims of modern slavery which includes details on how to refer potential child victims of modern slavery to the National Referral Mechanism. Children adopted from outside the UK The UK’s adoption legislation governing the bringing of a child adopted from outside the UK into the UK applies to all prospective adopters who are habitually resident in the UK, whatever their nationality. It can amount to a criminal offence to bring a child into the UK where section 83 of the Adoption and Children Act 2002 (England & Wales), articles 58ZA and 58ZB of the Adoption (Northern Ireland) Order 1987 or section 58 of the Adoption and Children (Scotland) Act 2007 applies, without complying with the relevant requirements imposed by those provisions or by regulations made under them, including being assessed and approved by a registered adoption agency. Where those provisions, or regulations made under them, apply, the Department for Education or other relevant Central Authority in the UK must issue a Certificate of Eligibility to Adopt, which attests to the suitability of the adopters (confirming that they have been assessed as suitable to adopt by a registered adoption agency), before the child enters the UK. The intercountry adoption process and the legal requirements to be met before a child adopted from outside the UK can enter the UK exist to safeguard against the trafficking of children and to promote their welfare. Therefore, in cases where a child has been adopted from outside the UK, you must check whether a Certificate of Eligibility to Adopt is required and, if so, whether it has been issued. You must use the information below to help you check this. If a Certificate of Eligibility to Adopt has not been issued in a case where it is required, you may need to make a safeguarding referral and you must speak to your senior caseworker. Where a child was legally adopted in a country named on The Adoption (Recognition of Overseas Adoptions) Order 2013 on or after 3 January 2014 and that adoption took place more than 12 months before the date on which they are seeking to bring the child into the UK, the prospective adopters are not required to apply for a Certificate of Eligibility to Adopt. Where a child was legally adopted in a country named on The Adoption (Designation of Overseas Adoptions) Order 1973 or The Adoption (Designation of Overseas Adoptions) (Variation) Order 1993 before 3 January 2014, the prospective adopters are not required to apply for a Certificate of Eligibility to Adopt. A Certificate of Eligibility to Adopt (albeit worded slightly differently) will also be issued in all Hague Convention applications. Evidence that a Certificate of Eligibility to Adopt has been issued may, for example, be confirmed in a letter from the relevant Central Authority. However, you must also email the relevant Central Authority to check whether a Certificate of Eligibility to Adopt has been issued: - England - [email protected] - Scotland - [email protected] - Wales - [email protected] – for Hague Convention adoptions only, otherwise contact ICA Darlington - Northern Ireland - [email protected] for Hague Convention adoptions only, otherwise contact ICA Darlington Applicants aged over 18 and under 21 Applicants who are aged 18 or over are not considered to be children for safeguarding purposes. Where an applicant aged 18 or over and under 21 has supplied sufficient evidence to be granted settled status or pre-settled status, or such information and evidence is otherwise available, it will not generally be necessary to request additional information or evidence relating to their parent or guardian or to safeguarding. However, if there are any indicators that the applicant is at risk (for example modern slavery or human trafficking), you must consult a senior caseworker and refer to guidance contained in Victims of modern slavery which includes details on how to refer potential victims of modern slavery to the National Referral Mechanism. Related content Victims of modern slavery Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Every Child Matters Section 55 of the Borders, Citizenship and Immigration Act 2009 Child adoption: Adopting a child from overseas - GOV.UK Adoption and Children Act 2002 The Adoption (Northern Ireland) Order 1987 Adoption and Children (Scotland) Act 2007 Intercountry adoption: information for adoption agencies Adopted children and children coming to the UK for adoption caseworker guidance Applications in respect of adults with mental capacity issues and / or care or support needs This section tells you about how to deal with applications in respect of adults with mental capacity issues (who lack the mental capacity to make their own decisions) and / or care or support needs. Adults with care or support needs may include many of those adults with mental capacity issues, but will also include those adults with broader care or support needs, such as those who may be residing in a residential care home, or receiving care and support services in their own home, with long-term physical or mental health needs or a disability. Applications made on behalf of an adult with mental capacity issues and/or care or support needs Some adult applicants with care or support needs may have been signposted to sources of support to assist them to make their application. These include the Settlement Resolution Centre, Assisted Digital and grant funded voluntary and community organisations. Other adults with care or support needs, and adults with mental capacity issues, may need someone to make the application on their behalf. The Home Office can accept an application made on someone’s behalf by an appropriate third party in a range of circumstances. Applications can be made on someone’s behalf by for example: - a person with power of attorney for the applicant - a deputy appointed by the Court of Protection in England and Wales - a person with an intervention or guardianship order made in Scotland - a controller appointed by an order made by the High Court in Northern Ireland - a legal guardian - another appropriate third party, for example, a friend, relative, carer, social worker, support worker or legal representative If the person has the mental capacity to consent to an appropriate third party making an application on their behalf if they are unable to apply themselves, their consent must be sought. If the person’s mental capacity fluctuates, then their consent must be sought, when they are able to give it, for an appropriate third party to make an application on their behalf if they are unable to apply themselves. In all cases concerning lack of mental capacity, you must be satisfied that the person acting on behalf of the individual either or both: has the authority (in the general sense of permission or consent) to do so is acting in the best interests of the individual in accordance (in both cases) with the Mental Capacity Act (England and Wales) 2005, the Mental Health Order (Northern Ireland) 1986 or the Enduring Powers of Attorney Order (Northern Ireland) 1987, or is acting for the benefit of the adult and following the best interpretation of the adult’s wishes under the Adults with Incapacity Act (Scotland) 2000. For further guidance on dealing with applications made on behalf of adult applicants with mental capacity issues: - under the Mental Capacity Act (England and Wales) 2005, see [Make decisions on behalf of someone](#) - under the Adults with Incapacity Act (Scotland) 2000, see [Adults with incapacity: guide to assessing capacity](#) - under the Enduring Powers of Attorney Order (Northern Ireland) 1987, see [Managing your affairs and enduring power attorney](#) - under the Mental Health Order (Northern Ireland) 1986, see the statutory [Code of Practice](#) or [Guidelines on the use of the Mental Health Order (NI) 1986](#) If there are any indicators that the applicant is at risk, for example of abuse, exploitation or modern slavery, then you must first consult your senior caseworker. A referral to the local authority adult safeguarding team may be required, or you may need to refer to the guidance on Victims of modern slavery which includes details on how to refer potential victims of modern slavery to the National Referral Mechanism. Where you have any other concerns about the application, such as to why the applicant has not applied by themselves or whether the applicant is aware of the application, you must contact the applicant where appropriate, to check the relevant authorisation provided is genuine, before you deal with the application. If it is not appropriate to contact the applicant, which will depend on the specific circumstances of the case, then enquiries with the person making the application on behalf of the applicant are to be pursued where possible. If you still have concerns after making these enquiries, then you must consult your senior caseworker. Power of Attorney A Power of Attorney is a document that grants the holder (the attorney) power to make certain decisions on behalf of the person named in the document. Someone who holds Power of Attorney for an individual may make any necessary application for immigration status (including under the EU Settlement Scheme) on their behalf as a result of the Power of Attorney or as a result of their general duty to act in the best interests of the individual. In any given case, you must be satisfied that the person is acting within the scope of their decision-making powers by checking the terms of the Power of Attorney, which must be provided to support the application. For example, the Power of Attorney may grant the holder general authority to take possession and control of the affairs of the person named in the document. There are different types of Power of Attorney according to the jurisdiction: - in England and Wales, an attorney will be appointed under either a Lasting Power of Attorney (LPA) or an Enduring Power of Attorney (the forerunner of the LPA) – a person must be aged 18 or over to be able to make a Power of Attorney and have capacity to understand what they are doing when granting this - in Scotland, there are 3 types of Power of Attorney, either Continuing, Welfare or Combined, which can be made by a person aged 16 or over with capacity - in Northern Ireland, there is the Enduring Power of Attorney, which can be made by a person aged 18 or over with capacity You must check with the relevant office in the UK (the Office of the Public Guardian in England and Wales, the Office of the Public Guardian in Scotland or the Office of Care and Protection in Northern Ireland) or the relevant issuing office abroad if you have doubts about the document, including its validity. Court appointed authorisations In cases where an individual has not made a Power of Attorney and now lacks the capacity to make decisions, arrangements may have been made to have a formal decision maker appointed by a court. England and Wales: Deputy appointed by the Court of Protection A deputy is authorised by the Court of Protection to make decisions on behalf of a person who lacks the mental capacity to make decisions for themselves and where there is no Power of Attorney already in place. A deputy is usually a close relative or friend of the person who needs help making decisions. In other instances, a person can be engaged professionally to act as a deputy, for example, an accountant, solicitor or representative of the local authority. Appointed deputies may make any necessary application for immigration status (including under the EU Settlement Scheme) on behalf of an individual as a result of a legal duty in their court order (for example, property and financial affairs), or as a result of their general duty to act in the best interests of the individual. In either case, you must be satisfied that a deputy is acting within the scope of their decision-making powers by checking the terms of their court order, which must be provided to support the application. For example, the deputy order may grant the holder general authority to take possession and control of the affairs of the person lacking capacity. Scotland: Guardian or Intervener appointed by the Sheriff Court A guardianship order may cover all of the individual’s property and financial affairs and personal welfare, including healthcare matters. A similar scope applies to intervention orders, which are designed for actions with a specific end, as opposed to ongoing powers granted in a guardianship order. Northern Ireland: Controllers appointed by the Office of Care and Protection Controllers appointed by the Office of Care and Protection are authorised to administer the financial affairs of individuals lacking capacity. Legal guardianship An application can be made on behalf of an applicant by their legal guardian. You must be satisfied that there is evidence of a guardianship order in place. Applications made by another appropriate third party An application can be made on behalf of an adult applicant with mental capacity issues and/or care or support needs by another appropriate third party, for example a friend, relative, carer, social worker, support worker or legal representative. In each case, you must be satisfied that the person acting on behalf of the individual is authorised to do so and/or that they are acting in the best interests of the individual. Evidence that may satisfy you of this may include: - a letter from a doctor, health professional, social services department or solicitor confirming the circumstances - a letter from the applicant themselves, authorising someone to act on their behalf - evidence of a carer relationship where the third party is providing for the individual’s care needs, for example a Department for Work and Pensions letter confirming receipt of carer’s allowance The third party must provide their contact details when prompted at the end of the online application process or in the relevant section of the appropriate paper application form. The third party must upload a letter in the evidence section of the online application form (or provide this with the appropriate paper application form) to inform the caseworker of the individual’s circumstances, including the reasons why the application is being made by a third party and their relationship to that individual. If this is not uploaded or included with the application, you must request it from the third party. The third party must also ensure they are acting appropriately according to the requirements of the [Immigration Advice Authority](#) (IAA), previously known as the Office of the Immigration Services Commissioner. The IAA is a government body set up to protect those seeking immigration advice through regulation, enforcement and promoting best practice. Where advice or assistance is provided to an applicant by a friend or relative, who is not acting in a professional capacity, such advice and assistance does not require IAA regulation. Professionals such as carers, social workers or support workers can also provide technical assistance in completing the application without the need to be regulated by the IAA, but they should ensure that they are not providing immigration advice. For example, they may provide assistance in completing and submitting the application form, by explaining what the form is asking for and entering the applicant’s responses. Further information about assistance that can be provided without the requirement for regulation can be found in the [Immigration assistance: practice note](#). A legal representative must be regulated by the IAA or another Designated Qualifying Regulator in order to provide immigration advice or services related to the application. Non-fee charging organisations that wish to be able to provide immigration advice and services regarding the EUSS may apply for regulation to the IAA through a specific application process which will allow them to become regulated in this area of work only. This application is free of charge. Further details of this scheme can be found at: [Application for Level 1 EU Settlement Scheme registration](#). Further details on the application process for organisations that intend to charge applicants for assistance with an EUSS application can be found at: [How to become a regulated immigration adviser](#). Related content Related external links [Grant funded voluntary and community organisations](#) [Mental Capacity Act 2005](#) [Adults with Incapacity Act (Scotland) 2000](#) [Mental Health Order (Northern Ireland) 1986](#) [Enduring Powers of Attorney Order (Northern Ireland) 1987](#) [Make decisions on behalf of someone](#) [Adults with incapacity: guide to assessing capacity](#) [Managing your affairs and enduring power attorney](#) [Code of Practice for Mental Health Order (Northern Ireland) 1986](#) [Guidelines on the use of the Mental Health Order (Northern Ireland) 1986](#) [Office of the Public Guardian (OPG)](#) [Office of the Public Guardian in Scotland](#) [Office of Care and Protection in Northern Ireland](#) [About us - Immigration Advice Authority](#) [Immigration assistance: practice note](#) [Application for Level 1 EU Settlement Scheme registration](#) [How to become a regulated immigration adviser](#) Suitability Rules EU15, EU16 and EU17 of Appendix EU set out the basis on which an application under Appendix EU will or may be refused on suitability grounds. The assessment of suitability must be conducted on a case by case basis and be based on the applicant’s personal conduct or circumstances in the UK and overseas, including whether they have any relevant prior criminal convictions, and whether they have been open and honest in their application. Under rule EU15(1), an application under Appendix EU will be refused on grounds of suitability where, at the date of decision, the applicant is subject to: - a ‘deportation order’ (as defined in Annex 1 to Appendix EU) or to a decision to make a deportation order - an ‘exclusion order’ or ‘exclusion decision’ (as defined in Annex 1 to Appendix EU) If one of the orders or decisions specified in rule EU15(1) applies in respect of the applicant at the date the decision on the application under the scheme is made, the application must be refused. Under rule EU15(1A), an application under Appendix EU will be refused on grounds of suitability where, because of the applicant’s conduct committed before the specified date, the Secretary of State is satisfied that the decision to refuse the application is justified on the grounds of public policy, public security or public health in accordance with regulation 27 of the EEA Regulations, irrespective of whether the EEA Regulations apply to that person (except that in regulation 27 for ‘with a right of permanent residence under regulation 15’ and ‘who has a right of permanent residence under regulation 15’ read ‘who has indefinite leave to enter or remain under, or who meets the requirements of, paragraph EU11, EU11A or EU12 of, Appendix EU to the Immigration Rules’; and for ‘an EEA decision’ read ‘a decision under paragraph EU15(1A) of Appendix EU to the Immigration Rules’). Under rule EU15(2), an application made under Appendix EU will be refused on grounds of suitability where the Secretary of State deems the applicant’s presence in the UK is not conducive to the public good because of conduct committed after the specified date. Under rule EU15(3) and (4), where, at the date of decision on an application under Appendix EU, the applicant is subject to either: - an ‘Islands deportation order’ (as defined in Annex 1 to Appendix EU), the application will be refused on grounds of suitability - an ‘Islands exclusion decision’ (as defined in Annex 1 to Appendix EU), the application may be refused on grounds of suitability Applicants (aged 18 or over) are required to provide information about previous criminal convictions in the UK and overseas, and are only required to declare past criminal convictions which appear in their criminal record in accordance with the law of the state of conviction at the time of the application. There is no requirement to declare spent offences, cautions or alternatives to prosecution, for example fixed penalty notices for speeding. Applicants (aged 18 or over) are also required, as in other immigration applications, to declare whether they have any been involved in any terrorist related activities, war crimes, crimes against humanity or genocide. Applications are subject to a check against the Police National Computer (PNC, where the applicant is aged 10 or over) and the Warnings Index (WI). Caseworkers can, where appropriate, consider evidence of criminality that they encounter on the PNC or WI even if that evidence was not declared by the applicant. From information provided by the applicant and obtained from the PNC and/or WI, Customer Services Group (formerly UK Visas and Immigration) must determine whether the application is to be referred to Immigration Enforcement (IE) for full case by case consideration of the individual’s conduct on: - grounds of public policy, public security or public health as set out in the European Economic Area (EEA) Regulations, as saved, where the conduct was committed before the specified date - the ground the Secretary of State deems the applicant’s presence in the UK is not conducive to the public good, where the conduct was committed after the specified date If a decision is then made by IE that falls within rule EU15(1), EU15(1A) or EU15(2) (such as a decision to deport or exclude the individual), the application under the scheme will be refused by IE. The refusal under the EUSS must include a public policy, public security or public health consideration if the decision by IE was made on non-conducive grounds for conduct committed before 11pm GMT on 31 December 2020. If the person is the subject of a pending prosecution which may result in deportation action being taken if the person is convicted, but at the point of consideration the person does not fall to be refused on suitability grounds, the EUSS application must be progressed and, if all validity, eligibility and suitability criteria are met, the relevant leave must be granted. If that person is subsequently convicted, deportation action may then be considered and, where a deportation order is made, this will invalidate the leave under section 5(1) of the Immigration Act 1971. Under rule EU16 an application under Appendix EU may be refused on grounds of suitability where, at the date of decision, the decision-maker is satisfied that: - EU16(a): it is proportionate to refuse the application where, in relation to the application and whether or not to the applicant’s knowledge, false or misleading information, representations or documents have been submitted (including false or misleading information submitted to any person to obtain a document used in support of the application), and the information, representation or documentation is material to the decision whether or not to grant the applicant indefinite leave to enter or remain or limited leave to enter or remain under the scheme - EU16(b): it is proportionate to refuse the application where, the applicant is subject to a removal decision under the [EEA Regulations](#) on the grounds of their non-exercise or misuse of rights, and the date of application under Appendix EU is before 1 July 2021 - EU16(c): the applicant either: - has previously been refused admission to the UK in accordance with regulation 23(1) of the [EEA Regulations](#) - has previously been refused admission to the UK in accordance with regulation 12(1)(a) of the [Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020](#) - had indefinite or limited leave to enter or remain granted under Appendix EU (or limited leave to enter granted by virtue of having arrived in the UK with entry clearance that was granted under Appendix EU (Family Permit)) which was cancelled under paragraph 321B(b)(i) or 321B(b)(ii) of the Immigration Rules, under paragraph A3.1., A3.1A., A3.1B. or A3.2.(a) of Annex 3 to Appendix EU or under paragraph A3.3. or A3.4.(a) of Annex 3 to Appendix EU (Family Permit) - and (in either case) the refusal of the application is justified either: - in respect of the applicant’s conduct committed before the specified date, on grounds of public policy, public security or public health in accordance with regulation 27 of the [EEA Regulations](#), irrespective of whether those Regulations apply to that person (except that in regulation 27 for ‘with a right of permanent residence under regulation 15’ and ‘who has a right of permanent residence under regulation 15’ read ‘who has indefinite leave to enter or remain under, or who meets the requirements of, paragraph EU11, EU11A or EU12 of, Appendix EU to the Immigration Rules’; and for ‘an EEA decision’ read ‘a decision under paragraph EU16(c) of Appendix EU to the Immigration Rules’), and it is proportionate to refuse the application (taking into account the particular circumstances and facts of the case at the date of decision) - in respect of conduct committed after the specified date, where the Secretary of State deems the applicant’s presence in the UK is not conducive to the public good - EU16(d): it is proportionate to refuse the application where the applicant is a relevant excluded person (as defined in Annex 1 to Appendix EU) because of their conduct committed before the specified date and the Secretary of State is satisfied that the decision to refuse the application is justified on the grounds of public policy, public security or public health in accordance with regulation 27 of the EEA Regulations, irrespective of whether the EEA Regulations apply to that person (except that in regulation 27 for ‘with a right of permanent residence under regulation 15’ and ‘who has a right of permanent residence under regulation 15’ read ‘who has indefinite leave to enter or remain under, or who meets the requirements of, paragraph EU11, EU11A or EU12 of, Appendix EU to the Immigration Rules’; and for ‘an EEA decision’ read ‘a decision under paragraph EU16(d) of Appendix EU to the Immigration Rules’) - EU16(e): the applicant is a relevant excluded person because of conduct committed after the specified date When considering whether to refuse on the basis of rule EU16(a), the decision-maker must examine whether the deception is material to the decision whether or not to grant the applicant indefinite leave to enter or remain or limited leave to enter or remain under the scheme. This is where the false or misleading information, representation or documentation concerns the applicant’s ability to meet the requirements of Appendix EU. Where false information, representations or documents have been submitted, whether or not to the applicant’s knowledge, and which are material to the decision whether or not to grant the applicant indefinite leave to enter or remain or limited leave to enter or remain under the scheme, the decision-maker may refuse the application on the basis of rule EU16(a), provided that it is proportionate to do so. You must not decide that an application falls to be refused under rule EU16(a) without first notifying the applicant in writing that you are thinking of refusing the application based on false or misleading information, representations or documents and setting out exactly what the allegation is in this regard, including making clear that it is your view that there has been dishonesty or deception. You must give the applicant a reasonable period in which to respond to the notification sent by letter or given in an interview. What is reasonable will depend on the circumstances, but in most cases 14 calendar days will be sufficient. When considering whether to refuse on the basis of rule EU16(b), the decision-maker may refuse the application only where it is proportionate to do so and the date of application under Appendix EU is before 1 July 2021. A refusal on the basis of rule EU16(c) may only take place where the applicant has previously either: - been refused admission under regulation 23(1) of the EEA Regulations (as saved) - been refused admission to the UK under regulation 12(1)(a) of the Citizens’ Rights (Frontier Workers) (EU Exit) Regulations 2020 - had previous leave granted under Appendix EU, or acquired by virtue of having arrived in the UK with entry clearance granted under Appendix EU (Family Permit), which in either case was cancelled: - under paragraph 321B(b)(i) or 321B(b)(ii) of the Immigration Rules - under paragraph A3.1., A3.1A., A3.1B. or A3.2.(a) of Annex 3 to Appendix EU - under paragraph A3.3. or A3.4.(a) of Annex 3 to Appendix EU (Family Permit) The decision to refuse the application under rule EU16(c) must be justified on grounds of public policy, public security or public health in accordance with regulation 27 of the EEA Regulations, as saved, irrespective of whether they apply to the person, and must only be made where it is proportionate to do so, unless the conduct took place after the specified date in which case it must be justified on the grounds that the decision is conducive to the public good. Rule EU16(d) and EU16(e) of Appendix EU are also discretionary provisions and provide for the refusal of an application where, at the date of the decision, the applicant is a ‘relevant excluded person’ as defined in Annex 1 to Appendix EU. Rule EU16(d) applies where a person is a ‘relevant excluded person’ on the basis of conduct committed before the specified date. Under rule EU16(d), an application can only be refused where, additionally, refusing the application is justified and proportionate on the grounds of public policy, public security or public health. Rule EU16(e) applies where a person is a ‘relevant excluded person’ because of conduct committed after the specified date. A ‘relevant excluded person’ means a person: - in respect of whom the Secretary of State has made a decision under Article 1F of the Refugee Convention to exclude the person from the Refugee Convention or under paragraph 339D of the Immigration Rules to exclude them from humanitarian protection - in respect of whom the Secretary of State has previously made a decision that they are a person to whom Article 33(2) of the Refugee Convention applies because there are reasonable grounds for regarding them as a danger to the security of the UK - who the Secretary of State considers to be a person in respect of whom either of the previous 2 would apply except that: - the person has not made a protection claim - the person made a protection claim which has already been finally determined without reference to Article 1F of the Refugee Convention or paragraph 339D of the Immigration Rules - in respect of whom the Secretary of State has previously made a decision that they are a person to whom Article 33(2) of the Refugee Convention applies because, having been convicted by a final judgment of a particularly serious crime, they constitute a danger to the community of the UK Under rule EU17, the application must not be refused on the basis of an order or decision as specified in EU15 or EU16 which, at the date of decision on the application, has been set aside or revoked. As noted in rule EU18, Annex 3 to Appendix EU applies in respect of the cancellation, curtailment and revocation of leave to enter or remain granted under Appendix EU. See: EU Settlement Scheme: suitability requirements for more detailed guidance on suitability assessment. Related content [Contents](#) EU Settlement Scheme: suitability requirements Related external links [Appendix EU to the Immigration Rules](#) [Immigration (European Economic Area) Regulations 2016](#) Qualifying residence Continuous qualifying period Completing, as a relevant European Economic Area (EEA) citizen or their family member, a continuous qualifying period of residence in the UK and Islands (or in the UK, where this is the requirement in some scenarios involving a person who has ceased activity or a family member who has retained the right of residence) generally means that the applicant was resident in the UK and Islands (or, where applicable, the UK) before 11pm on 31 December 2020, except in the case of: - a joining family member of a relevant sponsor (whose continuous qualifying period can only begin on or after 1 January 2021) - a relevant EEA family permit case - a specified relevant person of Northern Ireland (or the dependent relative of such a person) - an applicant who relies on any of bullet points 3 to 6 in the list of exceptions below, under which certain absence will not count towards any period of residence in the UK and Islands on which the person relies - in such circumstances, a person who has previously been granted limited leave to enter or remain under Appendix EU may need to seek a further grant of such leave in order to complete a continuous qualifying period of 5 years’ residence in order to be eligible for indefinite leave to enter or remain) Completing a continuous qualifying period of residence also generally means that the applicant has not been absent from the UK and Islands (or, where applicable, the UK) for more than 6 months in total (in a single period of absence or more than one) in any given 12-month period, throughout the period of residence relied upon by the applicant. This includes where the applicant has previously been granted limited leave to enter or remain under Appendix EU and is now seeking to rely upon having completed a continuous qualifying period of 5 years’ residence in order to be eligible for indefinite leave to enter or remain. There are some exceptions: - a single period of absence of more than 6 months but which does not exceed 12 months is permitted, where this is for an important reason, such as pregnancy, childbirth, serious illness, study, vocational training or an overseas posting, or due to domestic violence or abuse, or because of COVID-19: - evidence to support an absence as a result of pregnancy, childbirth or serious illness might take the form of a letter or other records from a qualified medical professional - evidence to support an absence as a result of study, vocational training or an overseas posting might take the form of a letter or other records from the relevant educational establishment or employer evidence to support an absence due to domestic violence or abuse will need to demonstrate that the relevant family relationship broke down permanently as a result of domestic violence or abuse - evidence to support an absence because of COVID-19 - a single period of absence of more than 6 months but which does not exceed 12 months is permitted, where the absence was not originally for an important reason but is to be treated as being for an important reason as it exceeded 6 months because of COVID-19 - (following a period of absence under the first bullet point above because of COVID-19 or under the second bullet point above) a second period of absence of more than 6 months but which does not exceed 12 months is permitted, where both: - this is for an important reason (such as described in the first bullet point above) - save for caring for someone with a serious illness, that reason is not because of COVID-19 - The period of this absence exceeding 6 months will not count towards any period of residence in the UK and Islands on which the person relies - (following a period of absence under the first bullet point above which, save for caring for someone with a serious illness, was not because of COVID-19) a second period of absence of more than 6 months but which does not exceed 12 months is permitted, where both: - this is for an important reason - that reason is because of COVID-19 - The period of this absence exceeding 6 months will not count towards any period of residence in the UK and Islands on which the person relies - (following a period of absence under the first bullet point above which, save for caring for someone with a serious illness, was not because of COVID-19) a period of absence under the second bullet point above is permitted; the period of this absence exceeding 6 months will not count towards any period of residence in the UK and Islands on which the person relies - a period of absence under any of the bullet points above which exceeded 12 months is permitted, where COVID-19 meant that the person was prevented from, or advised against, returning earlier; the period of this absence exceeding 12 months will not count towards any period of residence in the UK and Islands on which the person relies - any period of absence on compulsory military service: - evidence to support a period of absence as a result of compulsory military service might take the form of a letter or other records from the relevant government body - any period of absence on a posting on Crown service or (as a spouse, civil partner, durable partner or child) accompanying a person on a posting on Crown service - See Crown servants and HM Forces personnel - any period spent working in the UK marine area (as defined in section 42 of the Marine and Coastal Access Act 2009) - any period of absence due directly to an order or decision to which subparagraph (b)(iii) of the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU refers (as described below), where that order or decision has been set aside or revoked The continuous qualifying period must continue at the date of application, unless one of the exceptions set out in sub-paragraph (c) of the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU applies. These exceptions are that either: - under sub-paragraph (c)(i), the continuous qualifying period is of at least 5 years’ duration - under sub-paragraph (c)(ii)(aa), the person acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations (or, where there are reasonable grounds for the person’s failure to meet the deadline applicable to them in the entry for required date in Annex 1 to Appendix EU, would have acquired such a right had the EEA Regulations not been revoked), or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man - under sub-paragraph (c)(ii)(bb)(aaa), the continuous qualifying period relates to a relevant EEA citizen, where, in relation to that EEA citizen, a family member applicant relies either: - in (i), for all or part of the continuous qualifying period of 5 years to which condition 3 in rule EU11 of Appendix EU refers (or, as the case may be, for part of the period to which sub-paragraph (b) of condition 3 in the table in paragraph EU12 refers), on having been a family member of a relevant EEA citizen - in (ii), on being or having been a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen provided (in any case) the continuous qualifying period relating to that relevant EEA citizen continued (unless sub-paragraph (c)(i), (c)(ii)(aa), (c)(iii) or (c)(iv) of the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU applied to that relevant EEA citizen instead) either, as the case may be, throughout the continuous qualifying period the applicant relies on in (i) as having been a family member of a relevant EEA citizen or, as relied on in (ii), until the applicant became a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen - under sub-paragraph (c)(ii)(bb)(bbb), the continuous qualifying period relates to a relevant sponsor, where, in relation to that relevant sponsor, a joining family member applicant relies for all or part of the continuous qualifying period of 5 years to which condition 1 in rule EU11A of Appendix EU refers on having been (or, as the case may be, relies for all or part of the continuous qualifying period to which the condition in rule EU14A of Appendix EU refers on being) a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, provided (in either case) the continuous qualifying period relating to that relevant sponsor continued (unless sub-paragraph (c)(i), (c)(ii)(aa), (c)(iii) or (c)(iv) of the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU applied to that relevant sponsor instead) until the applicant became a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - under sub-paragraph (c)(iii), the person has valid indefinite leave to enter or remain granted under Appendix EU (or under its equivalent in the Islands) under sub-paragraph (c)(iv), there is valid evidence of their indefinite leave to enter or remain under sub-paragraph (c)(v), a relevant reference is concerned A ‘relevant reference’ (to a continuous qualifying period completed in the past) means the reference to continuous qualifying period in either: - condition 6 in rule EU11 of Appendix EU - condition 3 in rule EU11A of Appendix EU - sub-paragraph (d)(iii)(aa) of the entry for ‘family member who has retained the right of residence’ in Annex 1 to Appendix EU (as that reference applies to, as the case may be, the relevant EEA citizen, the qualifying British citizen or the relevant sponsor) - (where the date of application is on or after 1 July 2021) also any of the additional provisions listed in that definition of ‘relevant reference’ within the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU A continuous qualifying period is broken where the person served or is serving a sentence of imprisonment of any length in the UK and Islands (or, where applicable, the UK), unless the conviction which led to it has been overturned. Under sub-paragraph (b)(iii) of the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU, a continuous qualifying period is also broken by any of the following in respect of the person, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under the equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the EEA Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision Once a person has completed a continuous qualifying period of residence in the UK and Islands of 5 years, they may rely on this in applying for settled status under the scheme (under condition 3 in rule EU11 or condition 1 in rule EU11A) where, since completing that 5 year period, there has been no ‘supervening event’. This means that, since completing that 5 year period, they have not been absent from the UK and Islands for more than 5 consecutive years and that none of the decisions or orders set out above has been made in respect of the person, unless it has been set aside or revoked. Where the applicant served or is serving a sentence of imprisonment of any length in the UK and Islands, and where prior to that they have completed a continuous qualifying period of residence in the UK and Islands of less than 5 years (and the person has not acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man), that continuous qualifying period is broken, and restarts from scratch on release (where release is before the specified date, where a continuous qualifying period which started before that date is required). Where the continuous qualifying period of a relevant EEA citizen is broken and restarted in this way, this also breaks and restarts any continuous qualifying period of residence of less than 5 years on which their family member relies (where they have not acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands) as being a family member of a relevant EEA citizen. However, imprisonment which does not lead to deportation is not a ‘supervening event’ for the purposes of the scheme. This means that a person may rely on having previously either: - acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations - acquired the right of permanent residence in the Islands through the application there of section 7 of the Immigration Act 1988 (as it had effect before it was repealed) or under the EEA Regulations of the Isle of Man - completed a continuous qualifying period of residence in the UK and Islands of 5 years in applying for settled status even where they have been imprisoned since acquiring that right (or completing that period), provided that the imprisonment did not or does not lead to deportation. When assessing whether an applicant has a continuous qualifying period of residence in the UK, the applicant’s immigration status during the period of residence relied on, including whether they were at any point exempt from immigration control while resident in the UK, is immaterial: the test is whether all the relevant criteria set out in the definition of continuous qualifying period are met. Where an applicant is granted settled status (indefinite leave to enter or remain under Appendix EU), their status will lapse when they have been absent from the UK and Islands for a period of more than 5 consecutive years (or of more than 4 consecutive years in the case of Swiss citizens and their family members). There are exceptions for those overseas on Crown service and those accompanying them. Where a person’s settled status has lapsed, they can apply under Appendix Returning Resident to the Immigration Rules if they want to return to and settle in the UK. Further information can be found at Returning residents. Where an applicant is granted pre-settled status (limited leave to enter or remain under Appendix EU), their status will generally lapse when they have been absent from the UK and Islands for either: • a period of more than 2 consecutive years which occurred before 21 May 2024 • a period of more than 5 consecutive years (or of more than 4 consecutive years in the case of Swiss citizens and their family members) which occurred on or after 21 May 2024 (and may have begun before that date) There are exceptions for those overseas on Crown service and those accompanying them. COVID-19 Where this guidance refers to absence ‘because of COVID-19’, it means where an EEA citizen or their family member, who was resident in the UK and Islands (or, where applicable, the UK) by the end of the transition period at 11pm on 31 December 2020 (or who, having been so, relies on any of the exceptions above under which certain absence will not count towards any period of residence in the UK and Islands on which the person relies), has been: • ill with COVID-19 • in quarantine, self-isolating or shielding in accordance with local public health guidance on COVID-19 • caring for a family member affected by COVID-19 • prevented from returning earlier to the UK due to travel disruption caused by COVID-19 • advised by their university that, due to COVID-19, their course was moved to remote learning and were advised or allowed to return to their home country to study remotely • advised by their university or employer not to return to the UK, and to continue studying or working remotely from their home country • absent for another reason relating to COVID-19, for example, they left or remained outside the UK because there were fewer coronavirus restrictions elsewhere; they preferred to work or run a business from home overseas; or they would have been unemployed in the UK and preferred to rely on support from family or friends overseas This means that such a person can rely on any COVID-19 related reason (including where they chose to leave or remain outside the UK because of the pandemic) as being an ‘important reason’ permitting an absence of up to 12 months. The above is a non-exhaustive list of COVID-19 related reasons for absence and each case must be considered on an individual basis in light of the information and evidence provided by the applicant. For a non-exhaustive list of examples of relevant evidence, see below. As set out above, a second period of absence of more than 6 months but which does not exceed 12 months is permitted where you are satisfied this was (or is to be treated as being) for an ‘important reason’ and, save for caring for someone with a serious illness, one of those absences (not both) is because of COVID-19. Each case must be considered on an individual basis in light of the information and evidence provided by the applicant. For a non-exhaustive list of examples of relevant evidence, see below. This means a person can rely on any COVID-19 related reason (including where they chose to leave or remain outside the UK because of the pandemic) as the basis for requiring a second period of absence of up to 12 months for an ‘important reason’. In such a case, up to the first 6 months of the second period of absence will be counted towards their continuous qualifying period of residence, where the period counted means they have not been absent for more than 6 months in any 12-month period. Their continuous qualifying period will be paused from that point and will resume from the point of return to the UK and Islands (or, where applicable, the UK). As also set out above, a period of absence may exceed the 12-month maximum for a period of absence for an ‘important reason’ where COVID-19 meant that the person was prevented from, or advised against, returning to the UK and Islands (or, where applicable, the UK) earlier, such as where they were: - ill with COVID-19 - in quarantine, self-isolating or shielding in accordance with local public health guidance on COVID-19 - caring for a family member affected by COVID-19 - prevented from returning earlier to the UK due to travel disruption caused by COVID-19 - advised by their university or employer not to return to the UK, and to continue studying or working remotely from their home country, due to COVID-19 This is a non-exhaustive list of such reasons and each case must be considered on an individual basis in light of the information and evidence provided by the applicant. For a non-exhaustive list of examples of relevant evidence, see below. In such a case, the absence beyond 12 months will not be counted as residence in the UK and Islands (or, where applicable under Appendix EU, the UK) for the purposes of the EUSS. Their continuous qualifying period will be paused from the point their absence reached 12 months and will resume from the point of return to the UK and Islands (or, where applicable, the UK). Where, in the case of a person granted limited leave to enter or remain under Appendix EU as an EEA citizen or their family member who was resident in the UK and Islands (or, where applicable, the UK) by the end of the transition period, their absence (regardless of the reason for it) has exceeded 2 consecutive years if it occurred before 21 May 2024 – or has exceeded 5 consecutive years (or exceeded 4 consecutive years in the case of Swiss citizens and their family members) if it occurred on or after 21 May 2024 (and may have begun before that date) – that limited leave will have lapsed (meaning that, if they have a biometric residence card, this is no longer valid even if it is within its expiry date), in accordance with article 13(4) of the Immigration (Leave to Enter and Remain Order) 2000. Where that absence is in accordance with this guidance, they will be able to apply for a further grant of limited leave to enter or remain under Appendix EU. They can do so from outside the UK where they have the ‘required proof of entitlement to apply from outside the UK’. Otherwise, they will need to apply for an EU Settlement Scheme family permit in order to return to the UK and make a further application under the scheme. In all cases, the applicant will need to provide evidence of the length of, and reason for, any absence relating to COVID-19 on which they rely. Examples of acceptable evidence include: - used travel tickets confirming the dates the applicant left the UK and returned - confirmation of flight cancellations detailing the dates and times - doctor’s letter confirming the applicant contracted COVID-19 - doctor’s letter confirming the applicant was identified as vulnerable and advised to shield - email or letter confirming the applicant, or a person they were living with, received a positive COVID-19 test result - official letter confirming the applicant was in COVID-19 quarantine - doctor’s letter confirming the applicant’s family member, for whom they have been caring, contracted COVID-19 or was identified as vulnerable and advised to shield - email or letter confirming the applicant’s family member, for whom they have been caring, received a positive COVID-19 test result - email or letter from a university advising that, due to COVID-19, their course was moved to remote learning and they were advised or allowed to return to their home country to study remotely - email or letter from a university or employer advising the applicant not to return to the UK, and to continue studying or working remotely from their home country, due to COVID-19 - letter or other evidence from the applicant accounting for their absence for another reason relating to the COVID-19 pandemic, for example, they left or remained outside the UK because there were fewer COVID-19 restrictions elsewhere; they preferred to work or run a business from home overseas; or they would have been unemployed in the UK and preferred to rely on support from family or friends overseas This list is non-exhaustive, and each case must be considered on a case by case basis. As elsewhere under the EU Settlement Scheme, you may exercise discretion in favour of the applicant where appropriate, to minimise administrative burdens, and you must refer to your senior caseworker if you require further advice. Crown servants and HM Forces personnel Where, before an overseas posting, the applicant was resident in the UK and Islands, their continuous qualifying period of residence can include either: - any period of absence from the UK and Islands on a posting on Crown service - any period of absence from the UK and Islands, as a spouse, civil partner, durable partner or child, accompanying an EEA citizen or a British citizen on a posting on Crown service Crown service is defined under Annex 1 to Appendix EU as service as either: - a member of HM Forces (as defined in the Armed Forces Act 2006) - an employee of the UK Government, a Northern Ireland department, the Scottish Administration or the Welsh Government - a permanent member of the British Council Before considering whether the applicant’s time overseas should be counted towards their continuous qualifying period, you must first confirm that they were resident in the UK and Islands before the posting in the normal way (automated checks or alternative evidence of residence). To evidence their time overseas, the applicant may provide for example a letter on official stationery from the Head or Deputy Head of Mission, the Head of Office, the Head of Establishment in their Unit, or the department’s Head of Human Resources, confirming: - the start date of the overseas posting - the end date of the overseas posting (if applicable) - the period during which the spouse, civil partner, durable partner or child accompanied the Crown servant overseas (if applicable) Crown Dependencies Time spent in the Crown Dependencies – the Bailiwick of Guernsey, the Bailiwick of Jersey or the Isle of Man (‘the Islands’ as defined in Annex 1 to Appendix EU) – can count towards any or all of the applicant’s continuous qualifying period of residence as a relevant EEA citizen or their family member, except under sub-paragraph (a)(ii) or (d)(iii)(aa) of the entry for ‘family member who has retained the right of residence’ in Annex 1 to Appendix EU or in sub-paragraph (c) of the entry for ‘person who has ceased activity’ in Annex 1 to Appendix EU or as a ‘person with a derivative right to reside’ or a ‘person with a Zambrano right to reside’ – where (in each case) the period of residence must be in the UK. Automated checks of HM Revenue & Customs and Department for Work and Pensions data do not confirm residence in the Crown Dependencies and the applicant may provide other evidence which reflects that in the [evidence of residence](#) section of this guidance. Overseas Territories Time spent in Gibraltar or the other Overseas Territories does not count towards an applicant’s continuous qualifying period of residence, unless it is on Crown service or accompanying such a person (see above). Automated checks In applications by relevant EEA citizens and their family members in which the applicant provides their National Insurance number, automated checks – known as Application Programming Interface (API) – will be run against HM Revenue & Customs (HMRC) and certain Department for Work and Pensions (DWP) records to establish what those records tell us about the applicant’s residence in the UK. Where these checks indicate that the applicant has been resident in the UK for a continuous qualifying period of 5 years, and where the applicant has confirmed, by way of a self-declaration as part of the application process, that they have not since been absent from the UK for a period of more than 5 consecutive years, no further evidence of residence will be required to determine eligibility. The applicant will be asked to confirm this is correct and, subject to evidence of the relevant family relationship (where relevant) and to suitability checks, the applicant will be granted indefinite leave to enter (ILE) or indefinite leave to remain (ILR). Where these checks indicate that the applicant has been resident in the UK for a continuous qualifying period of less than 5 years, and the applicant confirms this (and does not claim to qualify for settled status on the basis of a continuous qualifying period of less than 5 years), no further evidence of residence will be required to determine eligibility. Subject to evidence of the relevant family relationship (where relevant) and to suitability checks, the applicant will be granted 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR). Where these checks indicate that the applicant has been resident in the UK for a continuous qualifying period of less than 5 years, and the applicant does not accept this (or claims to qualify for settled status on the basis of a continuous qualifying period of less than 5 years), the applicant will be asked to provide documentary evidence, to satisfy you of their eligibility for ILE or ILR. If the applicant does so, and subject to evidence of the relevant family relationship (where relevant) and to suitability checks, the applicant will be granted ILE or ILR. If they do not meet the eligibility requirements for ILE or ILR but have been resident in the UK for a continuous qualifying period of less than 5 years, subject to evidence of the relevant family relationship (where relevant) and to suitability checks, they will be granted LTE or LTR. Where these checks do not provide any evidence of the applicant’s UK residence, or the applicant does not provide a National Insurance number, the applicant will be asked to provide documentary evidence to satisfy you that they meet the requirements for eligibility for either ILE or ILR or LTE or LTR. If the applicant does so, and subject to evidence of the relevant family relationship (where relevant) and to and suitability checks, the applicant will be granted ILE or ILR or LTE or LTR as appropriate. See evidence of residence for further information on evidence which may be provided where automated checks do not confirm a continuous qualifying period of residence as claimed by the applicant. Automated conversion from pre-settled to settled status Where automated conversion from pre-settled status (LTE or LTR) to settled status (ILE or ILR) is considered, and a National Insurance number is available, checks will be run against HMRC and certain DWP records to establish if the pre-settled status holder has been resident in the UK for a continuous qualifying period of 5 years and, if they have, that there has since been no absence constituting a ‘supervening event’. Where these checks indicate that this is so, no further evidence of residence will be required and, where no other eligibility criteria apply and subject to suitability checks, they will be granted settled status (ILE or ILR). The person is entitled to request, via the Resolution Centre, a manual reconsideration of the assessment of their continuous residence in the UK on which an automated decision to convert their pre-settled status to settled status is based. Where such a request is received, you must conduct a manual check of HMRC and certain DWP records to confirm whether the person has been resident in the UK for a continuous qualifying period of 5 years. You must reconsider the case in light of the outcome of that manual check, recording any additional information for the reconsideration in the relevant free text box. You must inform the person of the outcome of the manual reconsideration within one month of the date on which their request for it is received. Related content Contents Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Armed Forces Act 2006 Consideration of applications: ILE or ILR An applicant who has made a valid application will be eligible for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) as a relevant European Economic Area (EEA) citizen or their family member where you are satisfied (including, where applicable, by the required evidence of family relationship) one of the conditions of rule EU11 of Appendix EU is met: - permanent residence (PR) document holders - holders of indefinite leave to enter (ILE) or indefinite leave to remain (ILR) held since before the end of the transition period - applicant has completed a continuous qualifying period of 5 years - a relevant EEA citizen who is a person who has ceased activity - family member of a relevant EEA citizen who is a person who has ceased activity - family member of a relevant EEA citizen who has died - child under the age of 21 years of a relevant EEA citizen or of their spouse or civil partner An applicant who has made a valid application will be eligible for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) as a family member of a relevant sponsor where you are satisfied (including, where applicable, by the required evidence of family relationship) one of the conditions of rule 11A of Appendix EU is met: - joining family member of a relevant sponsor who has completed a continuous qualifying period of 5 years - family member who has retained the right of residence by virtue of a relationship with a relevant sponsor who has completed a continuous qualifying period of 5 years - joining family member of a relevant sponsor who is a person who has ceased activity - joining family member of a relevant sponsor who has died - joining family member who is a child under the age of 21 years of a relevant sponsor or of their spouse or civil partner Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Official – sensitive: end of section Supervening event A supervening event means that, at the date of application either: - the person has been absent from the UK and Islands for a period of more than 5 consecutive years at any point since they last either: - acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations - acquired the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man - completed a continuous qualifying period of 5 years - any of the following events has occurred in respect of the person, unless it has been set aside or revoked: - any decision or order to exclude or remove them from the UK under regulation 23 or 32 of the EEA Regulations (or under equivalent provisions of the EEA Regulations of the Isle of Man) - a decision to which regulation 15(4) of the EEA Regulations otherwise refers in respect of their right to permanent residence in the UK, unless that decision arose from a previous decision under regulation 24(1) (or the equivalent decision, subject to the equivalent qualification, under the Immigration (European Economic Area) Regulations of the Isle of Man) - an exclusion decision - a deportation order, other than by virtue of the EEA Regulations - an Islands deportation order - an Islands exclusion decision Where indicated in Appendix EU in relation to eligibility for indefinite leave to enter or remain, the requirement that there has been ‘no supervening event’ applies in respect of the applicant. In relation to an applicant’s eligibility for limited leave to enter or remain under Appendix EU as a family member of a relevant EEA citizen or as a joining family member of a relevant sponsor, the requirement that there has been ‘no supervening event’ applies in respect of (as the case may be) the relevant EEA citizen or the relevant sponsor. Related content Contents Related external links Appendix EU to the Immigration Rules Permanent residence (PR) document holders Under condition 1 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) as a relevant European Economic Area (EEA) citizen, a family member of a relevant EEA citizen or a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, where you are satisfied that they have a documented right of PR and no supervening event has occurred in respect of the applicant. Requirements You must be satisfied that at the date of application: - the applicant has been issued with either: - a document certifying permanent residence or a permanent residence card under the EEA Regulations - a residence permit or residence document under the Immigration (European Economic Area) Order 1994 endorsed to show permission to remain in the UK indefinitely - the document or card is not invalid under regulation 19(4)(c) because the applicant never had a right of permanent residence and, if a permanent residence card, was issued or renewed within the last 10 years - the document or card has not been revoked, and its renewal has not been refused under regulation 24 (except where the revocation or refusal occurred because the applicant had been absent from the UK for a period of more than 2, and no more than 5, consecutive years) - the person’s right to reside has not been cancelled under regulation 25 Or you must be satisfied that at the date of application either: - the person has been given notice in writing under paragraphs 256 to 257A of the Immigration Rules of the Bailiwick of Guernsey showing that they may remain indefinitely, and this notice has not been revoked or otherwise ceased to be effective - the person has been issued by the relevant Minister with a document in accordance with paragraphs 255 to 258 of the Immigration Rules of the Bailiwick of Jersey in an appropriate form certifying permanent residence or a permanent residence card, and this document or card has not been revoked or otherwise ceased to be effective - the person has been issued with a letter certifying permanent residence, or their passport has been stamped to that effect, under the Immigration (European Economic Area) Regulations of the Isle of Man, and this evidence has not been revoked, invalidated or cancelled In addition, you must be satisfied that no supervening event has occurred in respect of the applicant. Relevant evidence The applicant must provide confirmation, via self-declaration within the required application process, that they have not been absent from the UK or Islands for a period of more than 5 consecutive years at any point since they last acquired the right of permanent residence as set out above. As set out above, you must be satisfied that the applicant has the documented right of permanent residence. If an applicant cannot provide the PR document (or its equivalent) or its reference number, for example because the number is damaged or obscured, or the document never had one, you must check Home Office records (or liaise with the Islands) and, if there is no record available, contact the applicant for further details such as approximate date of issue to narrow any searches. If there is still no trace, the applicant must be invited to submit the document for you to consider. In these circumstances, you must discuss this with your senior caseworker. Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Official – sensitive: end of section If the applicant has been subject to one of the decisions or orders in ‘supervening event’, you must discuss with your senior caseworker before further action is taken. Where an applicant has declared that they have a documented right of PR and they have not been absent from the UK and Islands for a period of more than 5 consecutive years at any point since they last acquired the right of permanent residence as set out above, but it is identified during the caseworking process that this is not the case, the applicant is not eligible for ILE or ILR under this condition. Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If, however, you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their eligibility for ILE or ILR under the other eligibility conditions in rule EU11 and otherwise their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a joining family member of a relevant sponsor for ILE or ILR under rule EU11A or for 5 years’ LTE or LTR under rule EU14A. Scenario 1 Miss A has applied on the basis of having documented permanent residence and has supplied her valid permanent residence card. There is no evidence to suggest that her permanent residence has lapsed or that a supervening event has occurred in respect of the applicant. Miss A will be eligible for ILE or ILR. Scenario 2 Mrs B applies and states that she has documented permanent residence, but information indicates that when she applied for her permanent residence document to be renewed her application was refused as she had been absent from the UK for more than 2 years since it was issued. Evidence provided confirmed that Mrs B was out of the UK for 3 consecutive years and this does not therefore constitute a supervening event. Mrs B will be eligible for ILE or ILR. Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Holders of indefinite leave to enter (ILE) or indefinite leave to remain (ILR) held since before the end of the transition period Under condition 2 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that they are a relevant European Economic Area (EEA) citizen, a family member of a relevant EEA citizen or a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, and there is valid evidence of their ILE or ILR, which they have held (other than under Appendix EU) since before the end of the transition period at 11pm GMT on 31 December 2020. Requirements You must be satisfied that, at the date of application, the applicant is either: - a relevant EEA citizen - a family member of a relevant EEA citizen - a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen And: - there is valid evidence of the applicant’s ILE or ILR Relevant evidence If the applicant is a family member of a relevant EEA citizen, see assessing family relationship for the relevant evidence of that. If the applicant is a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, see a family member who has retained the right of residence for the relevant evidence of that. You must be satisfied that there is valid evidence of the applicant’s ILE or ILR which means either: - an eVisa, a valid biometric immigration document (as defined in section 5 of the UK Borders Act 2007, and also referred to as a biometric residence permit), a valid stamp or endorsement in a passport (whether or not the passport has expired), or other valid document issued by the Home Office confirming that the applicant has ILE or ILR in the UK, which they have held since before the end of the transition period at 11pm GMT on 31 December 2020 you are otherwise satisfied from the evidence or information available to you that the applicant has ILE or ILR in the UK or the Islands, which they have held since before the end of the transition period at 11pm GMT on 31 December 2020 And, in either case, the status has not lapsed (by an absence from the UK and Islands for a period of more than 2 consecutive years) or been revoked or invalidated (for example, because a deportation order has been made against the applicant). The applicant must provide confirmation, via self-declaration within the application process, that their ILE or ILR has not lapsed through absence from the UK and Islands for a period of more than 2 consecutive years or been revoked or invalidated, and you must check this against Home Office systems and any documents provided. You must contact the applicant to request evidence of residence in the UK and Islands (or that absence was permitted, as per Article 13A or 13B of the Immigration (Leave to Enter and Remain) Order 2000, as a partner or child accompanying on an overseas posting a member of HM Forces or a person employed on Crown service or as a permanent member of the British Council) since their ILE or ILR was granted, if it was granted more than 2 years ago and either: - there is information on Home Office systems, or in any documentation provided, to suggest that the applicant’s ILE or ILR may have lapsed through absence from the UK and Islands - the applicant’s immigration history shows previous illegal entry or deception Applicants unable to provide evidence of ILE or ILR Where an applicant applies on the basis of having held ILE or ILR (other than under Appendix EU) since before the end of the transition period at 11pm GMT on 31 December 2020, but does not provide documentary evidence of this status, you must check Home Office records to confirm whether the Home Office holds any information confirming the status being claimed by the applicant. Where Home Office records confirm the status, you must accept this as evidence of that status. Applicants who claim to have an historical grant of ILE or ILR that they are unable to provide evidence of and which pre-dates current Home Office records may be able to apply under the Windrush Scheme to have their status checked and documented. See GOV.UK for information on undocumented Commonwealth citizens resident in the UK. If the applicant is unable to provide any evidence of their status, and no such evidence exists in Home Office records, you are unable to grant the application under this condition. Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. Official – sensitive: end of section Where an applicant has declared that their ILE or ILR has not lapsed through absence from the UK and Islands for a period of more than 2 consecutive years or been revoked or invalidated but it is identified during the caseworking process that their status has, in fact, lapsed or been lost, you are unable to grant the application under this condition. Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a joining family member of a relevant sponsor for ILE or ILR under rule EU11A or for 5 years’ LTE or LTR under rule EU14A. Scenario 1 Mr C is the non-EEA citizen spouse of an EEA citizen and has applied on the basis of having previously been granted ILR in the UK, which he has held since before the end of the transition period at 11pm GMT on 31 December 2020. He has provided his expired passport which contains a valid stamp confirming that he was granted ILR before the end of the transition period, along with evidence of his marriage to an EEA citizen. There is no evidence to suggest that he has been absent from the UK for a period of more than 2 consecutive years. Mr C is eligible for ILR. Scenario 2 Dr D, an EEA citizen, claims to have been granted ILR in the UK, which she has held since before the end of the transition period at 11pm GMT on 31 December 2020, but states that she has lost the appropriate document. Home Office records confirm that Dr D was granted ILR before the end of the transition period as claimed and there is no evidence to suggest this has lapsed or been revoked or invalidated. Dr D is eligible for ILR. Related content [Contents] Related external links [Appendix EU to the Immigration Rules] Applicant has completed a continuous qualifying period of 5 years Under condition 3 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that the applicant either: - is a relevant European Economic Area (EEA) citizen - is (or for the relevant period was) a family member of a relevant EEA citizen - is (or for the relevant period was) a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen - a person with a derivative right to reside - a person with a Zambrano right to reside - a person who had a derivative or Zambrano right to reside And, in addition, both the following apply: - the applicant has completed a continuous qualifying period of 5 years in any (or any combination) of the above categories - since then no supervening event has occurred in respect of the applicant Requirements You must be satisfied that, at the date of application, the applicant either: - is a relevant EEA citizen - is (or for the relevant period was) a family member of a relevant EEA citizen - is (or for the relevant period was) a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen - a person with a derivative right to reside - a person with a Zambrano right to reside - a person who had a derivative or Zambrano right to reside And you must be satisfied that, at the date of application, the applicant has completed a continuous qualifying period of 5 years which, unless they are the dependent relative of a specified relevant person of Northern Ireland, began before the specified date in any, or any combination of, those categories. Under rule EU13, the reference in condition 3 in rule EU11 to the applicant completing a continuous qualifying period of 5 years which began before the specified date can include a period during which the applicant was a family member of a qualifying British citizen or a family member who has retained the right of residence by virtue of a relationship with a qualifying British citizen before becoming (as the case may be) a relevant EEA citizen, a family member of a relevant EEA citizen (or thereafter a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen), a person with a derivative right to reside or a person with a Zambrano right to reside. In addition, you must be satisfied that since then no supervening event has occurred in respect of the applicant. Relevant evidence If the applicant is (or, as the case may be, for the relevant period was) a family member of relevant EEA citizen, see assessing family relationship for the relevant evidence of that. If the applicant is (or, as the case may be, for the relevant period was) a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, see a family member who has retained the right of residence for the relevant evidence of that. If the application is made online and the applicant has a National Insurance number and provides this, automated checks will be undertaken with HM Revenue and Customs (HMRC) and Department for Work and Pensions (DWP) as part of the application process. This may provide evidence that the applicant has completed a continuous qualifying period of residence in the UK and Islands (or, where applicable, the UK) of 5 years which began before the specified date. See automated checks for further information. Should these checks not provide sufficient evidence of the continuous qualifying period of residence in the UK and Islands (or, where applicable, the UK), the applicant will be invited by the application process to provide evidence that, when combined with any evidence supplied by the automated HMRC and DWP checks where these are conducted, confirms that they have completed a continuous qualifying period of residence in the UK and Islands (or, where applicable, the UK) of 5 years which began before the specified date. See evidence of residence for examples of evidence of residence an applicant may produce. The applicant must also provide a self-declaration that since then they have not been absent from the UK and Islands for a period of more than 5 consecutive years. Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years' limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a joining family member of a relevant sponsor for ILE or ILR under rule EU11A or for 5 years' LTE or LTR under rule EU14A. Scenario 1 Professor E, a French citizen, has been living in the UK continuously for the past 8 years. Automated checks from HMRC confirm that he has been working in the UK for 7 years. The data runs up to the month before his application, so it is not possible for him to have been absent for more than 5 consecutive years since then, and there is no evidence of any other supervening event in respect of the applicant. Professor E is eligible for ILR. Scenario 2 Mrs F is the Brazilian spouse of an Italian citizen. Relationship and relevant identities are confirmed. She claims that both she and her spouse have been resident in the UK since 2012. Home Office records show her spouse was issued with a document certifying permanent residence in 2017 and automated checks show that Mrs F was employed from 2013-2015. Mrs F provides council tax bills for the period 2015-2018, dated and addressed to both her and her spouse. There is no evidence of a supervening event in respect of the applicant. Mrs F is eligible for ILR. Related content Contents Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 A relevant EEA citizen who has ceased activity Under condition 4 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that: - the applicant is a relevant European Economic Area (EEA) citizen who is a person who has ceased activity - since they did so, no supervening event has occurred Requirements You must be satisfied that, at the date of application, the applicant is a relevant EEA citizen. You must be satisfied that, at the date of application, the applicant is a person who has ceased activity. Further detail on this is set out below. In addition, you must be satisfied that since the applicant became a person who has ceased activity, no supervening event has occurred. Retired You must be satisfied that, at the date of application, the applicant: - has terminated activity as a worker or self-employed person in the UK and either: - reached the age of entitlement to a state pension on terminating that activity - in the case of a worker, ceased working to take early retirement - immediately before that termination was both: - a worker or self-employed person in the UK for at least 12 months - resident in the UK and Islands for a continuous qualifying period of more than 3 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date The conditions above as to length of residence and of employment do not apply where you are satisfied, including by the required evidence of family relationship, that the relevant EEA citizen is the spouse or civil partner of a British citizen. See assessing family relationship for the relevant evidence of that. Relevant evidence Evidence which may be relevant to the requirements above includes: evidence that the applicant was a worker or self-employed person in the UK immediately before they retired - for example, employer’s letter, wage slips, relevant information from HMRC - evidence of the applicant’s retirement - for example, a relevant HMRC form, letter from employer, pension statements - unless the applicant is the spouse or civil partner of a British citizen, evidence of employment in the UK for at least 12 months immediately before retirement - for example, employer’s letter, wage slips, relevant information from HMRC - unless the applicant is the spouse or civil partner or a British citizen, evidence that they were resident in the UK and Islands for a continuous qualifying period of more than 3 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date, immediately before retirement (either from the automated checks with HMRC and DWP or as provided by the applicant: see evidence of residence) - a self-declaration that they have not been absent from the UK and Islands for a period of more than 5 consecutive years since they became a person who has ceased activity Permanent incapacity You must be satisfied that, at the date of application, the applicant has: - stopped being a worker or self-employed person in the UK owing to permanent incapacity to work and either: - having been resident in the UK and Islands for a continuous qualifying period of more than the preceding 2 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - the incapacity having resulted from an accident at work or an occupational disease that entitles the person to a pension payable in full or in part by an institution in the UK The condition above as to length of residence does not apply where you are satisfied, including by the required evidence of family relationship, that the relevant EEA citizen is the spouse or civil partner of a British citizen. See assessing family relationship for the relevant evidence of that. Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence that the applicant was a worker or self-employed person in the UK - for example, employer’s letter, wage slips, relevant information from HMRC - evidence of their permanent incapacity to work - for example, a letter from their hospital consultant - unless the applicant is the spouse or civil partner of a British citizen, evidence that they were resident in the UK and Islands for a continuous qualifying period of more than the preceding 2 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date (either from the automated checks with HMRC and DWP or as provided by the applicant: see evidence of residence) Or evidence that: - the permanent incapacity resulted from an accident at work or an occupational disease - for example, a letter from a hospital consultant - and confirmation, in the form for example of a letter or pension statements, that the accident at work or occupational disease entitles the applicant to a pension payable in full or in part by an institution in the UK - a self-declaration that they have not been absent from the UK and Islands for a period of more than 5 consecutive years since they became a person who has ceased activity Worker or self-employed person who has retained a place of residence You must be satisfied that, at the date of application, the applicant was resident in the UK for a continuous qualifying period of at least 3 years as a worker or self-employed person which, unless they are a specified relevant person of Northern Ireland, began before the specified date, immediately before becoming a worker or self-employed person in another EEA country. Also, they must have retained a place of residence in the UK to which they return, as a rule, at least once a week. Being a ‘worker’ means that there is evidence which satisfies you that the applicant is either: - a worker as defined in regulation 4(1) of the EEA Regulations - a person who is no longer working but who continues to be treated as a worker within the meaning of “qualified person” under regulation 6 Being a ‘self-employed person’ means that there is evidence which satisfies you that the applicant is either: - a self-employed person as defined in regulation 4(1) of the EEA Regulations - a person who is no longer in self-employment but who continues to be treated as a self-employed person within the meaning of “qualified person” under regulation 6 Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence of having resided in the UK for a continuous qualifying period of at least 3 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date (either from the automated checks with HMRC and DWP or as provided by the applicant: see evidence of residence) • evidence of having been a worker or self-employed person in the UK for that period of at least 3 years - for example, employer’s letter, pay slips, relevant information from HMRC • evidence of becoming a worker or self-employed person in another EEA country immediately after leaving the UK. For example, employer’s letter or pay slips • evidence of retaining a place of residence in the UK, for example, utility bills • evidence that the applicant returns to this place of residence, as a rule, at least once a week, for example travel tickets • a self-declaration that they have not been absent from the UK and Islands for a period of more than 5 consecutive years since they became a person who has ceased activity Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a [joining family member of a relevant sponsor](#) for ILE or ILR under rule EU11A or for 5 years’ LTE or LTR under rule EU14A. Scenario 1 Mr G, a 68 year old French citizen, became a retired worker in 2016. Automated checks from HMRC show that he was in employment in the UK for 3 years before retiring, and statements provided confirm he has been in receipt of a pension since 2016. There is no evidence of a supervening event. Mr G is eligible for ILR. Scenario 2 Ms H, a German citizen, has been living in the UK since 2014. She was injured in an industrial accident in the UK and was unable to continue work. A letter from her hospital consultant confirms she is no longer able to work in any capacity and an employer’s letter confirms her pension is as claimed. Automated checks from HMRC confirm her period of work and she has declared that she has not left the UK since. There is no evidence of a supervening event. Ms H is eligible for ILR. Scenario 3 Professor J, a Greek citizen, has applied on the basis of being a worker with a retained place of residence in the UK. She claims that she lived in the UK from 2012- 2016 and has since been working in Austria whilst returning to her house in the UK at least once a week. The automated checks from HMRC show that she was employed in the UK for the period claimed, and she has provided payslips and bank statements evidencing her employment in Austria. Professor J has also provided utility bills for her address in the UK from 2016 to the date of application, and her travel history showing that she returns to the UK every weekend. There is no evidence of a supervening event. Professor J is eligible for ILR. Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Family member of a relevant EEA citizen who is a person who has ceased activity Under condition 5 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that, at the date of application, the requirements below are met. Requirements You must be satisfied that, at the date of application: - the applicant is (or for the relevant period was) a family member of a relevant European Economic Area (EEA) citizen who is a person who has ceased activity - the applicant was such a family member at the point the EEA citizen became a person who has ceased activity Where the date of application is before 1 July 2021, you must also be satisfied the relevant EEA citizen either: - meets the requirements of sub-paragraph (b) of that definition in Annex 1 to Appendix EU – an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under Appendix EU or under its equivalent in the Islands) - would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date, either: - where they are an Irish citizen, they have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where they are a British citizen or a British citizen and an Irish citizen, and if they had made a valid application under Appendix EU before 1 July 2021, they would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU) Where the date of application is on or after 1 July 2021, you must also be satisfied the relevant EEA citizen either: - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen in accordance with sub-paragraphs (a), (c) and (d) of that definition in Annex 1 to Appendix EU who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application Whatever the date of application, the applicant also needs to demonstrate that: - they were resident in the UK and Islands for a continuous qualifying period which, unless they are the dependent relative of a specified relevant person of Northern Ireland, began before the specified date, immediately before the relevant EEA citizen became a person who has ceased activity - since the relevant EEA citizen became a person who has ceased activity, no supervening event has occurred in respect of the applicant Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence that the applicant is (or for the relevant period was) the family member of a relevant EEA citizen - see assessing family relationship for the relevant evidence of that evidence that the relevant EEA citizen is a person who has ceased activity and that the applicant was their family member when they did so - see ceased activity for the relevant evidence of that - evidence that the relevant EEA citizen either: - has been or (where the date of application is before 1 July 2021) is being granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) or (but for the fact, where they are, that they are a British citizen) would have been granted that leave under Appendix EU if they had made a valid application under it before 1 July 2021 - for example, the relevant application reference number where they have applied under the scheme - is a relevant naturalised British citizen - evidence that the applicant was resident in the UK and Islands for a continuous qualifying period which, unless they are the dependent relative of a specified relevant person of Northern Ireland, began before the specified date, immediately before the relevant EEA citizen became a person who has ceased activity - a self-declaration that the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years since the relevant EEA citizen became a person who has ceased activity Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years' limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a joining family member of a relevant sponsor for ILE or ILR under rule EU11A or for 5 years' LTE or LTR under rule EU14A. Scenario 1 Mrs K, a 60 year old Chinese citizen, has applied as the spouse of a Portuguese citizen who ceased activity in 2015. She has provided her marriage certificate and spouse's passport, and documents that show that her spouse was in employment for 3 years before retiring. There is also evidence that the Portuguese spouse has been receiving a pension since 2015. There is no evidence of a supervening event in respect of the applicant. Mrs K is eligible for ILR. Scenario 2 Mr L, a Mexican citizen, has applied at the same time as his wife, a Swedish citizen, who ceased activity in 2016. A marriage certificate has been provided to confirm the relationship and Mr L’s Swedish spouse was previously granted ILR as an EEA citizen who has ceased activity. There is no evidence of a supervening event in respect of the applicant. Mr L is eligible for ILR. Related content Related external links Appendix EU to the Immigration Rules Immigration (European Economic Area) Regulations 2016 Family member of a relevant EEA citizen who has died - Under condition 6 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that, at the date of application, the requirements below are met. Requirements You must be satisfied that, at the date of application: - the applicant is a family member of a relevant European Economic Area (EEA) citizen who has died - the applicant was resident in the UK with the relevant EEA citizen immediately before their death - the relevant EEA citizen was resident in the UK as a worker or self-employed person at the time of their death - the relevant EEA citizen was resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they were a specified relevant person of Northern Ireland, began before the specified date, immediately before dying, or the death was the result of an accident at work or an occupational disease - since the death of the relevant EEA citizen, no supervening event has occurred in respect of the applicant Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence that the applicant was the family member of a relevant EEA citizen before that EEA citizen died - see assessing family relationship for the relevant evidence of that - the death certificate of the relevant EEA citizen or other evidence you are satisfied evidences the death - evidence that the relevant EEA citizen was resident in the UK as a worker or self-employed person at the time of their death - for example, employer’s letter, wage slips, relevant information from HMRC - evidence that the relevant EEA citizen was resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they were a specified relevant person of Northern Ireland, began before the specified date, immediately before their death (see evidence of residence), or the death was the result of an accident at work or an occupational disease (such as a letter from a qualified medical professional, for example a hospital consultant or GP) - evidence that that the applicant was resident in the UK with the relevant EEA citizen when they died • a self-declaration by the applicant that they have not been absent from the UK and Islands for a period of more than 5 consecutive years since the relevant EEA citizen died Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a [joining family member of a relevant sponsor](#) for ILE or ILR under rule EU11A or for 5 years’ LTE or LTR under rule EU14A. Scenario 1 Mrs M is a Sri Lankan citizen, who was married to a Danish citizen. Both were employed together in the UK for 10 years and she has provided evidence to show they had resided together in the UK continuously since they were married 13 years ago. Mr M passed away in 2016. Mrs M has provided a marriage certificate and Mr M’s passport and death certificate. Mrs M has also provided Mr M’s pay slips, which confirm that he was in employment immediately before his death in 2016. There is no evidence of a supervening event. Mrs M is eligible for ILR. Scenario 2 Dr N is a Brazilian citizen who was married to Mr N, a French citizen who had been residing and working in the UK for 6 years. Dr N has provided a death certificate and hospital consultant’s letter confirming Mr N died after contracting an occupational disease. Dr N has also provided a marriage certificate and Mr N’s French ID card. P60s confirm Mr N’s employment as claimed and there is no evidence of a supervening event. Dr N is eligible for ILR. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) [Immigration (European Economic Area) Regulations 2016](#) Child under the age of 21 of a relevant EEA citizen or of their spouse or civil partner Under condition 7 in rule EU11 the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that either: - the applicant is a family member of a relevant European Economic Area (EEA) citizen and is a child under the age of 21 of a relevant EEA citizen - the applicant is a child under the age of 21 of the spouse or civil partner of a relevant EEA citizen, where the marriage was contracted before the specified date or where the person, who is now the spouse or civil partner of the relevant EEA citizen, was the durable partner of the relevant EEA citizen before the specified date and the partnership remained durable at the date And, in addition, where the date of application is before 1 July 2021, the relevant EEA citizen (or the spouse or civil partner) either: - has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under Appendix EU or under its equivalent in the Islands) - is an Irish citizen who, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member (“F”) to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date, either: - where they are an Irish citizen, they have been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - where they are a British citizen or a British citizen and an Irish citizen, and if they had made a valid application under Appendix EU before 1 July 2021, they would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU) Or, in addition, where the date of application is on or after 1 July 2021, the relevant EEA citizen (or the spouse or civil partner) either: - having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (a), (c) and (d) of the relevant definition in Annex 1 to Appendix EU) who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - (where the applicant is the family member ("F") to whom paragraph 9 of Schedule 6 to the EEA Regulations refers and meets the criteria as F in that paragraph) is an EEA citizen in accordance with sub-paragraph (c) of the definition in Annex 1 to Appendix EU, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant person of Northern Ireland and either: - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILR or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a person exempt from immigration control, who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application Relevant evidence Evidence which may be relevant to the requirements above includes evidence that the applicant is the child under the age of 21 of a relevant EEA citizen or of their spouse or civil partner). See [assessing family relationship](#) for the relevant evidence of that. - Where the date of application is before 1 July 2021, it also includes evidence that either: - the relevant EEA citizen (or their spouse or civil partner) has been or is being granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) - if the child’s parent (or their spouse or civil partner) is an Irish citizen who has not made a valid application under Appendix EU, evidence they would have been granted ILE or ILR under paragraph EU2 if they had made such an application before 1 July 2021. For example, their valid passport or national identity card and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - if the relevant EEA citizen is a relevant person of Northern Ireland, either: - where they are an Irish citizen, evidence they have been or are being granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) or would have been granted ILE or ILR under that paragraph, if they had made a valid application under Appendix EU before 1 July 2021 - for example, the reference number for their application under the scheme where they have been granted ILE or ILR under paragraph EU2 of Appendix EU; or their valid Irish passport or national identity card, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - where they are a British citizen or a British citizen and an Irish citizen, they would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid Irish passport or national identity card and/or their valid British passport, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - if the child’s parent (or their spouse or civil partner) is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU), evidence they would, were they not a British citizen, have been granted ILE or ILR under paragraph EU2 if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid passport or national identity card as an EEA citizen, evidence that they are a British citizen and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date Where the date of application is on or after 1 July 2021, it also includes evidence that either: - the relevant EEA citizen (or their spouse or civil partner) has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) - if the child’s parent (or their spouse or civil partner) is an Irish citizen, evidence they would have been granted ILE or ILR under paragraph EU2 of Appendix EU if they had made a valid application under that Appendix before 1 July 2021 - for example, their valid passport or national identity card and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - if the child’s parent (or their spouse or civil partner) is a relevant naturalised British citizen (in accordance with sub-paragraphs (a), (c) and (d) of that definition in Annex 1 to Appendix EU), evidence they would, were they not a British citizen, have been granted ILE or ILR under paragraph EU2 if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid passport or national identity card as an EEA citizen, evidence that they are a British citizen and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - if the relevant EEA citizen is a relevant person of Northern Ireland, either: - where they are an Irish citizen, evidence they have been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) or would have been granted ILE or ILR under that paragraph, if they had made a valid application under Appendix EU before 1 July 2021 - for example, the reference number for their application under the scheme where they have been granted ILE or ILR under paragraph EU2 of Appendix EU; or their valid Irish passport or national identity card, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - where they are a British citizen or a British citizen and an Irish citizen, they would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid Irish passport or national identity card and/or their valid British passport, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11. Otherwise, you must consider their eligibility for 5 years' limited leave to enter (LTE) or limited leave to remain (LTR) under condition 1 in rule EU14. If they do not meet the eligibility conditions in rule EU11 or EU14, you must consider their eligibility as a joining family member of a relevant sponsor for ILE or ILR under rule EU11A or for 5 years' LTE or LTR under rule EU14A. Scenario 1 Miss O, a 12 year old Argentinian citizen, has applied as the daughter of Mrs O, a Portuguese citizen. Miss O has provided her birth certificate which confirms her relationship to Mrs O and Mrs O’s reference number confirming a grant of ILR under the scheme, which has been confirmed by Home Office records. Miss O is eligible for ILR. Scenario 2 Mr P, a 16 year old Ecuadorian citizen, has applied as the son of Ms P, who is in a civil partnership with Ms Q, a Polish citizen. A birth certificate and civil partnership certificate have been produced to confirm both relationships are as claimed, and Ms Q’s passport confirms that she is a Polish citizen. A reference number provided confirms that Ms P has been granted ILR under the scheme. Mr P is eligible for ILR. Related content Related external links Appendix EU to the Immigration Rules Family member who has retained the right of residence An applicant can meet the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) under rule EU11 (condition 1, 2 or 3), or for limited leave to enter (LTE) or limited leave to remain (LTR) under rule EU14 (condition 1), as a family member who has retained the right of residence by virtue of a relationship with a relevant European Economic Area (EEA) citizen. An applicant can meet the eligibility requirements for ILE or ILR under rule EU12 (condition 1, 2 or 3), or for LTE or LTR under rule EU14 (condition 2), as a family member who has retained the right of residence by virtue of a relationship with a qualifying British citizen. An applicant can meet the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) under rule EU11A (condition 1), or for limited leave to enter (LTE) or limited leave to remain (LTR) under rule EU14A (the condition there), as a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor. This section sets out the requirements to be met and the evidence which may be provided by the applicant, who can be a European Economic Area (EEA) citizen or a non-EEA citizen, to satisfy you that, at the date of application, they are a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, with a qualifying British citizen or with a relevant sponsor. You must also be satisfied that since satisfying those requirements, the ‘required continuity of residence’ has been maintained by the applicant. This means that, where the applicant has not completed a continuous qualifying period of 5 years (and does not have valid evidence of their indefinite leave to enter or remain, and has not acquired the right of permanent residence in the UK under regulation 15 of the EEA Regulations, or the right of permanent residence in the Islands through the application there of section 7(1) of the Immigration Act 1988 (as it had effect before it was repealed) or under the Immigration (European Economic Area) Regulations of the Isle of Man), then, since the point at which (where they do so) they began to rely on being in the UK and Islands as a family member who has retained the right of residence and while they continued to do so, one of the events referred to in subparagraph (b)(i) or (b)(ii) in the definition of ‘continuous qualifying period’ in Annex 1 to Appendix EU has not occurred. Evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor) Where the applicant is an EEA citizen or non-EEA citizen without a documented right of permanent residence who relies on being (or for the relevant period on having been) a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen (or with a qualifying British citizen or relevant sponsor), the applicant will need to provide: - proof of the identity and nationality of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) – see other evidence in assessing family relationship You can agree to accept alternative evidence of the identity and nationality of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) where the applicant is unable to obtain or produce the required document due to circumstances beyond their control or to compelling practical or compassionate reasons. For example, in cases where you are satisfied that there has been a permanent breakdown in the relationship between the applicant and the relevant EEA citizen (or qualifying British citizen or relevant sponsor), it may not be possible for the applicant to obtain or produce the required document. You must consider each case on its merits as to whether you are satisfied that the applicant cannot obtain or produce the required document, having made every reasonable effort to do so or having shown why it is not possible for them to do so. For further guidance, see Alternative evidence of identity and nationality or of entitlement to apply from outside the UK. Where the applicant is an EEA citizen or non-EEA citizen without a documented right of permanent residence who relies on having been a family member of a relevant EEA citizen (or of a qualifying British citizen), or a joining family member of a relevant sponsor, before being (or for the relevant period on having been) a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen, a qualifying British citizen or a relevant sponsor, the applicant will also need to provide: - evidence about the residence or status of the relevant EEA citizen (or about the residence of the qualifying British citizen or the residence or status of the relevant sponsor) – see other evidence in assessing family relationship – which satisfies you either that: - the EEA citizen (was a relevant EEA citizen throughout any continuous qualifying period on which the applicant relies as being a family member of a relevant EEA citizen - the EEA citizen (or British citizen) was a relevant sponsor (or a qualifying British citizen) throughout any continuous qualifying period on which the applicant relies as being a joining family member of a relevant sponsor (or a family member of a qualifying British citizen) You must take a flexible and pragmatic approach, particularly where you are satisfied that there has been a permanent breakdown in the relationship between the applicant and the relevant EEA citizen (or qualifying British citizen or relevant sponsor). Each case must be dealt with on its own merits and on a case by case basis, in consultation with your senior caseworker. In consultation with a senior caseworker, you can, where necessary and appropriate, make reasonable enquiries on behalf of the applicant in order to obtain the required evidence on a case by case basis, and in line with the General Data Protection Regulation (GDPR) and other data sharing protocols, where an applicant is having difficulty in proving their eligibility. The relevant EEA citizen (or qualifying British citizen or relevant sponsor) has died Requirements The applicant can apply as a family member who has retained the right of residence where: - they were the family member of a relevant EEA citizen (or qualifying British citizen), or the joining family member of a relevant sponsor, and that person has died - (if they are a non-EEA citizen) they were resident in the UK as the family member of that relevant EEA citizen (or qualifying British citizen), or as the joining family member of that relevant sponsor, for a continuous qualifying period of at least 1 year immediately before their death Relevant evidence In addition to evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor), evidence which may be relevant to the requirements above includes: - the death certificate of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or other evidence which you are satisfied evidences the death - evidence that the applicant was the family member of the relevant EEA citizen (or qualifying British citizen) or a joining family member of the relevant sponsor - see assessing family relationship for the relevant evidence of this - evidence that (if they are a non-EEA citizen) the applicant was resident in the UK as the family member of the relevant EEA citizen (or qualifying British citizen), or as a joining family member of the relevant sponsor, for a continuous qualifying period of at least 1 year immediately before their death A child of a relevant EEA citizen (or qualifying British citizen or relevant sponsor) who has died or ceased to reside in the UK (or of their spouse or civil partner) Requirements The applicant can apply as a family member who has retained the right of residence where they both: are the child of a relevant EEA citizen (or qualifying British citizen or relevant sponsor) who has died or ceased to reside in the UK, or of their spouse or civil partner at that point were attending a general educational course, apprenticeship or vocational training course in the UK immediately before the relevant EEA citizen (or qualifying British citizen or relevant sponsor) died or ceased to reside in the UK, and they continue to do so Relevant evidence In addition to evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor), evidence which may be relevant to the requirements above includes: - evidence of the child’s family relationship to the relevant EEA citizen (or qualifying British citizen or relevant sponsor, or to their spouse or civil partner at the time of their death or at the point they ceased to reside in the UK), and (where applicable) of the spouse or civil partner’s family relationship to the relevant EEA citizen (or qualifying British citizen or relevant sponsor) - see assessing family relationship for the relevant evidence of that - the death certificate of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or other evidence which you are satisfied evidences the death, or evidence that the relevant EEA citizen (or qualifying British citizen or relevant sponsor) has ceased to reside in the UK, for example an employer’s letter for employment outside the UK - evidence that the EEA citizen (or British citizen or relevant sponsor) was a relevant EEA citizen (or qualifying British citizen or relevant sponsor) immediately before their death or before they ceased to reside in the UK - evidence that the applicant was attending a general educational course, apprenticeship or vocational training course in the UK immediately before the relevant EEA citizen (or qualifying British citizen or relevant sponsor) died or ceased to reside in the UK, and that they continue to do so A parent with custody of a child of a relevant EEA citizen or qualifying British citizen (or of their spouse or civil partner) Requirements The applicant can apply as a family member who has retained the right of residence where: - they are the parent with custody of a child who has retained the right of residence because a relevant EEA citizen (or qualifying British citizen) has died or ceased to reside in the UK - the child was attending a general educational course, apprenticeship or vocational training course in the UK immediately before the EEA citizen (or qualifying British citizen) died or ceased to reside in the UK, and the child continues to do so - the child is not a joining family member of a relevant sponsor Custody of a child means that the child normally lives with the applicant or does so part of the time, and includes arrangements agreed informally and those which are subject to a court order for determining who the child shall live with and when. Relevant evidence In addition to [evidence](#) about the relevant EEA citizen (or qualifying British citizen), evidence which may be relevant to the requirements above includes: - evidence that the applicant has custody of the child, such as a court order - evidence of the child’s family relationship to the relevant EEA citizen or qualifying British citizen (or to their spouse or civil partner at the time of their death or at the point they ceased to reside in the UK) - see [assessing family relationship](#) for the relevant evidence of that - where applicable, evidence of the spouse or civil partner’s relationship to the relevant EEA citizen (or qualifying British citizen) - see [assessing family relationship](#) for the relevant evidence of that - the death certificate of the relevant EEA citizen (or qualifying British citizen) or other evidence which you are satisfied evidences the death, or evidence that the relevant EEA citizen (or qualifying British citizen) has ceased to reside in the UK, for example, an employer’s letter for employment outside the UK - evidence that the EEA citizen (or British citizen) was a relevant EEA citizen (or qualifying British citizen) immediately before their death or before they ceased to reside in the UK - evidence that the child was attending a general educational course, apprenticeship or vocational training course in the UK immediately before the relevant EEA citizen (or the qualifying British citizen) died or ceased to reside in the UK and continues to do so The marriage or civil partnership with a relevant EEA citizen (or qualifying British citizen or relevant sponsor) has been terminated Requirements The applicant can apply as a family member who has retained the right of residence where: - they ceased to be a family member of a relevant EEA citizen (or of a qualifying British citizen), or a joining family member of a relevant sponsor, on the termination of the marriage or civil partnership of that relevant EEA citizen (or of that qualifying British citizen or relevant sponsor), regardless of whether, after the initiation of the proceedings for that termination, the relevant EEA citizen ceased to be a relevant EEA citizen (or the qualifying British citizen ceased to be a qualifying British citizen or the relevant sponsor ceased to be a relevant sponsor) - they were resident in the UK at the date of the termination of the marriage or civil partnership And (where the applicant is a non-EEA citizen) one of the following applies, either: - prior to the initiation of the proceedings for the termination of the marriage or civil partnership, the marriage or civil partnership had lasted for at least 3 years, and the parties to the marriage or civil partnership had been resident in the UK for a continuous qualifying period of at least 1 year during its duration - the applicant has custody of a child of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) - the applicant has the right of access to a child of the relevant EEA citizen (or qualifying British citizen or relevant sponsor), where the child is under the age of 18 years and where a court has ordered that such access must take place in the UK - the applicant’s continued right of residence in the UK is warranted by particularly difficult circumstances, such as where they or another family member has been a victim of domestic violence or abuse whilst the marriage or civil partnership was subsisting Relevant evidence In addition to evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor), evidence which may be relevant to the requirements above includes: - the court order terminating the marriage or civil partnership - evidence that the applicant was resident in the UK at the date of the termination Where the applicant is a non-EEA citizen applying on the basis that the marriage or civil partnership of the relevant EEA citizen (or of the qualifying British citizen or relevant sponsor) lasted for at least 3 years before legal proceedings for its termination began, and the parties to the marriage or civil partnership were resident in the UK for a continuous qualifying period of at least one year during its duration, evidence which may be relevant to those requirements also includes: - evidence of the marriage or civil partnership of the relevant EEA citizen (or qualifying British citizen or relevant sponsor), for example a marriage or civil partnership certificate - evidence that prior to the initiation of the legal proceedings for its termination, the marriage or civil partnership had lasted for at least 3 years - evidence that the parties to the marriage or civil partnership were resident in the UK for a continuous qualifying period of at least one year during its duration You also need to be satisfied that the applicant, whether they are an EEA or non-EEA citizen, met the definition of a family member of a relevant EEA citizen (or of a qualifying British citizen), or of a joining family member of a relevant sponsor, for the period of residence, prior to the termination of the marriage or civil partnership, on which they are seeking to rely (such as for the period prior to them meeting the definition of a family member who has retained the right of residence). See assessing family relationship for the relevant evidence of that. Where the applicant is a non-EEA citizen applying on the basis that they have custody of a child of the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or the right of access to a child of the relevant EEA citizen (or qualifying British citizen or relevant sponsor), evidence which may be relevant to those requirements also includes either: - evidence that they have custody of the child, including either: - evidence that the child normally lives with the applicant - evidence that the child lives with the applicant part of the time - evidence of informally agreed arrangements regarding the child’s care - where the child is subject to a court order, evidence of this and the determination as to whom the child should live with and when - evidence that they have the right of access to a child under the age of 18, including: - a court order in respect of that right of access that states that such access must take place in the UK Where the applicant is a non-EEA citizen applying on the basis that their continued right of residence in the UK is warranted by particularly difficult circumstances, such as domestic violence or abuse whilst the marriage or civil partnership was subsisting, you will also need to see relevant information or evidence about this from the applicant. You must take a flexible and pragmatic approach. Each case must be dealt with on its own merits and on a case by case basis, in consultation with your senior caseworker. For further guidance regarding domestic violence or abuse, see the next section. In consultation with a senior caseworker, you can, where necessary and appropriate, make reasonable enquiries on behalf of the applicant on a case by case basis, and in line with the General Data Protection Regulation (GDPR) and other data sharing protocols, where an applicant is having difficulty in proving their eligibility. A relevant family relationship with a relevant EEA citizen (or with a qualifying British citizen or relevant sponsor) has broken down permanently as a result of domestic violence or abuse Requirements The applicant can apply as a family member who has retained the right of residence where both: - they are an EEA or non-EEA citizen who provides evidence that a relevant family relationship with a relevant EEA citizen (or with a qualifying British citizen or relevant sponsor) has broken down permanently as a result of domestic violence or abuse - they were resident in the UK when the relevant family relationship broke down permanently as a result of domestic violence or abuse, and the continued right of residence in the UK of the applicant is warranted where the applicant or another family member has been a victim of domestic violence or abuse before the relevant family relationship broke down permanently ‘Relevant family relationship’ means a family relationship with a relevant EEA citizen (or with a qualifying British citizen or relevant sponsor) such that the applicant is, or (immediately before the relevant family relationship broke down permanently as a result of domestic abuse) was, a family member of a relevant EEA citizen (or of a qualifying British citizen) or a joining family member of a relevant sponsor. For further guidance see assessing family relationship. This means that the applicant can be a victim of domestic violence or abuse or a relevant family member of the victim. Where, following the permanent breakdown of the relevant family relationship as a result of domestic violence or abuse, the applicant remains a family member of a relevant EEA citizen (or of a qualifying British citizen), or a joining family member of a relevant sponsor, they will be deemed to have ceased to be such a family member for the purposes of Appendix EU once the permanent breakdown occurred. They can rely instead from that point on being a family member who has retained the right of residence. This means that the applicant does not need to meet the requirements of Appendix EU as a family member of a relevant EEA citizen (or of a qualifying British citizen), or as a joining family member of a relevant sponsor, from that point on. For example, where the applicant is applying on the basis that their continued right of residence in the UK is warranted where they or another family member have been a victim of domestic violence or abuse before the relevant family relationship broke down permanently, the applicant does not need to provide evidence which satisfies you that they remain dependent on the relevant EEA citizen (or qualifying British citizen or relevant sponsor) or (where relevant) on the spouse or civil partner, if the applicant is either: - a child aged 21 or over of a relevant EEA citizen, qualifying British citizen or relevant sponsor (or of their spouse or civil partner) and was not previously granted limited leave to enter or remain under Appendix EU (or under its equivalent in the Islands) as a child under the age of 21 - the dependent parent of a relevant EEA citizen, qualifying British citizen or relevant sponsor who is aged under 18 Relevant evidence In addition to evidence about the relevant EEA citizen (or qualifying British citizen or relevant sponsor), evidence which may be relevant to the requirements above includes: • evidence that demonstrates that the relevant family relationship broke down permanently as a result of domestic violence or abuse • evidence that the applicant was resident in the UK when the relevant family relationship broke down permanently as a result of domestic violence or abuse You need to see evidence that demonstrates that the relevant family relationship broke down permanently as a result of domestic violence or abuse. You need to be satisfied both that the relevant family relationship has broken down permanently and that this is as a result of domestic violence or abuse. See the examples of relevant evidence below, but this is not exhaustive. You must take a flexible and pragmatic approach. Each case must be dealt with on its own merits and on a case by case basis in consultation with your senior caseworker. For guidance on types of domestic violence or abuse see Victims of domestic violence and abuse. Neither Appendix EU nor any other parts of the Immigration Rules specify any mandatory evidence to be submitted with an application to demonstrate that a relevant family relationship has broken down permanently as a result of domestic violence or abuse. All the evidence must be considered and a conclusion drawn as to whether there is sufficient evidence to demonstrate that, on the balance of probabilities, the relevant family relationship broke down permanently as a result of domestic violence or abuse. Factors to be taken into account when assessing the evidence include: • the length of time since the alleged incident or incidents of domestic violence or abuse and any reasons given for this - for example, the applicant’s family member may have retained their documents or failed to tell them about their immigration status as part of the abuse - some individuals may not have realised that they were experiencing domestic abuse or may not have known how or where to get support • a person may hold pre-settled status before their relationship broke down as a result of domestic violence or abuse, and where they apply later for settled status, the length of time since then may make it difficult for them to obtain certain evidence, for example from support services for victims of domestic violence or abuse which they accessed at the time - you must look at the reasons given for this and take a flexible and pragmatic approach to considering the application • the fact that the applicant and the perpetrator of domestic violence or abuse may still be living at the same address when the application is made may not necessarily be taken as an indicator the relationship has not broken down permanently, as this could be due to a number of reasons - for example, the victim’s lack of knowledge of, or access to safety and support, their fear of losing custody of any children, their fear for their or their children’s safety, a lack of means to support themselves or their children financially, or religious or cultural beliefs or practices • previous immigration history, particularly where there is evidence that the applicant has made a number of attempts to secure leave to remain in the UK on different grounds For guidance on the type of evidence which may be produced and factors which are to be taken into account when considering whether the evidence is sufficient to demonstrate that, on the balance of probabilities, the relevant family relationship broke down permanently as a result of domestic violence or abuse, see the table of evidence for this in Victims of domestic violence and abuse. This is not exhaustive and all the evidence must be considered in the round. In consultation with a senior caseworker, you can, where necessary and appropriate, make reasonable enquiries on behalf of the applicant on a case by case basis, and in line with the General Data Protection Regulation (GDPR) and other data sharing protocols, where an applicant is having difficulty in proving their eligibility. Under section 55 of the Borders, Citizenship and Immigration Act 2009, the Home Office has a duty to have regard to the need to safeguard and promote the welfare of children under the age of 18 who are in the UK. If you have concerns about a child who has applied to the scheme or in respect of whom an application has been made, see Applications in respect of children for further guidance. A spouse, civil partner or durable partner under Appendix EU with pre-settled status under the EU Settlement Scheme (limited leave to enter or remain under Appendix EU) as a family member of a relevant EEA citizen (or of a qualifying British citizen), as a joining family member of a relevant sponsor or as a family member who has retained the right of residence, whose relationship has broken down permanently as a result of domestic violence or abuse, can apply for the Migrant Victims of Domestic Abuse Concession or for permission to settle in the UK permanently under Appendix Victim of Domestic Abuse. A person with indefinite leave to enter or remain under Appendix Victim of Domestic Abuse can apply for settled status under the EU Settlement Scheme (indefinite leave to enter or remain under Appendix EU) once they are eligible to do so on the basis of their continuous residence in the UK. For further information see Appendix Victim of Domestic Abuse. Related content Contents Victims of domestic violence and abuse Related external links Appendix EU to the Immigration Rules Joining family member of a relevant sponsor who has completed a continuous qualifying period of 5 years Under condition 1 in rule EU11A the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that the applicant either: - is (or for the relevant period was) a joining family member of a relevant sponsor - is (or for the relevant period was) a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor And, in addition, all the following apply: - the applicant has completed a continuous qualifying period of 5 years which began after the specified date, in either (or any combination) of the above categories - since then no supervening event has occurred in respect of the applicant Requirements You must be satisfied that, at the date of application and in an application made after the specified date, that the applicant either: - is (or for the relevant period was) a [joining family member of a relevant sponsor](#) - is (or for the relevant period was) a [family member who has retained the right of residence by virtue of a relationship with a relevant sponsor](#) And you must be satisfied that, at the date of application and in an application made after the specified date, the applicant has completed a continuous qualifying period of 5 years which began after the specified date, in either, or any combination of, those categories. In addition, you must be satisfied that since then no [supervening event](#) has occurred in respect of the applicant. Relevant evidence If the applicant is (or, as the case may be, for the relevant period was) a joining family member of a relevant sponsor, see [assessing family relationship](#) for the relevant evidence of that. If the applicant is (or, as the case may be, for the relevant period was) a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor, see [a family member who has retained the right of residence](#) for the relevant evidence of that. The applicant will be invited by the application process to provide evidence that confirms that they have completed a continuous qualifying period of residence in the UK and Islands (or, where applicable, the UK) of 5 years which began after the specified date. See [evidence of residence](#) for examples of evidence of residence an applicant may produce. The applicant must also provide a self-declaration that since then they have not been absent from the UK and Islands for a period of more than 5 consecutive years. Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11A. Otherwise, you must consider their eligibility for 5 years' limited leave to enter (LTE) or limited leave to remain (LTR) under the condition in rule EU14A. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Joining family member of a relevant sponsor who is a person who has ceased activity Under condition 2 in rule EU11A the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that, at the date of application, the requirements below are met. Requirements You must be satisfied that, at the date of application and in an application made after the specified date, all the following requirements are met: - the applicant is (or as the case may be was) a joining family member of a relevant sponsor who is a person who has ceased activity - the applicant was such a joining family member at the point the relevant sponsor became a person who has ceased activity Where the date of application is before 1 July 2021, you must also be satisfied that the relevant sponsor is either: - a European Economic Area (EEA) citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of this Appendix or under its equivalent in the Islands) - would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant person of Northern Ireland in accordance with that definition in Annex 1 to Appendix EU and, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date, either: - where they are an Irish citizen, they have been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) which has not lapsed or been cancelled, revoked or invalidated (or are being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under that paragraph of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application where they are a British citizen or a British citizen and an Irish citizen, and if they had made a valid application under Appendix EU before 1 July 2021, they would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - is a relevant naturalised British citizen (in accordance with sub-paragraphs (b), (c) and (d) of that definition in Annex 1 to Appendix EU) Where the date of application is on or after 1 July 2021, you must also be satisfied that the relevant sponsor is either: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen who, having resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (a), (c) and (d), of that definition in Annex 1 to Appendix EU, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, either: - has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - if they had made a valid application under Appendix EU before 1 July 2021, would have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - an EEA citizen (in accordance with sub-paragraph (d) of that definition in Annex 1 to Appendix EU) who is a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, and who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application Whatever the date of application, the applicant also needs to demonstrate both that: - they were resident in the UK and Islands for a continuous qualifying period which began after the specified date, immediately before the relevant sponsor became a person who has ceased activity - since the relevant sponsor became a person who has ceased activity, no supervening event has occurred in respect of the applicant Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence that the applicant is (or for the relevant period was) the family member of a relevant sponsor - see assessing family relationship for the relevant evidence of that - evidence that the relevant sponsor is a person who has ceased activity and that the applicant was their family member when they did so - see ceased activity for the relevant evidence of that - evidence that the relevant sponsor: - has been or (where the date of application is before 1 July 2021) is being granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) or (but for the fact that, where they are, they are a British citizen) would have been granted that leave under paragraph EU2 if they had made a valid application under Appendix EU before 1 July 2021 - for example, the relevant application reference number where they have applied under the scheme - is a relevant person of Northern Ireland - is a relevant naturalised British citizen - is a person who is exempt from immigration control - evidence that the applicant was resident in the UK and Islands for a continuous qualifying period which began after the specified date, immediately before the relevant sponsor became a person who has ceased activity • a self-declaration that the applicant has not been absent from the UK and Islands for a period of more than 5 consecutive years since the relevant sponsor became a person who has ceased activity Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11A. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under the condition in rule EU14A. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Joining family member of a relevant sponsor who has died Under condition 3 in rule EU11A the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that, at the date of application and in an application made after the specified date, the requirements below are met. Requirements You must be satisfied that, at the date of application and in an application made after the specified date, all the following requirements are met: - the applicant is a joining family member of a relevant sponsor who has died - the applicant was resident in the UK with the relevant sponsor after the specified date and immediately before their death - the relevant sponsor was resident in the UK as a worker or self-employed person at the time of their death - the relevant sponsor was resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they were a specified relevant person of Northern Ireland, began before the specified date, immediately before dying, or the death was the result of an accident at work or an occupational disease - since the death of the relevant sponsor, no supervening event has occurred Relevant evidence Evidence which may be relevant to the requirements above includes: - evidence that the applicant was the joining family member of a relevant sponsor before the relevant sponsor died – see assessing family relationship for the relevant evidence of that - the death certificate of the relevant sponsor or other evidence you are satisfied evidences the death - evidence that the relevant sponsor was resident in the UK as a worker or self-employed person at the time of their death – for example, employer’s letter, wage slips, relevant information from HM Revenue and Customs (HMRC) - evidence that the relevant sponsor was resident in the UK and Islands for a continuous qualifying period of at least 2 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date, immediately before their death (see evidence of residence), or the death was the result of an accident at work or an occupational disease (such as a letter from a qualified medical professional, for example a hospital consultant or GP) - evidence that the applicant was resident in the UK with the relevant sponsor immediately before they died • a self-declaration by the applicant that they have not been absent from the UK and Islands for a period of more than 5 consecutive years since the relevant sponsor died Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11A. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under the condition in rule EU14A. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Joining family member who is a child under the age of 21 years of a relevant sponsor or of their spouse or civil partner Under condition 4 in rule EU11A the applicant meets the eligibility requirements for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) where you are satisfied that either: - the applicant is a joining family member of a relevant sponsor and is a child under the age of 21 of the relevant sponsor, and the relevant sponsor meets the relevant requirements set out below - the applicant is a joining family member of a relevant sponsor and is a child under the age of 21 of the spouse or civil partner of the relevant sponsor, where the marriage was contracted or the civil partnership was formed before the specified date (or the spouse or civil partner was the durable partner of the relevant sponsor before the specified date and the partnership remained durable at the specified date) and the spouse or civil partner has been or is being granted indefinite leave to enter or remain under paragraph EU2 of Appendix EU (as the family member of a relevant European Economic Area (EEA) citizen, who is the relevant sponsor) - the applicant is a joining family member of a relevant sponsor and is a child under the age of 21 of the spouse or civil partner of the relevant sponsor, and the spouse or civil partner meets the requirements of the first sub-paragraph (a), together with either the second sub-paragraph (a) or sub-paragraph (b)(i) or (b)(ii), of the definition of ‘joining family member of a relevant sponsor’ in Annex 1 to Appendix EU, and the spouse or civil partner has been or is being granted indefinite leave to enter or remain under paragraph EU2A of Appendix EU (as a joining family member of the relevant sponsor) Requirements Where the date of application is before 1 July 2021, where the applicant relies on being a joining family member of a relevant sponsor and a child under the age of 21 years of the relevant sponsor, you must be satisfied that, at the date of application and in an application made after the specified date, both: - the applicant is a child under the age of 21 of the relevant sponsor (see assessing family relationship) - the relevant sponsor is: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands) - an Irish citizen who is an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated (or is being granted that leave under that paragraph of Appendix EU or under its equivalent in the Islands), or would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (b), (c) and (d), of that definition in Annex 1 to Appendix EU Where the date of application is on or after 1 July 2021, where the applicant relies on being a joining family member of a relevant sponsor and a child under the age of 21 years of the relevant sponsor, you must be satisfied that, at the date of application, both: - the applicant is a child under the age of 21 of the relevant sponsor (see assessing family relationship) - the relevant sponsor is: - an EEA citizen (in accordance with sub-paragraph (a) of that definition in Annex 1 to Appendix EU) who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated - an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant naturalised British citizen, in accordance with sub-paragraphs (a), (c) and (d), of that definition in Annex 1 to Appendix EU, who, if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is an Irish citizen who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, has been granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands), which has not lapsed or been cancelled, revoked or invalidated; or, if they had made a valid application under Appendix EU before 1 July 2021, would have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a relevant person of Northern Ireland, in accordance with that definition in Annex 1 to Appendix EU, who is a British citizen, or a British citizen and an Irish citizen, who, having been resident in the UK and Islands for a continuous qualifying period which, unless they are a specified relevant person of Northern Ireland, began before the specified date and if they had made a valid application under Appendix EU before 1 July 2021, would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application - a person exempt from immigration control who, having been resident in the UK and Islands for a continuous qualifying period which began before the specified date, would, if they had made a valid application under Appendix EU before 1 July 2021, have been granted ILE or ILR under paragraph EU2 of Appendix EU, which would not have lapsed or been cancelled, revoked or invalidated before the date of application Whatever the date of application, where the applicant relies on being a joining family member of a relevant sponsor and a child under the age of 21 years of the spouse or civil partner of the relevant sponsor, you must be satisfied that, at the date of application and in an application made after the specified date, either: - they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: - meets the requirements of sub-paragraph (a) of the definition of ‘family member of a relevant EEA citizen’ in Annex 1 to Appendix EU, substituting 'relevant sponsor' for each reference in that sub-paragraph to 'relevant EEA citizen' - has been or is being granted ILE or ILR under paragraph EU2 of Appendix EU - they are a child under the age of 21 of the spouse or civil partner of the relevant sponsor (see assessing family relationship) and the spouse or civil partner both: - meets the requirements of the first sub-paragraph (a), together with either the second sub-paragraph (a) or sub-paragraph (b)(i) or (b)(ii), of the definition of 'joining family member of a relevant sponsor' in Annex 1 to Appendix EU - has been or is being granted ILE or ILR under paragraph EU2A of Appendix EU Relevant evidence Evidence which may be relevant to the requirements above includes evidence that the applicant is the child under the age of 21 of a relevant sponsor or of their spouse or civil partner). See assessing family relationship for the relevant evidence of that. It also includes evidence that either: - the child’s parent has been or is being granted ILE or ILR under paragraph EU2 of Appendix EU or (where the parent is a joining family member of the relevant sponsor) under paragraph EU2A of Appendix EU - if the child’s parent (or their spouse or civil partner) is an Irish citizen, evidence that they would have been granted ILE or ILR under paragraph EU2 if they had made a valid application under Appendix EU before 1 July 2021. For example, their valid passport or national identity card as an Irish citizen and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - if the relevant sponsor is a relevant person of Northern Ireland, either: - where they are an Irish citizen, evidence that they have been or (where the date of application is before 1 July 2021) are being granted ILE or ILR under paragraph EU2 of Appendix EU (or under its equivalent in the Islands) or would have been granted that leave under that paragraph, if they had made a valid application under Appendix EU before 1 July 2021 - for example, the reference number for their application under the scheme, or their valid Irish passport or national identity card, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date - where they are a British citizen or a British citizen and an Irish citizen, evidence that they would, but for the fact that they are a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU, if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid Irish passport or national identity card and/or their valid British passport, evidence that they are a relevant person of Northern Ireland (see Family members of the people of Northern Ireland) and evidence of a continuous qualifying period of residence in the UK of 5 years which, unless they are a specified relevant person of Northern Ireland, began before the specified date - if the child’s parent (or their spouse or civil partner) is a relevant naturalised British citizen (in accordance, where the date of application is before 1 July 2021, with sub-paragraphs (b), (c) and (d) - and, where the date of application is on or after 1 July 2021, with sub-paragraphs (a), (c) and (d) - of that definition in Annex 1 to Appendix EU), evidence that they would, but for the fact that they a British citizen, have been granted ILE or ILR under paragraph EU2 of Appendix EU if they had made a valid application under Appendix EU before 1 July 2021 - for example, their valid passport or national identity card as an EEA citizen, evidence that they are a British citizen and evidence of a continuous qualifying period of residence in the UK of 5 years which began before the specified date Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, the applicant is eligible for ILE or ILR. If you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, you must consider their application for ILE or ILR under the other eligibility conditions in rule EU11A. Otherwise, you must consider their eligibility for 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) under the condition in rule EU14A. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Consideration of applications: 5 years’ limited leave to enter (LTE) or limited leave to remain (LTR) Relevant EEA citizens and family members Under rule EU14, an applicant will meet the eligibility requirements for leave to enter (LTE) or leave to remain (LTR) where you are satisfied, including (where applicable) by the required evidence of family relationship, that at the date of application: - the applicant is: - a relevant European Economic Area (EEA) citizen - a family member of a relevant EEA citizen - a family member who has retained the right of residence by virtue of a relationship with a relevant EEA citizen - a person with a derivative right to reside - a person with a Zambrano right to reside - the applicant is not eligible for indefinite leave to enter (ILE) or indefinite leave to remain (ILR) under paragraph EU11 of Appendix EU solely because they have completed a continuous qualifying period of residence of less than 5 years - where the applicant is a family member of a relevant EEA citizen, there has been no supervening event in respect of the relevant EEA citizen Relevant evidence You must be satisfied that the applicant meets the eligibility criteria for ILE or ILR of condition 3 in rule EU11, as set out in this guidance, save that they have not completed a continuous qualifying period of 5 years. Automated checks will be undertaken with HM Revenue and Customs (HMRC) and Department for Work and Pensions (DWP) which may provide evidence that the applicant has completed a continuous qualifying period of residence in the UK of less than 5 years. See automated checks for further information. Should these checks not provide any evidence of residence in the UK, the applicant must be invited to provide evidence that confirms that they have completed a continuous qualifying period of residence in the UK. See consideration of applications: eligibility and see evidence of residence for examples of the forms of evidence that they may provide to do so. Joining family members of relevant sponsors Under rule EU14A, an applicant will meet the eligibility requirements for LTE or LTR as a joining family member of a relevant sponsor where you are satisfied, including by the required evidence of family relationship, that, at the date of application and in an application made after the specified date: - the applicant is either: - a joining family member of a relevant sponsor - a family member who has retained the right of residence by virtue of a relationship with a relevant sponsor - the applicant is not eligible for either: - ILE under paragraph EU11A of Appendix EU, where the application is made outside the UK - ILR under paragraph EU11A of Appendix EU, where the application is made within the UK, solely because they have completed a continuous qualifying period of less than 5 years which began after the specified date - where the applicant is a joining family member of a relevant sponsor, there has been no supervening event in respect of the relevant sponsor Relevant evidence Where the application is made outside the UK, you must be satisfied that the applicant does not meet the eligibility criteria for ILE under rule EU11A of Appendix EU and that the applicant meets the eligibility criteria for LTE under rule EU14A of Appendix EU. Where the application is made within the UK, you must be satisfied that the applicant meets the eligibility criteria for ILR under condition 1 in rule EU11A, as set out in this guidance, save that they have not completed a continuous qualifying period of 5 years which began after the specified date. Where they have not done so and the application is made within the UK, the applicant must be invited to provide evidence that confirms that they have completed a continuous qualifying period of residence in the UK which began after the specified date. See [consideration of applications: eligibility](#) and see [evidence of residence](#) for examples of the forms of evidence that they may provide to do so. Decision If you are satisfied, on the balance of probabilities, that the applicant meets the above requirements, they will be eligible for LTE or LTR. If, however, you are not satisfied, on the balance of probabilities, that the applicant meets the above requirements, the application must be refused. For further information, see [refusals](#) section. --- Official – sensitive: start of section The information on this page has been removed as it is restricted for internal Home Office use. The information on this page has been removed as it is restricted for internal Home Office use. Related content Related external links Appendix EU to the Immigration Rules Consideration of applications: eligibility Where an applicant, who does not fall to be refused on grounds of suitability, needs to provide more information or evidence than the application contains of their eligibility for indefinite leave to enter or remain or limited leave to enter or remain under Appendix EU, you must attempt to contact the applicant under the standard process or (where it applies as set out below) the truncated process. Standard process You must make 3 attempts in total over a minimum of 3 weeks to contact the applicant. The first 2 contacts may be made concurrently by 2 different methods (where the applicant has provided the relevant contact details) – from, ordinarily, telephone call, text, email, letter – and must include the applicant’s preferred method of contact, where this has been specified as part of the application. You must give the applicant a reasonable opportunity in which to provide more information or evidence, after which a third and final attempt must be made, giving the applicant a response time of a further 7 calendar days. You can exceed that number of attempts at contact where, following consultation with your senior caseworker, you are satisfied that there is good reason to do so in the particular circumstances of the case. All attempts at contact must be recorded. If the applicant makes clear that they are unable or unwilling to provide more information or evidence, you must decide the application on the basis of all the information and evidence before you. A ‘reasonable opportunity in which to provide more information or evidence’ means, subject to the next paragraph, 14 calendar days, from the date of the attempted contact (or the date on which you discussed the matter with the applicant), in which to provide the information or evidence specified in your request (or which you discussed with the applicant). Where the attempted contact is by letter sent by first-class post, you may assume delivery on the second business day after the date of postage. You may provide longer than 14 calendar days where, following consultation with your senior caseworker, you are satisfied that there is good reason to do so in the particular circumstances of the case. Truncated process The standard contact process is truncated where the applicant has submitted either: - fraudulent evidence of their eligibility for status under the EU Settlement Scheme (for example in respect of UK residence or family relationship) which is relevant to the decision on their application • a late application with no evidence of their eligibility for status under the scheme and they have no footprint in the UK under the automated checks with HM Revenue & Customs and the Department for Work and Pensions In such cases, you must contact the applicant, by their preferred method of contact (where stated), and give them 7 calendar days in which to provide relevant evidence of their eligibility for status (or to provide compelling practical or compassionate reasons why they need more time in which to do so). Where the second bullet point immediately above applies, you can provide longer than 7 calendar days where, following consultation with your senior caseworker, you are satisfied that there is good reason to do so in the particular circumstances of the case. Where the first bullet point immediately above applies, it does not require that you establish whether there has been material deception in relation to the application (as under rule EU16(a)), and does not apply where the fraudulent evidence is not relevant to the decision on the application because the applicant has also submitted sufficient genuine evidence of their eligibility for status. All cases When contacting the applicant by telephone, you must, if possible, leave a voicemail if the applicant does not respond. Where it is not possible to leave a voicemail, this will not count as a contact and you must make another telephone call or, if this also fails, use another means of contact. Once the final deadline you have given the applicant to provide more information or evidence (or to contact you to discuss this) has passed, you must consider and decide the application on the basis of all the information and evidence before you, including any further information or evidence the applicant has provided. Throughout this process of engagement with the applicant, you may exercise discretion in their favour where appropriate, to minimise administrative burdens. In consultation with a senior caseworker, you can, where necessary and appropriate, make reasonable enquiries on behalf of the applicant on a case by case basis, and in line with the General Data Protection Regulation (GDPR) and other data sharing protocols, where an applicant is having difficulty in proving their eligibility. Related content [Contents](#) Related external links [Appendix EU to the Immigration Rules](#) Consideration under Annex 2 of Appendix EU A valid application made under Appendix EU, and any issue as to whether a person granted limited leave to enter or remain under Appendix EU continues to meet the eligibility requirements for that leave which they met at the date of application (or meets other eligibility requirements for limited leave to enter or remain, or the eligibility requirements for indefinite leave to enter or remain, under Appendix EU), will be decided on the basis of: - the information and evidence provided by the person, including in response to any request by you for further information or evidence - any other information or evidence made available to you (including from other government departments) at the date of decision Requesting further information or evidence and interviewing When deciding whether the person meets the eligibility requirements for indefinite leave to enter or remain or for limited leave to enter or remain, you may: - request that they provide further information or evidence that they meet the requirements for indefinite leave to enter or remain or limited leave to enter or remain - invite them to be interviewed in person, by telephone, by video-telecommunications link or over the internet If the person claims to be eligible for a grant of indefinite to enter or remain or limited leave to enter or remain on the basis of a relationship with another person ("P"), including a qualifying British citizen or a relevant sponsor, you may: - request that P provide information or evidence about their relationship with the person, their residence in the UK or, if P is a qualifying British citizen, their residence in a European Economic Area (EEA) country or Switzerland (as in sub-paragraph (a)(i) of the definition of ‘EEA citizen’ in Annex 1 to Appendix EU) - invite P to be interviewed in person, by telephone, by video-telecommunications link or over the internet Failure to provide information or evidence or attend an interview If the person or P fails within a reasonable timeframe specified in the request to provide the information or evidence that you have requested or, on at least 2 occasions, fails to comply with an invitation to attend an interview in person or with other arrangements to be interviewed, you may draw any factual inferences about whether the person meets the eligibility requirements for indefinite leave to enter or remain or for limited leave to enter or remain as appear appropriate in the circumstances. You may decide, following the drawing of such a factual inference, that the person does not meet the eligibility requirements for indefinite leave to enter or remain or for limited leave to enter or remain. You must not decide that the person does not meet the eligibility requirements for indefinite leave to enter or remain or for limited leave to enter or remain on the sole basis that they or P failed on at least 2 occasions to comply with an invitation to be interviewed. Related content Related external links Appendix EU to the Immigration Rules Refusals There is no basis to refuse a valid application under the scheme beyond the eligibility and suitability conditions set out in Appendix EU, which are consistent with the Withdrawal Agreement. A valid application under Appendix EU which does not meet the requirements for indefinite leave to remain or limited leave to remain will be refused under rule EU6. If you require further information, you must discuss the case with your senior caseworker who may refer to the EEA Citizens’ Rights & Hong Kong Unit for further advice. Related content Contents Related external links Appendix EU to the Immigration Rules Evidence of residence Evidence required to establish residence in the UK Many applicants will have their residence confirmed by automated checks of HM Revenue & Customs (HMRC) and Department for Work and Pensions (DWP) data. However, where those checks indicate that an applicant who does not hold a permanent residence document has a continuous qualifying period of residence in the UK of less than 5 years – or do not indicate that the applicant has been and remains resident in the UK for the purposes of establishing a continuous qualifying period – the applicant will be able to upload documentary evidence to satisfy you that they are or have been resident for a continuous qualifying period and, where appropriate, that they have been so for at least 5 years or that that they are in one of the categories eligible for indefinite leave to enter or remain (ILE or ILR) with a continuous qualifying period of residence in the UK of less than 5 years. Applicants who are relying on periods of residence in the Islands will be able to upload documentary evidence of their residence there. This section provides non-exhaustive lists of the type of documentary evidence which the applicant will be able to provide. The guidance below is not prescriptive or definitive. Some applicants may lack documentary evidence in their own name for various reasons; you must work flexibly with applicants to help them evidence their continuous qualifying period of residence in the UK by the best means available to them. The applicant may submit several types of evidence to cover their claimed continuous qualifying period of residence. For example, a dated and signed letter from an employer confirming a 12 month period of UK-based employment which has been undertaken, and confirmation of the employer’s status, may be submitted as evidence of residence in the relevant 12 month period and bank statements may be submitted as evidence of residence in the subsequent 12 month period. Preferred evidence of residence The documents listed below are preferred evidence because a single document may cover a significant period. Where an applicant submits evidence from this list, a single piece of evidence is likely to be sufficient for the period it covers: - an annual bank statement or an account summary covering a 12 month period, showing payments received or spending in the UK in at least 6 months of that 12 month period - annual business accounts of a self-employed person - a dated and signed letter from an employer, confirming the duration of a period of UK-based employment which has been undertaken, and confirmation of the employer’s status (such as registration with HMRC or Companies House) - this will be considered evidence of residence for the period of that employment • a P60 for a 12 month period (you may request additional evidence to confirm that the person has been resident in the UK for at least 6 months of that period) • a P45 confirming the duration of a period of employment which has ceased - this will be considered evidence of residence for the period of that employment • a dated and signed letter from an accredited organisation in the UK confirming physical attendance at a course and its duration, or confirming enrolment on a course accompanied by dated and signed evidence of completion (such as a qualification certificate) - this will be treated as evidence of residence for the duration of the course • a dated and signed letter from a registered care home confirming the period of residence in the home - this will be treated as evidence of residence for that period • a dated, addressed invoice from an accredited organisation for school, college or university fees for education requiring physical attendance in the UK, which includes the name of the student, and accompanying evidence of payment - this will be treated as evidence of residence for the relevant academic term or terms or year • documentation issued by the student finance body for England, Wales, Scotland or Northern Ireland or the Student Loans Company that shows a UK address, such as an entitlement notification or repayment statement - this will be treated as evidence of residence for the relevant academic term or terms or year • a residential mortgage statement or tenancy agreement, and accompanying evidence of the mortgage or rent being paid (for example, confirmation from the lender or landlord), will be treated as evidence of residence for the period covered by the statement or agreement • a dated, addressed council tax bill will be treated as evidence of residence for the period covered by the bill • evidence of an employer making pension contributions will be treated as evidence of residence for the period covered by the contributions where the employment requires physical presence in the UK Alternative evidence of residence Because the documents listed below cover a shorter period, the applicant may need to submit more of them to evidence that they meet the residence requirement. Where an applicant submits evidence from this list, a single piece of evidence is likely to be sufficient for the period it covers: • a dated bank statement (other than an annual statement, as above) showing payments received or spending in the UK - this will be treated as evidence of residence for the period covered by the bank statement • a dated payslip for a UK-based job will be treated as evidence of residence for the period covered by that payslip • a dated invoice for work you have done in the UK, and accompanying evidence of payment - this will be treated as evidence of residence for the month in which the invoice is dated • a dated, UK-addressed domestic utility bill featuring the applicant’s name will be treated as evidence of residence for the period covered by the bill • a dated, UK-addressed domestic bill or contract for a mobile or fixed line telephone or for a TV or internet service featuring the applicant’s name will be treated as evidence of residence for the period covered by the bill or contract • a dated letter from a UK GP or other healthcare professional confirming the applicant’s attendance at appointments, or a card issued by the healthcare professional confirming those appointments - this will be treated as evidence of residence for the period covered by the appointments (or for the month in which a single appointment occurred) • a dated letter, or benefit claims made to, a UK government department, another UK public body or a UK charity confirming the applicant’s physical interaction with them, for example Job Centre Plus or Citizens’ Advice or a registration card or certificate issued under the Worker Registration Scheme - this will be treated as evidence of residence for the month in which it is dated, unless it explicitly confirms interactions over a longer period • other dated, UK-addressed domestic bills, for example, for insurance, veterinary bills or home services/repairs, featuring the applicant’s name and accompanying evidence of payment will be treated as evidence of residence for the month in which the bill is dated • a passport stamp confirming entry at the UK border - this will be treated as evidence of residence for the month of entry • a used travel ticket confirming previous inbound travel to the UK - this will be treated as evidence of residence for the month of entry Related content Contents Related external links Appendix EU to the Immigration Rules Cancellation, curtailment and revocation of leave to enter or remain Annex 3 to Appendix EU sets out the circumstances in which indefinite leave to enter or remain (ILE or ILR) or limited leave to enter or remain (LTE or LTR) granted under Appendix EU must be cancelled or may be cancelled, curtailed or revoked. Cancellation Under A3.1., a person’s ILE, ILR, LTE or LTR granted under Appendix EU must be cancelled on or before their arrival in the UK where you deem (or an Immigration Officer deems) the person’s presence in the UK is not conducive to the public good because of conduct committed after the specified date. Under A3.1A., a person’s ILE, ILR, LTE or LTR granted under Appendix EU must be cancelled on or before their arrival in the UK where both: - the person is an excluded person, as defined by section 8B(4) of the Immigration Act 1971, because of their conduct committed before the specified date, and the person does not fall within section 8B(5A) or 8B(5B) of that act - you are (or an Immigration Officer is) satisfied that, because of the person’s conduct committed before the specified date, the cancellation is justified on grounds of public policy, public security or public health in accordance with regulation 27 of the Immigration (European Economic Area) Regulations 2016, irrespective of whether the European Economic Area (EEA) Regulations apply to that person (except that in regulation 27 for ‘a right of permanent residence under regulation 15’ read ‘indefinite leave to enter or remain under, or who would be granted indefinite leave to enter or remain if they made a valid application under, Appendix EU to the Immigration Rules’; and for ‘an EEA decision’ read ‘a decision under paragraph A3.1A. of Annex 3 to Appendix EU to the Immigration Rules’) Under A3.1B., a person’s ILE, ILR, LTE or LTR granted under Appendix EU must be cancelled on or before their arrival in the UK where the person is an excluded person, as defined by section 8B(4) of the Immigration Act 1971, because of conduct committed after the specified date, and the person does not fall within section 8B(5A) or 8B(5B) of that act. Under A3.2., a person’s ILE, ILR, LTE or LTR granted under Appendix EU may be cancelled on or before their arrival in the UK where you are (or an Immigration Officer is) satisfied that it is proportionate to cancel that leave where either: - because of the person’s conduct committed before the specified date, the cancellation is justified on grounds of public policy, public security or public health in accordance with regulation 27 of the EEA Regulations, irrespective of whether the EEA Regulations apply to that person (except that in regulation 27 for ‘a right of permanent residence under regulation 15’ read ‘indefinite leave to enter or remain under, or who would be granted indefinite leave to enter or remain if they made a valid application under, Appendix EU to the Immigration Rules’; and for ‘an EEA decision’ read ‘a decision under paragraph A3.2.(a) of Annex 3 to Appendix EU to the Immigration Rules’) - the cancellation is justified on grounds that, in relation to the relevant application under Appendix EU, and whether or not to the applicant’s knowledge, false or misleading information, representations or documents were submitted (including false or misleading information submitted to any person to obtain a document used in support of the application); and the information, representation or documentation was material to the decision to grant the applicant leave to enter or remain under Appendix EU Under A3.3., a person’s LTE or LTR granted under Appendix EU may be cancelled on or before their arrival in the UK where you are (or an Immigration Officer is) satisfied that it is proportionate to cancel that leave where they cease to meet the requirements of Appendix EU. This does not apply to ILE or ILR granted under Appendix EU. Curtailment Under A3.4., a person’s LTE or LTR granted under Appendix EU may be curtailed where you are satisfied that it is proportionate to do so where: - curtailment is justified on grounds that, in relation to the relevant application under Appendix EU, and whether or not to the applicant’s knowledge, false or misleading information, representations or documents were submitted (including false or misleading information submitted to any person to obtain a document used in support of the application); and the information, representation or documentation was material to the decision to grant the applicant leave to enter or remain under Appendix EU - curtailment is justified on grounds that it is more likely than not that, after the specified date, the person has entered, attempted to enter or assisted another person to enter or to attempt to enter, a marriage, civil partnership or durable partnership of convenience - the person ceases to meet, or never met, the requirements of Appendix EU - curtailment is justified on grounds that it is more likely than not that, after the specified date, the person has assisted another person fraudulently to obtain, or to attempt to obtain, entry clearance to, or leave to enter or remain in, the UK This does not apply to ILE or ILR granted under Appendix EU. Revocation The revocation of ILE and ILR is governed by section 76 of the Nationality, Immigration and Asylum Act 2002. There is no legal power to revoke ILE or ILR for any reason beyond those set out in section 76 of the 2002 Act. The relevant provisions of that section are reflected in Annex 3 to Appendix EU for completeness. Under A3.5., a person’s ILE or ILR granted under Appendix EU may be revoked where you are satisfied that it is proportionate to do so where either: - the applicant is liable to deportation, but cannot be deported for legal reasons - the ILE or ILR was obtained by deception Further guidance is available in EU Settlement Scheme: suitability requirements and in Revocation of indefinite leave guidance. Related content EU Settlement Scheme: suitability requirements Revocation of indefinite leave guidance Related external links Appendix EU to the Immigration Rules Section 76 of the Nationality, Immigration and Asylum Act 2002 Right of appeal From 4 April 2024, there is no scope to apply for an administrative review of any decision made on a valid application under Appendix EU. Anyone who makes a valid application under Appendix EU on or after 11pm GMT on 31 January 2020 will have a right of appeal against a decision to refuse their application on eligibility or suitability grounds or to grant pre-settled status where they believe they qualify for settled status. Anyone who made a valid application under Appendix EU before 11pm GMT on 31 January 2020 will have a right of appeal against a decision, made on or after 8 May 2023, to refuse their application on eligibility or suitability grounds or to grant pre-settled status where they believe they qualify for settled status. Where a relevant decision is made on or after 11pm GMT on 31 January 2020 to cancel, curtail or revoke pre-settled or settled status or to make a deportation order in relation to a person with such status, they will have a right of appeal. They may appeal on grounds that the decision: - breaches any right they have under the Withdrawal Agreement, the EEA EFTA separation agreement or the Swiss citizens’ rights agreement - was not in accordance with the legislation under which it was made The paragraphs above summarise the position set out in detail in the Rights of appeal guidance. 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Inquiry into Homelessness in Victoria Ms Jess Pomeroy Organisation Name:Community Housing Industry Association Victoria (CHIA Vic) Your position or role: Policy & Projects SURVEY QUESTIONS Services,Rough sleeping,Housing affordability,Public housing,Indigenous people,Mental health,Family violence,Employment Drag the statements below to reorder them. In order of priority, please rank the themes you believe are most important for this inquiry into homelessness to consider:: What best describes your interest in our Inquiry? (select all that apply) : A peak body Are there any additional themes we should consider? The theme for public housing should be expanded to include community housing as well. Supply of social housing YOUR SUBMISSION Submission: Do you have any additional comments or suggestions?: FILE ATTACHMENTS File1: 5e33c082af967-CHIA Vic submission Homelessness in Victoria Jan 2020.pdf File2: File3: Signature: Jess Pomeroy Grow the supply of affordable housing CHIA Vic recognises that building new social and affordable housing is not a short-term solution. However, a key factor contributing to homelessness in Victoria is the lack of affordable housing for people on low incomes. Policy responses that do not attempt to address the availability of housing will ultimately fail to achieve the objective of ending homelessness. Of the 112,900 clients assisted by Victorian homelessness services in Victoria in 2018-19 only 3 in 10 clients who were homeless were assisted into housing, and a greater proportion of clients in Victoria (58%) needed accommodation compared to the national average (49%). 3 The Anglicare Victoria Rental Affordability Snapshot for 2019 found that only 274 rental properties across the whole of Victoria were suitable for at least one household type living on income support payments without placing them in housing stress. Within metropolitan Melbourne this dropped to 83 properties, or 0.6% of all available rentals. 4 There are two ways to ensure that more housing is affordable to low income households. One is to increase their income through greater income support, which is what the Raise the Rate campaign is advocating for. An increase to Commonwealth Rent Assistance (CRA), or a Victorian supplement to CRA would also assist in raising the income levels of our most vulnerable citizens. The other response is to increase the supply of affordable housing, by funding the creation of more social housing. In 2018-19 Victoria spent the least amount per capita on social housing, $92.02 per Victorian. This is just over half of the national average ($159.10 per person) 5 . We also have the lowest level of social housing across Australia, 3.2% of our housing stock compared to 4.6% nationally 6 . However, Victoria's population is growing faster than any other jurisdiction, with an average increase of 125,000 people per year forecasted to grow the population to 11.2 million people by 2056. 7 Action is urgently needed to grow the supply of social housing in Victoria, not only to catch up with the rest of the nation but to keep pace with our rapid population growth. Recognising that each year we do nothing we are making the problem worse, CHIA Vic and the other housing and homelessness peaks in Victoria have been calling on Government for several years now to commit to a supply target and grow the supply of social housing Targets are more than symbolic. They provide focus and establish a platform for review and accountability. CHIA Vic suggests that the right target is to match the national average of social 3 Australian Institute of Health and Welfare (2019) Specialist homelessness services 2018–19: Victoria fact sheet, Australian Institute of Health and Welfare, Canberra, AIHW Specialist homeless services annual report 2018-19 https://anglicareras.files.wordpress.com/2019/04/victoria.pdf 4 Anglicare Victoria (2019) Rental Affordability Snapshot, Anglicare, 5 Productivity Commission (2020) Report on Government Services, Housing data tables, 6 Australian Institute of Health and Welfare. (2019). Housing assistance in Australia 2019. https://www.aihw.gov.au/reports/housing-assistance/housing-assistance-in-australia-2019 https://www.pc.gov.au/research/ongoing/report-on-government-services/2020/housing-andhomelessness/housing#downloads 7 Department of Environment, Land, Water and Planning (2019) Victoria in Future (2019) – Population Projections 2016 to 2056, Melbourne, https://www.planning.vic.gov.au/land-use-and-populationresearch/victoria-in-future housing of 4.5% in 10 years. Based on research undertaken by CHIA Vic 8 this means we need to deliver approximately 60,000 community and public housing dwellings within the next 10 years and at least 5,000 of these need to be designated for Aboriginal people in line with the Aboriginal Housing and Homelessness Framework. While this figure is daunting we believe that it is possible. There are many overseas and local examples where community housing sectors have successfully geared up to deliver large growth programs in partnership with Government. The Social Housing Growth Fund initiative launched as part of Homes for Victorians is a good start but will not be enough to meet these targets. Government needs to commit significant funds to meet these targets, and CHIA Vic strongly encourages them to consider borrowing to fund this investment. Investment in housing delivers a range of benefits over time including: * Greater social inclusion through the creation of safe and healthy communities * Increased economic participation through housing stability and access to employment opportunities in the labour market * Generation of strong financial returns in the form of rent and capital gains. 9 The Victorian government has committed to increasing the level of state net indebtedness in order to grow the economy and ultimately benefit all Victorians through a higher standard of living. Quality, affordable housing will provide the platform for an improved standard of living for the most vulnerable low income households. At a time of great shortages of affordable housing in the state, there could surely be no better candidate for a portion of the state's additional indebtedness than new social housing, especially as the public housing stock — valued at $26b — is debt free. Given the significant number of properties required to meet demand, growing the supply of social housing needs to be a whole of government approach. There are a range of departments involved in planning and funding social and affordable housing, many of whom are already doing work in this space. However a solution to the homelessness crisis requires all of them to work together in an integrated and coordinated response. Increasing the funding for supports Homelessness supports are an essential part of the solution to homelessness. Not only do they assist homeless people to find housing, if brought online before someone becomes homeless support workers can work with clients to ensure that they are able to sustain their tenancies. The cheapest and most effective response is to prevent someone from becoming homeless in the first place. However, due to insufficient funding and a lack of coordination the current housing and homelessness system in Victoria often does not respond until someone is homeless or on the verge of homelessness. This is not acceptable. 8 CHIA Vic (2016) Quantifying the shortfall of Social and Affordable Housing, Melbourne, https://chiavic.com.au/wp-content/uploads/2017/08/CHFV-Housing-Needs-Estimates.pdf 9 Infrastructure Victoria (2016) Victoria's 30-year Infrastructure Strategy, Melbourne, https://www.infrastructurevictoria.com.au/wp-content/uploads/2019/03/IV 30 Year Strategy WEB V2.pdf We need system reform to create alignment between housing and supports, ensuring tenants can access the supports they need to stay housed. This includes not just tenancy support services, such as Tenancy Plus, but also mental health, alcohol and other drugs, and other allied support services. We need a system where a range of supports can 'wrap around' a household at risk of homelessness, acting to stabilise the tenancy and address the issues that caused it to become at risk in the first place. When adopted early enough this will act to reduce the number of households falling into homelessness in the first place. Not only do we need alignment between housing and supports, we also need a significant increase in funding for support agencies to ensure clients get support when they need it and for as long as they need it. Increasing investment in preventative measures will have the added benefit of driving savings in health, justice, education and employment budgets. The most effective approach to providing preventative supports as described above is outcomebased and includes case-management that is culturally relevant, individualised, strength based, and person-centred. There are a range of individual programs doing excellent work of this nature with their clients but they are not available everywhere. Similarly there are good reform initiatives being pursued under Victoria's Homelessness and rough sleeping action plan, but they are not available to everyone who needs them. With an average of 105 requests for assistance turned away each day 10 by specialist homeless services across Victoria, and homelessness workers reporting that they often spend their time simply trying to find housing rather than helping clients address the underlying issues that led to being homeless it is clear that any effective response to the homelessness crisis in Victoria is going to require a concerted, coordinated effort across multiple sectors as well as government, and a significant increase in funding for supports. Providing supportive housing for high-need cohorts Making wrap around supports available to anyone who needs them will assist the majority of households to sustain their tenancies. However there is a small cohort with multiple and complex needs that will require permanent support to sustain their housing. Historically, many vulnerable individuals requiring this level of support would have been housed in institutions which have been closed due to inadequate quality of care, and which have not been adequately replaced. Permanent supportive housing in Australia has tended to focus on the most vulnerable chronically homeless in the community. This includes people with long-term or multiple episodes of homelessness, as well as those with disabilities, mental illness or substance misuse disorders. 11 Supportive housing models can be provided either in a single location with supports on-site (e.g. a Common Ground type of set up) or at scattered sites with outreach support. 12 10 AIHW (2019) Specialist homelessness services 2018–19: Victoria 12 Council to Homeless Persons (2018) Housing First, Melbourne, http://chp.org.au/wpcontent/uploads/2018/06/FINAL-180606-Housing-First-2018-6-June.pdf 11 Parsell, C et al (2015) Brisbane Common Ground Evaluation: Final Report, ISSR Research Report, Brisbane, https://issr.uq.edu.au/files/4003/BrisbaneCommonGroundFinalReport.pdf For those tenants unable to sustain their tenancies without a significant level of on-site support, models such as Common Ground provide an effective housing response. They build in the supports and structure onsite that tenants may need to address the causes of a person's experience of homelessness and to reduce the likelihood of a tenancy failing. The key principles underpinning Common Ground are: * stable and affordable housing; * safety; * accessible and voluntary support services; and * tenant independence. By removing barriers to supports, allowing clients to access supports when they want them, and creating a safe and secure home environment for residents through a 24 hour concierge and security systems these programs create an environment where clients with complex needs can find stability and begin to make life improvements in a range of areas. Common Ground and similar single-site supportive housing programs have been found to be very effective in sustaining housing for people with complex needs and a history of homelessness .13,14 Furthermore, by reducing service use of a range of state-funded services, these programs can generate significant cost offsets across state government. 15 Even in an environment where sufficient funding for wrap around support services is available there will remain a small cohort of people who require housing with onsite support and security, who are unable to sustain their tenancies without this framework. Victorian examples of the Common Ground approach include Elizabeth St Common Ground, operated by Launch Housing, 16 and the Queen Street Rooming House Plus Program operated by Community Housing Limited in partnership with Sacred Heart 17 . A culturally responsive approach to Aboriginal housing and homelessness In line with the principle of self-determination CHIA Vic is committed to supporting the Aboriginal Housing and Homelessness Framework. The Framework was funded by the Victorian Government and developed by Aboriginal Housing Victoria in partnership with the Aboriginal community in Victoria between 2018-2019. It will be launched in early 2020. The work that informed the Framework identified that the Victorian Aboriginal community is fast growing, experiencing complex historical disadvantage, and has the highest and fastest growing rate of people accessing specialist homelessness services in Australia. 13 Parsell, C et al (2015) 15 Parsell et al (2015) p.148 14 Launch Housing (2015) Elizabeth Street Common Ground 5th Anniversary, Melbourne https://www.launchhousing.org.au/site/wp-content/uploads/2016/12/LH ESCG booklet 04.pdf 16https://www.launchhousing.org.au/service/elizabeth-street-common-ground/ 17 https://www.sacredheartmission.org/seek-help/housing-support/rooming-house see also https://www.launchhousing.org.au/site/wp-content/uploads/2016/12/LH ESCG booklet 04.pdf Safe secure housing is the foundation of any solution to Aboriginal homelessness, with all other investments likely to be ineffective without it. The overarching vision of the Framework is for every Aboriginal person to have a home. Growing the supply of housing for the Aboriginal community is essential. The fast-growing Aboriginal population will drive demand for an additional 27,000 dwellings by 2036. Of these at least 5,000 must be social housing units, and these figures will merely allow Victoria to maintain the status quo. The Framework emphasises that current homelessness cannot be seen in isolation from historical government policy. Intergenerational dispossession from land and culture and the removal of children have resulted in the very high level of disadvantage now experienced by Aboriginal Victorians. In response the Framework proposes a target of a 10% reduction in Aboriginal homelessness, compounding each year for 10 years. The Frameworks sets out a number of principles, including those listed below, that relate directly to addressing Aboriginal homelessness in Victoria. We believe that these should be incorporated into any response to Victorian homelessness: * A housing and homelessness safety net that provides Aboriginal clients with dignity, respect and quality of life; * A housing and homelessness system that is accountable to the Aboriginal community through transparent, disaggregated public reporting of outcomes for people who seek assistance; * An easily accessible housing and homelessness system which is responsive to Aboriginal housing needs and understands their connection to land, culture and family networks; * A system that uses housing as a platform for other services, building on individuals' community strengths to deliver people-centred outcomes that break the cycle of disadvantage; and * A system that builds the capacity of Aboriginal Community Controlled Organisations to upskill, create critical mass for development and engage in productive partnerships with the mainstream. A culturally responsive homelessness system would need to create clear entry points for Aboriginal people and provide tailored support for those at high risk. Whether accessing services through an Aboriginal Community Controlled Organisation or a mainstream organisation Aboriginal Victorians should be able to easily access culturally safe and appropriate support as and when they need it. Recommendations Growth * Set a target for social housing growth in Victoria, ideally at least 6,000 dwellings per year which should include 500 dwellings each year specifically for Aboriginal people * Commit to funding social housing, through borrowing if required * Identify whole of government opportunities to leverage funding, such as: o working with the planning system o providing government land for social housing developments o leveraging all major infrastructure developments o building support within key government departments such as the Valuer General and related entities such as Development Victoria Supports * Commit to reforming the support system to ensure better integration and coordination between housing and support, and between support agencies working on different issues * Increase the funding available for tenancy-related supports to ensure clients can access support when it is needed, and for as long as is required Supportive housing * Assess the level of need for permanent supportive housing across Victoria * Fund the development and delivery of supportive housing programs as required Meeting the needs of Aboriginal people * Create clear entry points for all Aboriginal people experiencing or at risk of homelessness through a networked and culturally safe mainstream and a capable and resourced Aboriginal Community Controlled sector * Provide better access to affordable and social housing including funding the development of 5000 additional social housing units for Aboriginal people by 2036 * Set a target of reducing Aboriginal homelessness by 10% a year, compounding each year * Support the development of culturally safe mainstream homelessness and housing sectors * Support the development of strong and capable Aboriginal Community Controlled Organisations that deliver housing and homelessness services alongside access to broader services that support sustained tenancies and pathways to improved life outcomes. * Foster strong partnerships between mainstream and Aboriginal Community Controlled Organisations * Build a housing and homeless system based on respect and self-determination for Aboriginal people.	<urn:uuid:3bc05d49-3d4b-46f0-980b-c49c17ee69cc>	CC-MAIN-2022-27	https://parliament.vic.gov.au/images/stories/committees/SCLSI/Inquiry_into_Homelessness_in_Victoria/Submissions/S208_-_CHIA_Vic_Redacted.pdf	2022-06-30T00:50:36+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-27/subset=warc/part-00033-48f675b2-7fd4-43af-adb3-2a4ea7f82193.c000.gz.parquet	492,578,216	3,553	eng_Latn	eng_Latn	0.99607	eng_Latn	0.997292	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 960, 4568, 7802, 11223, 14106, 16983, 18715 ]
PARÓISTE NA DROMODA- PARISH NEWSLETTER – 19 th March 2017 Third Week of Lent Parish Priest: Fr. Gerard Finucane www.dromodparish.ie Contact: 066-9474703 087-0554874 Email: [email protected] MASS INTENTIONS FROM THE 19 th March - 26 th March 2017 th Sunday the 19 March +9.30am Mass in St Finian's for the repose of the soul of Michael Joe Cronin, Murreigh. Fr Gerard will be away for the next two weeks. Fr Pat Ahern will be covering masses at the weekend. For emergencies please call Fr Martin Sheehan on (066)9475111 or (087)9192414. Monday 20 th March 10.00am Mass in Oratory for the repose of the soul of Eamon Walsh, Waterville. 11.00am Mass in St Finian's: Funeral Mass for John 'Seano' O Shea, Tullig. Tuesday, 21 st March No Mass Wednesday, 22 nd March No Mass Thursday 23 rd March No Mass Friday, 24 th March No Mass Saturday 25 th March 7.30pm Mass in Cillin Liath for the repose of the soul of Maureen McLaughlin, Gortaglea. Sunday the 26 th March +9.30am Mass in St Finian's for the deceased members of the Curran family, Kenneigh. MINISTRY ROTA Altar Servers next weekend: Cillin Liath: Rebecca O Sullivan, Kelly O Sullivan, Corina O Sullivan St Finian's: Aoife Cronin, Aoife Dwyer, Emily O Sullivan. Lectors (Readers) for next weekend: Cillin Liath: 7.30pm: Michael Ryan. St Finian's: 9.30am: Curran family. Eucharistic Ministers next weekend: Cillin Liath: Richard Maher, Eilish Farley, Angela Hallissey. St Finian's: Nuala O Sullivan, Breda Fenton, Anne McCarthy. Our Lady of the Valley Church Cleaners Rota for March. Helen O Sullivan, Peggy O Shea. St Finian's Church Cleaners Rota for March Mary Clifford, Collette O Sullivan, Joan O Shea. SAFEGUARDING CHILDREN If you have a child protection concern or wish to report an allegation, please contact one of the following: Dromod parish representative for Safeguarding Children on (087)3853245 or Designated Safeguarding Children Officer for the Diocese of Kerry on (087)6362780 LENT For Lenten Talks during Lent in the diocese please see dioceseofkerry.ie Join Trocaire's campaign by taking a TROCAIRE BOX this weekend. PARISH WEBSITE Parish webpage can be opened at dromodparish.ie NOTICES CHARITY CYCLE-A cycle will take place on Sunday 19th March in memory of John O Shea, starting and finishing in Dromod. There will be 2 distances, 45k and 70k. All money raised will go to the Charity" The Irish Pilgrimage Trust Group 135" who take children with special needs to Lourdes at Easter. LENTEN EVENT: From Darkness to Light: Healing on Life's Journey by Dr. Anne Francis in the Nun's Chapel in the O'Connell Memorial Church on Thursday 30th March @8pm. All are welcome. REFLECTION The Samaritan woman Jesus meets is all too aware of what the Jews think of her. She is nervous when approached by Jesus at the well. But he sees beyond the label to the person, the woman with a life story. He engages her in conversation, listens to her, wins her over. Jesus could tell the woman everything about her life, and he knows each one of us just as intimately. He knows our past and all our faults, our 'cracks.' That is why he is able to speak to us, if we resolve to try and listen.	<urn:uuid:4084196c-6a25-4d76-a110-0aec90f80122>	CC-MAIN-2023-23	https://dromodparish.ie/wp-content/uploads/2017/03/PARISH-Newsletter-19-03-17.pdf	2023-06-11T01:16:37+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-23/subset=warc/part-00234-ffa3bf93-6ba1-4a27-adea-b0baae3b4389.c000.gz.parquet	246,912,312	901	eng_Latn	eng_Latn	0.98802	eng_Latn	0.98802	[ "eng_Latn" ]	false	rolmOCR	[ 3238 ]
Rhode Island Department of Environmental Management Office of Boat Registration and Licensing rd Providence, Rhode Island 02908-5767 235 Promenade Street, 3 Floor, Room 360 Taxation Certification Requirements A state law, enacted in 2004, requires everyone applying for any license from the state to first certify that they have filed all required state tax returns and paid all taxes due to the State, or entered into a written installment agreement with the Tax Administrator to pay delinquent state taxes. Accordingly, all applicants for new or renewed commercial fishing licenses must first complete one of the following two requirements: a) Sign a Taxation Certification, certifying compliance with all state tax obligations as noted above; the form must also include the applicant's social security number or FEIN, or b) Furnish a Letter of Good Standing from the Tax Administrator. (401)574-8756. The Taxation Certification form is available from DEM; it may be completed at the counter while applying for a license or may be filled out online and submitted as part of the online renewal process. Letters of Good Standing must be obtained from the RI Division of Taxation, Collections Division, One Capitol Hill, Providence, RI 02908 (401) 574-8756. DEM will not issue any new or renewed license until the applicant has submitted a properly completed Taxpayer Affidavit or a Letter of Good Standing. Any questions regarding the new tax law should be directed to the RI Division of Taxation at 401-574-8941. Telephone (401) 222-6647 \| www.dem.ri.gov \| Rhode Island Relay 711 Rhode Island Department of Environmental Management Office of Boat Registration and Licensing rd Providence, Rhode Island 02908-5767 235 Promenade Street, 3 Floor, Room 360 Taxpayer Certification You are required to furnish your Social Security # or FEIN pursuant to Chapter 76 of Title 5 and Chapter 3 of Title 31 of the RI General Laws, as amended. Any person applying for any license or permit to conduct a business or occupation within Rhode Island or any person renewing a motor vehicle operator's license or motor vehicle registration within Rhode Island must have filed all required state tax returns and paid all taxes due the state or must have entered into a written installment agreement to pay delinquent state taxes that is satisfactory to the Tax Administrator. Failure to provide the Department with your Social Security # or FEIN will result in you having to obtain a Letter of Good Standing from the RI Division of Taxation, One Capitol Hill Providence, RI 02908 PRIOR to the issuance or renewal of your license. If you have any questions regarding your tax status, please contact Taxation directly at 401-574-8941. I hereby declare, under penalty of perjury, that I have filed all required state tax returns and have either paid all taxes due the state or have entered into a writteninstallment agreement with the Rhode Island Division of Taxation. Applicant's Signature ____________________________ Date ________________ Printed Name ____________________________________ Social Security # or FEIN ________________________ Marine License # _________________________________ Telephone (401) 222-6647 \| www.dem.ri.gov \| Rhode Island Relay 711	<urn:uuid:046c48b4-5cbf-43ff-9c9c-b90413408817>	CC-MAIN-2024-10	https://dem.ri.gov/sites/g/files/xkgbur861/files/2023-12/taxpayer.pdf	2024-02-28T15:15:29+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-10/subset=warc/part-00293-d9675c6d-5c8d-45bb-9c98-c56e42022a4d.c000.gz.parquet	193,404,242	684	eng_Latn	eng_Latn	0.991095	eng_Latn	0.993746	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1595, 3272 ]
CAMP ARROWHEAD Stop by to meet some of our staff and take a tour of Camp Arrowhead and the YMCA. SAMPLE DAY & OPEN HOUSE Saturday, May 7, 2022 10:00am—12:00pm A great way for your child to find out more about our camp. There will be a sampling of activities the campers will experience each day along with games and lots of fun! Our counselors will be there to answer any questions they may have about camp. CAMP SCHEDULE (SAMPLE SCHEDULE) \| Time \| Activity \| \|------------\|-----------------------------------\| \| 9:00 AM \| Tribe Activity \| \| 9:30AM \| POW WOW \| \| 10:00AM \| Morning Swim \| \| 12:00PM \| Lunch \| \| 12:30PM \| D.E.A.R. Drop Everything And Read \| \| 1:00PM \| Activity #1 \| \| 1:45PM \| Activity #2 \| \| 2:30PM \| Activity #3 \| \| 3:15PM \| Activity #4 \| \| 4:00PM \| Dismissal \| 2022 SUMMER CAMP WEEKS, THEMES AND FIELD TRIPS 1. May 23—May 27 #BESTSUMMEREVER COOK OUT & KONA ICE 2. May 31—JUNE 3 DISCO DAZE BOWLING* 3. JUNE 6—JUNE 10 AMAZING RACE GET AIR* 4. JUNE 13—JUNE 17 FEAR FACTOR DR. INSECTA IS BACK!!!! 5. JUNE 20—JUNE 24 O-H-I-O CINCINNATI REDS* 6. JUNE 27—JULY 1 GOIN’ GREEN CINCINNATI OBSERVATORY 8. JULY 11—JULY 15 DOWN ON THE FARM NEIDERMAN FARMS* 9. JULY 18—JULY 22 SAFARI ADVENTURE CINCINNATI ZOO* 10. JULY 25—JULY 29 CAMP ARROWHEAD TALENT TALENT SHOW 11. AUG 1—AUG 5 WALK THE RED CARPET MOVIE* 12. AUG 8—AUG 12 HAWAIIAN HULLABALOO TBD *Offsite Field Trips CAMP ARROWHEAD Grades 1-7 Designed to provide campers with a variety of experiences in a well-supervised camp setting. Each week will include a special theme. Camp activities include; archery, crafts, group games, climbing wall, science and nature, swimming, sports, Drop Everything And Read (D.E.A.R) Program and much more! Weekly in-house AND outside field trips are included in the cost of camp. Counselor In Training (C.I.T) Grades 8-10 Teens looking to gain leadership experience working with adults and children should consider this program. The Counselor In Training (C.I.T.) will have an active role with the camp counselors in assisting them during the activity periods. They will also have the opportunity to choose activities independent of the day campers. The C.I.T. program will enhance their self-esteem, creativity, communication skills, decision making and motivation. The program has been designed to be a positive learning experience for everyone involved. CAMP FEES DAY CAMP 9:00AM –4:00PM MEMBER FEE: $153/week NON-MEMBER FEE: $196/week EXTENDED DAY CAMP 7:00AM –6:00PM MEMBER FEE: $190/week NON-MEMBER FEE: $235/week C.I.T 7:00AM –6:00PM MEMBER FEE: $122/week NON-MEMBER FEE: $155/week First payment includes $50 non-refundable, non-transferable deposit for each week pre-registered. Remaining weekly tuition will be charged to your credit card each Friday for the upcoming week. A credit card is required at registration for future payments if not paid in full. Registration is required the Wednesday prior to the week attending or a $35 late fee is applied. Registrations are accepted at the Lakota Family YMCA Front Desk or your Lakota YMCA Online Portal. Questions contact us at 513-779-3917 SUMMER 2022 Lakota Family YMCA CAMP ARROWHEAD 6703 YANKEE ROAD LIBERTY TWP, OH 45044 513-779-3917 WWW.LAKOTAYMCA.COM	b2c727fa-97d7-4a73-9888-fe7077f1adf8	CC-MAIN-2022-27	https://lakotaymca.com/uploads/editor/files/Child%20Care/Camp%20Arrowhead/2022/Camp%20Arrowhead%202022%20Brochure.pdf	2022-07-01T11:44:06+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-27/subset=warc/part-00028-48f675b2-7fd4-43af-adb3-2a4ea7f82193.c000.gz.parquet	385,734,600	1,051	eng_Latn	eng_Latn	0.974388	eng_Latn	0.991339	[ "eng_Latn", "eng_Latn" ]	true	docling	[ 1734, 3588 ]
VERMONT ECONOMIC DEVELOPMENT AUTHORITY AUDIT COMMITTEE MEETING Minutes June 30, 2023 A meeting of the Vermont Economic Development Authority's Audit Committee originated at the office of the Vermont Economic Development Authority, Montpelier, Vermont on June 30, 2023 beginning at 8:29 a.m. Members of the Committee present via video conferencing: R. Shippee, Chair; K. Hale; S. Voigt and T. Gallagher. Staff present in VEDA's office: P. Samson, Chief Lending Officer and A. Wright, Executive Assistant and Office Manager. Staff present via video conferencing: T. Richardson, Chief Financial Officer; R. Grzankowski, Chief Operations Officer and H. Hook, Senior Accountant. Joining via video conferencing from BerryDunn: R. Smalley, Principal; K. Balukas, Senior Manager and S. Edie, Senior Auditor. Approval of December 1, 2022 Minutes On a motion by T. Gallagher, seconded by S. Voigt, the Minutes of December 1, 2022 were approved by those Members of the Committee present by a vote of 3 to 0 with the Chair abstaining. BerryDunn Presentation R. Smalley. K. Balukas and S. Edie of BerryDunn presented their 2023 Pre-Audit Communications. K. Balukas defined the communication responsibilities of the management and auditors as well as the required supplemental information for the Vermont Small Business Development Corporation and Vermont 504 Corporation. Next, K. Balukas noted the uniform guidance audit for federal grants over $750,000. S. Edie provided an overview of planned significant audit areas and risks that will be performed on five major programs. The timing of the audit procedures and required communication letter were discussed. Audit Committee Minutes – June 30, 2023 Next, K. Balukas reviewed the emerging issues, including GASB 96 which is applicable for the audited fiscal year. GASB 101, which will be effective for FY2024, was briefly discussed. R. Smalley noted that with five major programs being audited this year it was good to have the previous year of experience with VEDA. The engagement letter prepared by BerryDunn will be shared with R. Shippee for her approval. There being no other business to properly come before the Committee, on a motion by S. Voigt, seconded by K. Hale, the meeting adjourned at 8:51 a.m. ATTEST: Audit Committee By:________________________________________ Thaddeus G. Richardson, Chief Financial Officer	<urn:uuid:b30b7966-19f5-4909-a9e8-a827028f7494>	CC-MAIN-2024-30	https://www.veda.org/hubfs/2023-06-30%20Audit%20Committee%20Minutes%20Approved.pdf	2024-07-15T08:16:17+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-30/subset=warc/part-00208-65338ae2-db7f-48fa-a620-71777c40d854.c000.gz.parquet	909,571,869	571	eng_Latn	eng_Latn	0.964421	eng_Latn	0.977697	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1666, 2395 ]
A game figure is provided having a liquid projectile launching device. The liquid projectile launching device includes a body, a fluid reservoir supported by the body, and a liquid projectile launching mechanism supported by the body and in fluid communication with the fluid reservoir. FIG. 1 FIG. 2 FIG. 3 LIQUID PROJECTILE SHOOTING DEVICE AND GAME CROSS REFERENCE TO RELATED APPLICATIONS [0001] This application is a continuation of U.S. patent application Ser. No. 12/067,156 filed Oct. 3, 2008, which will issue on Dec. 13, 2011 as U.S. Pat. No. 8,074,993; which is a 371 National Phase of International Application No. PCT/IB2006/002569, filed Sep. 15, 2006, which claims the benefit of U.S. provisional application no. 60/717,443, filed Sep. 15, 2005, the entire contents of which are incorporated by reference as if fully set forth. FIELD OF INVENTION [0002] The present invention, relates generally to a device, such as a toy, for launching a liquid projectile. BACKGROUND [0003] Toys which simulate robots, soldiers or the like, and which launch projectiles, provide a constant source of amusement to children. However, solid projectiles launched by such toys (e.g., marbles, plastic missiles or bullets, or the like) can pose a danger to young children who may swallow the projectiles. Also, solid projectiles may cause injury if they strike a person, for example if the projectile is fired at the eye. Solid projectiles can also easily become lost, rendering the toy ineffective. Therefore, what is needed is an improved toy for launching a projectile, where the projectile is safe and is not subject to being lost. SUMMARY [0004] Liquid projectiles cannot be fired from devices such as toys with sufficient velocity to cause injury, and also cannot cause choking if swallowed. As the liquid projectile is not reused in the same manner as a solid projectile, the liquid projectile cannot become lost. [0005] The invention thus provides a free-standing device, such as a toy, comprising at least one liquid reservoir and at least one liquid projectile launching mechanism. When actuated by the user, the liquid projectile launching mechanism draws a portion of the liquid from the reservoir and launches this portion of liquid outward from the toy. [0006] The invention further provides a game, comprising at least one device of the invention and at least one target or at least two devices of the invention, and optionally rules for game play. [0007] The invention further provides a method of playing a game, comprising the steps of providing a game comprising at least a first device of the invention and a target, and firing liquid projectiles from the device toward the target, such that the target can be struck by the liquid projectiles. [0008] The invention still further provides a method of playing a game, comprising the steps of providing a game comprising at least a first and second device of the invention, and firing liquid projectiles from the first device toward the second device, and from the second device toward the first device, such that the first or second devices are struck by the liquid projectiles. The step of firing liquid projectiles can optionally be repeated until the game is concluded. [0009] The invention yet further provides a method of marketing a device or game of the invention, comprising packaging the device or game with at least one additional item. BRIEF DESCRIPTION OF THE DRAWINGS [0010] For the purpose of illustrating the invention, there are shown in the drawings forms which are exemplary; it being understood, that this invention is not limited to the precise arrangements and instrumentalities shown. [0011] FIG. 1 is an exemplary liquid projectile launching device of the invention; [0012] FIG. 2 is an alternate embodiment of the projectile launching device of FIG. 1; and [0013] FIG. 3 is schematic representation of a game system, which utilizes the projectile launching device of FIGS. 1 and 2. DETAILED DESCRIPTION OF THE PREFERRED EMBODIMENTS [0014] It will be appreciated that the following description is exemplary and is not intended to define or limit the invention, other than in the appended claims. For ease of illustration, the device of the invention is discussed in terms of a toy, although it is understood that the device of the invention can comprise other objects. [0015] As used herein, a “liquid projectile” is a portion of liquid, for example in the form of a drop, projected outwardly from the toy by the liquid projectile shooting mechanism. Once fired from the toy, the liquid projectile is not preferably not enclosed in any container. A liquid projectile also does not necessarily have a fixed or constant volume or mass, and the volume or mass of the liquid projectile may vary from toy to toy or between “shots” fired from the toy. It is understood that the liquid projectile can comprise a portion of the liquid in the liquid reservoir, or can comprise essentially all the liquid in the liquid reservoir of the toy; i.e., all the liquid in the reservoir can be expelled as one “shot.” The velocity of the liquid projectile when launched from a device of the invention can vary, but is sufficient to propel the liquid projectile at least some distance from the toy. [0016] A toy 100′ (depicted schematically in FIG. 3) of the invention comprises a body which, can support the liquid reservoir and liquid projectile launching mechanism. The body can be made in any suitable size and shape capable of supporting the liquid reservoir and liquid projectile launching mechanism, for example in the shape of a stylized human being or animal, robot, military vehicle or aircraft, spacecraft, or in a fanciful shape. The body can also be made in the likeness (including a caricature) of actual sports or military figures. The body can also comprise limbs or appendages-wheel, and the like which may move independently of me body or other toy components. [0017] The body further comprises one or more structures which allow the toy to be free standing. As used herein, “free standing” means that the toy can stand upright without support from an outside source, such as a user’s hand. Thus, the body can comprise a base portion with extensions, flanges, feet, struts, or other supports feat allow the toy to remain upright when unsupported from any source independent of the toy. The toy of the invention can also fire liquid projectiles while free-standing, such as with an electronically activated, automatic liquid projectile launching mechanism. The body can be essentially flat, (i.e., with minimal thickness), or it can be essentially three dimensional (3-D); i.e., with substantial length and depth. For example, in 3-D form, the toy can have the ability to stand upright. Alternatively, an essentially flat body can further comprise feet or other supports extending outward from the flat surface of the body to allow the body to stand upright. Thus, both the essentially flat and 3-D bodies can include at least one base member the body to stand upright and to be substantially anchored for the launch of a liquid projectile. The user can hold the toy during launch of the liquid projectile to provide further stability. The toy can comprise one or more colors, designs or indicia, for example for the purpose of decoration or to indicate different group affiliations. Such colors, designs or indicia can be those associated with actual armies, sports teams or sports or military figures. The toy can be any suitable size which allows a person to handle the toy and actuate the liquid projectile launching mechanism, as can be readily determined by one skilled in the art. For example, the toy can be from about 5 cm to about 50 cm (e.g., about 10 cm to about 30 cm, about 15 cm to about 25 cm, or about 20 cm) in height, from about 5 cm to about 30 cm (e.g., about 10 cm to about 25 cm, or about 15 cm to about 20 cm) in length (i.e., from left to right sides), and from about 5 cm to about 25 cm (e.g., about 10 cm to about 20 cm, or about 15 cm) in depth (i.e., from front to back). Greater or lesser values are contemplated for the height, length and breadth of the toy. All or part of the toy can be fabricated from any suitably rigid material, such as heavy gauge paper or cardboard, woods, metals, plastics, rubbers or synthetic resins, as are known in the art, by standard techniques for producing toys or figures. For example, the toy can be fabricated by injection molding or other suitable technique from commercially-available material such as thermo plastic polyurethane (TPU); ionomer resin; ethylene vinyl acetate (EVA); thermo plastic styrenics (TPS); melt processible rubber (MPR); thermo plastic vulcanate (TPV); thermo plastic olefin (TPO); thermo plastic ester elastomer (TPEE); thermo plastic elastomer (TPE); thermoplastic rubber (TPR); polypropylene (PP); polyethylene terphthalate (PET); polyvinyl chloride (PVC); acrylonitrile-butadiene-styrene terpolymer (ABS); a polycarbonate and acrylonitrile-butadiene-styrene terpolymer blend (PC/ABS); flexible plastic such as polystyrene sheet or polymethylmethacrylate (PMMA, marketed as “PERSPEX” by ICi Acrylics, Inc.); other acrylics; metal (e.g., stainless steel, aluminum, copper); wood; or any combination thereof. Other suitable materials and forming methods will be apparent to those skilled in the art. In various embodiments, the toy may be supplied as a fully assembled device or as a kit, wherein a user assembles the toy by popping out prefabricated parts along lines of weakness from a flat piece of plastic, metal or any other suitable material, and then attaches the liquid projectile reservoir and liquid projectile launching mechanism. Generally, the assembly of the toy will not require the aid of tools and/or adhesives, and all the parts can be joined together by the snap-fit of the parts themselves. The liquid reservoir can comprise any closed or open container suitable for holding liquid. For example, the liquid reservoir can comprise a thin-walled plastic container with a removable cap. In practice, the liquid reservoir can be refilled when the liquid has been depleted during play. Alternatively, the liquid reservoir may not include a removable cap or other means for refilling, and the toy or the liquid reservoir would then be discarded when the liquid in the reservoir is depleted, and the entire toy or the liquid reservoir replaced. (It is envisioned that such a liquid reservoir could be disposable, or provided in a small, inexpensive disposable toy.) The liquid reservoir can be constructed from any suitable material, such as the materials described above for the body, according to techniques within the skill in the art. The liquid reservoir can also be constructed to withstand internal pressure, for example if the air and liquid within the reservoir are pressurized in preparation for firing liquid projectiles. As used herein, “supported by the body” means that the liquid reservoir can be located on the outside of the body, inside the body, or can extend through the body. It is specifically contemplated that the liquid reservoir can be coextensive with the body; for example, the liquid reservoir can be formed by the body, and this configuration is included in the meaning of “supported by the body”. At least one liquid projectile launching mechanism is in fluid communication with one or more liquid reservoirs, for example through a tube or other suitable conduit. A liquid projectile launching mechanism can be located on the outside of the body, inside the body, or can extend through the body. When located outside the body, the liquid projectile launching mechanism can function independently of the body, and can comprise all the elements (including a liquid reservoir) necessary to store and launch a liquid projectile. For example, an independently functioning liquid projectile launching mechanism can represent a gun held in the hand of a toy figure of the invention. Such independently functioning liquid projectile launching mechanisms can be interchangeable from toy to toy. Alternatively, the liquid projectile launching mechanism and the liquid reservoir can be located separately outside the body, and can be removed or interchanged with the liquid projectile launching mechanism or liquid reservoirs on other toys. In any case, that portion of the liquid projectile launching mechanism which discharges and directs the liquid projectile away from the body (called the “discharge tube,” see below) should not be obstructed by the body so that the liquid projectile can be launched unimpeded. The liquid projectile launching mechanism can comprise any suitable mechanism for drawing liquid from the liquid reservoir and launching a portion of liquid outwardly from the toy. For example, the liquid projectile launching mechanism can comprise a simple manual or electric pump mechanism such as are commonly found in plastic squirt guns; see, e.g., U.S. Pat. Nos. 6,892,902 and 5,373,975, the entire disclosures of which is herein incorporated by reference. The pump can force liquid directly through and out the liquid projectile launching mechanism, for example by actuating a piston operably connected to series of valves which allow the liquid to be forcibly ejected from the liquid projectile launching mechanism. Alternatively, the pump can pressurize the liquid reservoir such that the liquid travels through and out the liquid projectile launching mechanism when a valve between the liquid reservoir and liquid projectile launching mechanism is released. The pump can also be configured to draw liquid into the liquid reservoir to replenish the liquid supply therein. The liquid projectile launching mechanism can also comprise a bladder or other flexible-walled container. The bladder or other flexible-walled container can be filled to overcapacity to create internal pressure, such that liquid can be expelled through an opening in the liquid projectile launching mechanism. The liquid projectile launching mechanism comprising a bladder or other flexible-walled container can also be squeezed to expel the liquid. Where a liquid projectile launching mechanism comprises a bladder or other flexible-walled container, the liquid projectile launching mechanism and the liquid reservoir can be essentially coextensive. For example, the bladder or other flexible-walled container can be the liquid reservoir. The liquid projectile launching mechanism can also comprise a mechanism which expels hollow or porous projectiles, which are filled or saturated with a liquid. Such mechanisms are known in the art, and can comprise pneumatic systems, spring-loaded systems, or systems in which the projectile is expelled by the potential energy of a rubber band or other elastic material, such as are known in the art. As used herein, a liquid projectile thus includes a hollow or porous projectiles, which are filled or saturated with a liquid. In such configurations, the liquid reservoir may contain liquid, or may comprise a magazine or other similar container for holding the hollow or porous liquid projectiles. It is also contemplated that the toy can comprise further magazines or similar containers for holding the hollow shell or porous material before the liquid has been added. Liquid from a liquid reservoir can then be apportioned into the hollow shells or porous materials to form the liquid projectile before the projectile is fired. When actuated, the liquid projectile launching mechanism expels liquid projectiles through at least one discharge tube. The discharge tube is considered part of the liquid projectile launching mechanism. The discharge tube can extend away from the body, and may be constructed so that it can be aimed independently of the body; i.e., the discharge tube can be positioned to point or aim in different directions without necessarily changing the orientation of the toy. For example, the discharge tube, or the entire liquid projectile launching mechanism, can be seated on a ball bearing, so that the shooting direction can be changed without moving or changing the orientation of other parts of the toy. The discharge tube can comprise cylinders of differing diameter (see, e.g., FIG. 1) and can comprise other components such as a nozzle. A discharge tube can be positioned anywhere on the body which allows liquid projectiles to be projected outwardly from the toy when the liquid projectile launching mechanism is actuated. As discussed above, the liquid projectile launching mechanism, can be manually or electronically actuated. If electronically actuated, the liquid projectile launching mechanism can fire multiple liquid projectiles in succession without further input from the user, until the electronic signal is stopped or the liquid reservoir is depleted. Multiple liquid projectiles can also be fired in succession by manual actuation of the liquid projectile launching mechanism. Alternatively, manual or electronic actuation of the liquid projectile launching mechanism can result in the expulsion of essentially all the liquid in the liquid reservoir at once. An exemplary liquid projectile launching mechanism is shown in FIG. 1. With reference to FIG. 1, the exemplary liquid projectile launching mechanism 100 comprises a spring 105 engaged with piston 110 such that the spring 105 forces the piston 110 forward (toward the nozzle 115) when the spring 105 is compressed by action of the trigger 120 as described below. The piston 110 is seated in housing 125, which comprises a channel through with the piston 110 can extend, and together form a pump assembly as indicated by 111. In use, the liquid projectile launching mechanism is actuated by depressing trigger 120 such that the piston is drawn backward (away from nozzle 115) by virtue of the contact between the trigger 120 and piston surface 130 by flange 135. As the piston 110 is drawn, backward, spring 105 is compressed between piston surface 140 and housing surface 145. When the piston 110 is drawn backwards, water from the fluid reservoir 150 will fill the interior of the cylinder 155. Upon reaching essentially file full range of depression, the trigger 120 pivots around a bearing (marked as hole 160), causing the flange 135 to lose contact with piston surface 130 and releasing the piston 110. The piston 110 is then biased forward by the spring 105, and the liquid in the interior of cylinder 155 will travel through the discharge tube 165 and finally out through the nozzle 115 with sufficient velocity to project the liquid away from the nozzle. The reservoir 150 also includes a cap 151 that is removable for refilling the reservoir 150. In an alternative embodiment, the pump 111 can be actuated electronically by an electronic actuator 121 as shown in FIG. 2. The toy can also comprise electronic components other than, and optionally connected to, any electronic components comprising, shown schematically in FIG. 2 as 170, the liquid projectile launching mechanism. Such electronic components can be activated along with any electronic components comprising the liquid projectile launching mechanism, or can be activated separately. For example, the toy can comprise components for the electronic generation of sound and/or light, or for independent movement of the toy. For example, the toy can comprise limbs or appendages that are connected to drive motors activated by the electronics. Alternatively, the toy can move independently through drive wheel or wheels located on the feet or base of the toy, which are connected to a drive motor activated by the electronics. Electronics suitable for use in the toy of the invention can include a power source box, or battery box which can be located suitably in the body, for containing batteries or another suitable power source. Suitable wires can be used to couple operable components such as incandescent lights, LED's, switches and speakers. These components can be supported and/or contained in the body, located outside and supported by the body, or can extend through the body. For example, one or more portions of the body can be lighted or adapted to glow by providing a suitable light source such as an LED mounted adjacent to a chamber with transparent or translucent portion. The electronic components can be activated by actuation of the liquid projectile launching mechanism and/or by the flow of liquid through the liquid projectile launching mechanism. For example, a switch can be mounted adjacent to a conduit or a flexible or soft portion of a conduit, such as conduit carrying pressurized liquid from the liquid reservoir to or through the liquid projectile launching mechanism. The deformation or expansion of the conduit can move one contact element of the switch into contact with the other element, thus activating the electronics. The electronic components can also be activated by contact with a liquid. For example, the toy can comprise a liquid-responsive switch opening or closing an electric circuit between a battery and a light or sound source when in contact with liquid. A suitable liquid-responsive switch, as is known in the art, comprises a pair of electric terminals impressed with a certain voltage potential. When in the dry state, the impedance between the terminals is very high and the current allowed to circulate is virtually nil. However, when wet, the impedance is dramatically reduced establishing an electrical path which sets a simple transistor circuit in the conduction state, closing the electric circuit between the battery and the light source. Thus, the toy can be activated to emit sound and/or light when struck by a liquid projectile from another source. This arrangement can be used to indicated a “score” or “hit” by another such toy when simulating combat or team sports play with the toys of the invention. A liquid-activated switch can also be operably connected to a liquid projectile launching mechanism, such that the liquid projectile launching mechanism is temporarily inactivated or rendered inoperable when the toy is struck by liquid, for example from another such toy. [0036] The toy 100' can also comprise at least one portion located on the outside of the body which reacts when contacted with a liquid. For example, this portion can comprise a substance which changes color, or loses or gains opacity, when contacted with a liquid. Thus, this portion can act as a target which indicates when it is hit with a liquid projectile. For example, the body can comprise a plastic or cloth that changes color when becoming wet, or can comprise a surface which has been coated with a particulate (e.g., dust, sand, fiberglass, or the like) on the surface, which particulate changes color or becomes transparent when wet, revealing an underlying color. Different portions of the body can comprise at least two liquid reactive materials which react differently from each other when wet. For example, a leg portion of the toy can comprise a material which turns a first color (e.g., green) when wet, and a head portion of the same toy can comprise a material which turns a second color (e.g., blue) when wet. Thus, a game of the invention, depicted schematically in FIG. 3 can comprise at least two toys 100' of the invention which at least one portion comprising a material which reacts when wet. A target 210 included in a game of the invention (see below) can also comprise materials which react differently when wet. For example, the outer areas of the target 210 (which are typically considered lower scoring) can comprise a first material which turns a first color when wet, and the inner areas of the target, such as the “bulls-eye” or center (typically considered higher-scoring) can comprise a second material which turns a second color when wet. A game of the invention can also comprise a game board 200 or playing arena comprising different obstacles or formations (see below) which comprise materials which react differently when wet. For example, a game board 200 or arena can comprise a protective wall 220 behind which a toy 100' of the invention can be hidden while playing a game, which protective wall 220 turns a given color upon being hit by a liquid projectile fired by an opposing toy 100'. [0037] The toy can also comprise at least one portion located on the outside of the body which reacts when contacted with an acidic ox basic solution. For example, this portion can comprise a pH indicator which changes color upon contact with an acid or a base. A suitable pH indicator is one which changes to a certain color (e.g., blue) when contacted with an acidic solution, and changes to another color (e.g., pink or red) when contacted with a basic solution. Thus, a game of the invention can comprise at least two toys of the invention with at least one portion comprising a pH indicator. One toy carries an acidic liquid in its liquid reservoir, and the other toy carries a basic solution. Hits from the toy carrying the acidic solution will cause the other toy to turn a first color, and hits from the toy carrying the basic solution will cause the first toy to turn a second color. The initial color of the pH indicator on a given toy can be restored by removing the acidic or basic solution (such as by washing with water), or by neutralizing with an acidic or basic solution, as appropriate. [0038] With regard to fastening, mounting, attaching or connecting components of the invention to form the toy, unless specifically described otherwise, such are intended to encompass suitable conventional fasteners such as screws, nut and bolt connectors, threaded connectors, snap rings, detent arrangements, clamps such as screw clamps and the like, rivets, toggles, pins and the like. Components can also be connected by adhesives, glues, welding, ultrasonic welding, and friction fitting or deformation, if appropriate, and appropriate liquid and/or airtight seals or sealing devices can be used. Electronic portions of the device can use conventional, commercially available electronic components, connectors and devices such as suitable wiring, connectors, printed circuit boards, microchips, speakers, lights, LED's, liquid crystal displays, pressure sensors, liquid level sensors, audio components, inputs, outputs and the like. [0039] As discussed above, the launch direction of the liquid projectile can be pre-selected by changing the orientation or posture of the toy and/or the discharge tube, to direct the flight path of the liquid projectile. The discharge tube can comprise an open or closed channel through which a conduit can run, or the discharge tube can itself comprise the conduit through which the liquid projectile travels. [0040] The liquid which can be used to form the liquid projectiles of the invention can include any suitable liquid which is compatible with the toy components, and which has a suitably low viscosity such that it can be discharged from the liquid projectile launching mechanism. Suitable liquids include water, such as tap water, spring water, salt water, sugar water or mineral water; inks, such as “disappearing” and other non-permanent inks and permanent inks: dyes, for example washable or other non-permanent dyes and permanent dyes; fluorescent liquids; perfumes; juices; liquid candies and acidic or basic liquids. Generally, acidic or basic liquids for use in the invention comprise a weak acid or base, so as not to damage the toy or toy components and surrounding object, or injure a user. [0041] Toys of the invention can be marketed by packaging the toy with at least one additional item for sale, such as candy or gum, stickers, electronic items, and promotional items such as contests or lotteries and team or league paraphernalia. [0042] Toys 100' of the invention can be utilized to play games in which a user is required to hit an opponent’s toy 100', target 210, goal, etc. Thus, the invention provides a game comprising at one toy 100' of the invention and a target 210, or at least two toys 100' of the invention, and suggested rules of play. For example, the game can comprise two teams or armies of toys, with each team or army comprising 1, 2, 3, 4, 5, 10, 20, 50 or more toys 100'. [0043] The target 210 can comprise a liquid-activated switch connected to sound- or light-generating electronics, such as are described above. The target 210 can also comprise at least one portion which reacts when contacted with a liquid, as described above. Thus, the target 210 can indicates when it is hit with a liquid projectile. [0044] A game of the invention, can be played on any generally planar playing surface 200, such, as a floor, table top, desktop, and the like. The playing surface 200 is preferably smooth enough so that the toys can move unimpeded during game play. Alternatively, the playing surface 200 can be uneven or multi-leveled. A game of the invention optionally comprises one or more game boards 200 which are marked or otherwise carry indicia which simulate, for example, battle fields or fields of play for one or more team sports. It is understood that the markings or indicia which simulate a battle field or field of play on a game board 200 can include rear areas, sideline areas or other areas where individuals not actively participating in the group activity would be located. One skilled in the art is familiar with the relative dimensions and configurations of fields of play for team sports, and can readily adapt such, dimensions and configurations into a game board 200 for use with, the present invention. In addition to any markings or indicia which, indicate the field of play, a game board 200 can also comprise regular markings which indicate spaces or distances through, which a toy 100' can be moved in a given turn during game play, or obstacles impeding the movement of toys. For example, a game board 200 can comprise a grid of regular squares or hash marks which dictate the extent to which a toy 100' can be moved during game play. The game board 200 of the invention (e.g., representing a battle field) can comprise mobile or random-appearing obstacle or target. For example, such a game board 200 can comprise flat "pop-up" targets 210 representing opponents, which appear at random intervals and/or locations during game play. Such "pop-up" targets 210 can be controlled by electronics such as are described above, as is known in the art. The game board 200 of the invention can be fabricated from any suitably smooth and rigid material, such as heavy gauge paper or cardboard, woods, metals, plastics, rubbers or synthetic resins, as are known in the art, by standard techniques. The game board 200 can comprise colors, designs or indicia in addition, to those which mark the field of play, for example which are associated with a particular army, team or league that engages in the group activity being simulated. The game board 200 can also comprise structures which can be attached to or placed on the game board, representing obstacles, geographic features, seats, score boards, goals or goal posts and the like. The game board 200 may be placed on, any flat surface, or may be supported by a frame or by legs, during play. The game of the invention can also comprise other items, such as a foldable housing to contain the playing pieces and game board (if present) when not in use, scorecards or other devices to record game statistics and results, candy or gum, electronic devices (such as for producing light and sound effects or play-by-play announcements during game play), a timing device, stickers or the like for decorating the game pieces and/or game board, and promotional items such as contests or lotteries and team or league paraphernalia. The precise rules of play for a game of the invention depend on the type of game desired to be played. For example, the game can comprise rules of play simulating combat. Such rules can be readily designed and understood by one skilled in the art. For example, using the techniques for moving the toys and for shooting liquid projectiles, games simulating various combat situations can be played. In one such game, two armies of toys can be provided. The individuals playing the game decide beforehand which army shall have initial possession of which parts of the battle field, and which army can attack first. For example, the armies can occupy different sections of the battlefield, or one army can occupy the entire battle field, and the second army can attempt to "invade" the occupied territory. The game is begun by one or more toys of a given army attacking toys of the other army. A toy can attack another toy by launching a liquid projectile toward that toy. The toy which has been attacked will be "wounded" or "killed" if it is struck by the liquid projectile. The "wounded" or "killed" toy is then removed from the board or left in place, and game play continues. "Wounded" toys may be re-introduced to the board or used again after a suitable amount of time has passed, simulating recovery of the wounded soldier. The game progresses with a series of turns, in which each individual playing the game moves their toys (a "move" includes projecting a weapon at an opposing toy). Multiple toys can be moved in a given turn. The game continues until the expiration of a predetermined time period or until all the toys of one army have been "wounded" or "killed." The army with the most remaining toys at the end of the time period, or the army in possession of a predetermined territory or objective, wins the game. While the present invention has been described in connection with the examples discussed above and the various figures, it is to be understood that other similar examples may be used, or modifications or additions may be made to the described examples for performing the same function of the present invention without deviating therefrom. Therefore, the present invention should not be limited to any single example, but rather should be construed in breadth and scope in accordance with the recitation of the appended claims. What is claimed is: 1. A game figure comprising a liquid projectile launching device, the liquid projectile launching device comprising a body, a fluid reservoir supported by the body, and a liquid projectile launching mechanism supported by the body and in fluid communication with the fluid reservoir. 2. The game figure of claim 1, wherein the liquid projectile mechanism comprises a piston is seated in housing, which comprises a channel through which the piston extends, wherein when the piston is drawn back, a biasing member is compressed between a piston surface and water from the fluid reservoir fills a cylinder intermediate the reservoir and a discharge tube, when the piston is released, it is biased forward by the spring, the liquid in the interior of cylinder moves through the discharge tube outwardly through a nozzle connected thereto with sufficient velocity to project the liquid, in a single drop, away from the nozzle. 3. The game figure of claim 1, wherein the game figure comprises a body configured in the shape of: a stand, a human, an animal, a robot, a vehicle, an aircraft or a spacecraft. 4. The game figure of claim 3, wherein the game figure body supports the liquid projectile launching mechanism and the fluid reservoir. 5. The game figure of claim 4, wherein the liquid projectile launching mechanism is integral with the game figure body. 6. The game figure of claim 4, wherein the liquid projectile launching mechanism is detachable from the game figure body. 7. The game figure of claim 1, wherein the game figure comprises a body configured in the shape of a human holding a gun and the liquid projectile launching mechanism is configured as the gun. 8. The game figure of claim 3, wherein the body comprises a portion which provides an indication when wet. 9. The game figure of claim 8, wherein the indication is a color change, a sound or a light. 10. The game figure of claim 2, wherein the liquid projectile launching mechanism comprises a pump. 11. The game figure of claim 10, wherein the pump is manually or electronically actuated. 12. The game figure of claim 2, wherein the liquid projectile launching mechanism comprises a pressurized liquid reservoir. 13. A game comprising at least one game figure comprising a liquid projectile launching device, the liquid projectile launching device comprising a body, a fluid reservoir supported by the body, and a liquid projectile launching mechanism supported by the body and in fluid communication with the fluid reservoir. 14. The game of claim 13, wherein, the mechanism comprises a piston is seated in housing, which comprises a channel through which the piston extends, wherein when the piston is drawn back, a biasing member is compressed between a piston surface and water from the fluid reservoir fills a cylinder intermediate the reservoir and a discharge tube, when the piston is released, it is biased forward by the spring, the liquid in the interior of cylinder moves through the discharge tube outwardly through a nozzle connected thereto with sufficient velocity to project the liquid, in a single drop, away from the nozzle. 15. The game of claim 13, wherein the at least one game figure comprises a body configured in the shape of: a human, an animal, a robot, a vehicle, an aircraft or a spacecraft. 16. The game of claim 13, further comprising at least one target. 17. The game of claim 16, wherein the at least one target comprises an indicator to show when the target is struck by a drop. 18. The game of claim 17, wherein the indication is a color change, a sound or a light. 19. The game of claim 16, wherein the at least one target comprises an outer area indicator that comprises a first material which turns a first color when wet, and an inner area comprising a second material which turns a second color when wet. 20. The game of claim 13, comprising at least two game figures, wherein the at least two game figures each comprise a body configured in the shape of: a stand, a human, an animal, a robot, a vehicle, an aircraft or a spacecraft. 21. The game of claim 20, wherein the body comprises an indicator to show when the body is struck by a drop. 22. The game of claim 21, wherein the indication is a color change, a sound or a light.	<urn:uuid:2de30ee3-f3a1-4e46-a7fa-eb91dcf0dd19>	CC-MAIN-2018-30	https://patentimages.storage.googleapis.com/f3/15/7d/a2f6e927581388/US20120080847A1.pdf	2018-07-20T18:17:21Z	s3://commoncrawl/crawl-data/CC-MAIN-2018-30/segments/1531676591719.4/warc/CC-MAIN-20180720174340-20180720194340-00490.warc.gz	723,070,155	7,802	eng_Latn	eng_Latn	0.997454	eng_Latn	0.998199	[ "eng_Latn", "unknown", "unknown", "unknown", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	docling	[ 286, 294, 302, 310, 6564, 13912, 21284, 28832, 35895, 38481 ]
Mendip East Newsletter – September 2021. Welcome to this month's newsletter, for September which is sent out from the team at the start of each month to keep you updated about what your local neighbourhood policing teams have been up to and anything we have planned for the future – If you no longer wish to receive this please let us know. We are still facing challenges with the amount of demand that the police are receiving over the summer months. August has been another busy month for the Teams. Frome Town – August has been another exciting month for the town team, we continue our excellent partnership with our colleagues for the Community Speed watch (CSW), with a number of schemes currently in operation across the town, and we often visit and assist each of our schemes. CSW is a partnership between the Community, the Police and Local Authorities. It gives local people the ability to actively get involved in Road Safety. The aim of Community Speed Watch is to make motorists who speed through residential neighbourhoods aware of the impact their actions have on local residents, or the danger they pose to other road users and pedestrians. This is something we are working with communities to address. More information on CSW can be found here: https://www.avonandsomerset.police.uk/apply/community-speedwatch/ It has also been great to see an array of events in the town, we have been able to support the Town Councils play day in the park as well as the Lions Club summer fete. We have also been able to offer our bike registration service to users of Victoria Park. We often hold events where you can make use of these services or even just come and speak with us, all our events our advertised on our social media channels and also on our website which can be found here: https://www.avonandsomerset.police.uk/your-area/frome-town/ We also continue to receive sporadic reports of Crimes and ASB being caused in both Victoria Park and Mary Bailey playing fields. Because of these calls, numerous people have been identified and have been issued an ASB warning letter. Because of these reports, we also continue to utilise s.35 of the Anti-Social Behaviour, Crime and Police Act 2014 which allows officers and PCSO's to disperse persons identified as causing ASB. We work closely with Frome Town Council to ensure that the parks remain safe for all to use. If you do experience any ASB, or cause for concern, in and around our parks, we urge you to report it as it is happening on 999, 101 or via the force website as appropriate. Frome and Shepton Rural- During this month, a burglary occurred in a residential property in Ditcheat. High value jewellery was stolen leaving the owner understandably upset. Within a short period, Police recovered the jewellery with a suspect found & arrested. There have been a recent fire set on the old factory site at Evercreech. In addition, a bench was damaged by fire on the recreation ground off Queens's Road. The Rural Neighbourhood Team have directed patrols to this area to deter further incidents. Rural officers have been out to visit farms recently due to being the victim of fuel thefts. Intelligence has been gathered which we hope to use to target criminals who steal fuel. Alarms and padlocks have been provided to victims to help boost their security of sheds and fuel containers. Shepton Mallet Town – The Shepton Neighbourhood Team were invited to attend an event at Pullen Court. It was a good time for engagement with the local community as there had been a few reports of incidents in the general area. The team continue to carry out regular patrols in this part of town to offer reassurance. Also during this time local PCSO Amanda Ware in company with the trading standards loan shark team conducted a week of action in Shepton Mallet Town Area due to information received that loansharks were targeting our area. We wanted to get information out about the illegal practices of loan sharks. We conducted a social media campaign and conducted some drop in surgeries outside Tesco's and Aldi to hand out leaflets. Our goal as always is to safeguard as many members of our community as we can. We want to thank the local community for the support we received. There are multiple ways you can report a loan shark either by phone 0300 555 2222 or Text 07860022116 email: [email protected] or you report online at stoploansharks.co.uk A big hello from the Fraud Protect team! We are a brand new team within Avon and Somerset Constabulary, focused on supporting vulnerable victims of fraud. We are committed to providing our communities with all of the materials and knowledge they need to identify a scam, and protect themselves from fraud. Fraud is the UK's biggest recorded crime and it was recognised by our force that we need to do better with supporting victims of this cruel crime. As with anything new, things take time. However, we are well and truly up and running! Since March of this year we have delivered enhanced interventions to over 60 victims of fraud that were either in denial or considered to be extremely vulnerable. In addition to that, we have reached hundreds more by reaching out to parish councils, universities and various clubs/organisations providing them with fantastic resources. Some of the things we can do are: Install call blockers to prevent those nasty cold calls Home visits when a victim does not recognise they are being defrauded Deliver fraud safety speeches to community groups Educate the public on different types of fraud and how to identify it Safeguard victims from being repeatedly targeted Spread awareness on the threat of fraud and the impact it has The most common scams we see are romance fraud, courier fraud, transfer into a safe account fraud, and advance fee fraud. We have a great book detailing all of these that includes tips on how to spot a scam. If you would like a copy sent out to you in the post or the online version emailed to you, please contact us. Similarly, if you have an audience that you feel would benefit from a fraud safety speech (this could be anything from community groups to care home residents) we would love to hear from you too! Reach out to us anytime using [email protected] If you think you have been a victim of fraud, please report it to Action Fraud on 0300 123 2040 or via their website at www.actionfraud.police.uk We have now seen our local Facebook pages change these can now be found under: Frome Neighbourhood Policing and Mendip Neighbourhood Policing. Mendip Neighbourhood Supervisor contact details: Sergeant Rachel Clark PCSO Supervisor Stephen Reading Email: [email protected]: [email protected] We continue to ask that members of the public who are witnessing any incidents to report them to us as they are happening, via 999, 101 or the Force Website.	<urn:uuid:720c0e54-33ff-42c4-a959-f287f1a4353c>	CC-MAIN-2022-21	http://beckingtonparishcouncil.org.uk/get_file.php?id=453	2022-05-20T11:00:37+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-21/subset=warc/part-00013-bd7ecbba-8e15-4123-ae07-d9c98ad96845.c000.gz.parquet	6,299,977	1,477	eng_Latn	eng_Latn	0.999417	eng_Latn	0.999425	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 3362, 7018 ]
Pregnancy - what do you need to know? The following table will highlight some of the key topics that are important to understand. \| Resources \| \| Topics \| \|---\|---\|---\| \| \| 1. If you smoke, quit NOW & make sure your home is smokefree I'm quitting smoking for baby and me Quit Line NZ Local support services (select the region you want) HealthPoint \| \| \| \| 2. Folic acid and Iodine Ideally take folic acid once a day for 3 months prior to pregnancy and the first 3 months of pregnancy. Iodine is one tablet per day throughout pregnancy. Ask your GP or midwife for a prescription for each. Read more: Webpage \| \| \| \| 3. Do not drink alcohol once pregnant or planning to become pregnant The safe level of alcohol intake is said to be zero when pregnant. Webpage and brochure pdf HealthEd NZ \| \| \| \| 4. Choose a Lead Maternity Carer (a midwife, GP or specialist) Your pregnancy booklet from HealthEd NZ \| \| \| \| 5. Avoiding Listeria Learn about foods that are safe and those that are not. Health Ed website \| \| \| \| 6. Healthy eating and physical activity in pregnancy Eating well and doing moderate physical activity during pregnancy are important for you and your baby. Webpage and booklet pdf HealthEd NZ \| \| \| \| 7. Rubella and women If you are planning pregnancy, ask your GP for a blood test to see whether you need to be immunised for rubella. If pregnant, find out if you are immune. If not, find out how to reduce risk. Read more: Rubella information, \| \| Resources Topics 8. Screening tests When you are first pregnant, you will be offered some standard blood tests and a urine test (this looks for any sign of a urine infection or bacteria in the urine). This blood test is free, and it checks for: - your blood group, rhesus factor and for any antibodies - your haemoglobin (the amount of iron in your blood) - if you are immune to rubella - if you are a hepatitis B carrier, have syphilis or HIV - if you have diabetes or are at risk of developing diabetes. 9. Antenatal screening and testing for Down's Syndrome & other conditions You will also be offered screening tests to check for Down's syndrome and other genetic conditions. The type of test that can be done depends on how many weeks pregnant you are. - First trimester combined screening (before 14 weeks) Blood test and a nuchal thickness ultrasound scan (looks at the thickness of the back of the neck of the developing baby. (Part charge for ultrasound). - Second trimester maternal serum screening (14-20 weeks) Blood test plus age and weight, to give a risk result. - Read more about antenatal screening, National Screening Unit HIV testing in pregnancy We now offer all pregnant women the option of being tested for HIV infection as early detection can reduce the risk of passing this on to the baby. - Health Ed website and pamphlet in 8 languages. - English, Chinese Simplified, Sāmoan, Tongan etc. For further information about pregnancy and what to expect, visit - www.healthnavigator.org.nz/healthy-living/pregnancy/pregnant-whatdo-i-need-to-know/ - Includes pregnancy videos, apps, books and much more. Content adapted from Health Navigator NZ with permission. Visit www.hn.org.nzAugust 2015.	<urn:uuid:d4ee44d5-da22-4870-9dc0-48b4b60f4771>	CC-MAIN-2024-38	https://maternitycare.co.nz/wp-content/uploads/2019/11/MOH-Pregnancy-what-do-you-need-to-know.pdf	2024-09-09T16:00:10+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2024-38/subset=warc/part-00063-781f89b0-54ef-4e32-b51d-e5860e733e3a.c000.gz.parquet	364,564,403	770	eng_Latn	eng_Latn	0.99796	eng_Latn	0.996884	[ "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 1479, 3204 ]
FINDING BALANCE THE POST-COVID LANDSCAPE FOR FINANCIAL INSTITUTIONS Sustainability Part 6 Resilience Recovery Renewal INTRODUCTION Welcome to our sixth briefing on how COVID-19 has affected financial institutions and its impact on current industry trends. In this edition, we focus on the first of our global mega trends — sustainability for financial institutions. Together with digital transformation, we are likely to see the sector transformed by these two trends over the next decade. As always, in addition to sharing our own opinions, we reference the views of external commentators. Please bear in mind that our opinions are based on hypotheses that may change in a rapidly developing situation and there are doubtless other perspectives. Takeaways • Financial institutions are critical players in the transition to a carbon neutral economy and because of their role in allocating capital can act as a catalyst to achieving better environmental, social and governance (ESG) outcomes in society generally. • Reflecting their role in mediating the allocation of capital and their highly regulated nature, sustainability for financial institutions extends beyond climate change, and even further than wider ESG concerns, to encompass the very nature of their contribution to the economy and society as a whole. • Sustainability has seen a tremendous rise in awareness since 2015 with the COVID-19 pandemic providing added impetus, yet progress is slowed by the lack of common, consistent, international standards over disclosure and classification. • Sustainability policies are a necessary response to climate change and to better manage social and governance risks faced by financial institutions, while affording the opportunity to offer new products and services, allowing the most agile businesses to differentiate themselves from their competitors. Sustainability for financial institutions - setting the terms of the debate Broadly speaking, for financial institutions, sustainability represents both risk and opportunity. On the risk side, in 2015, the then Chair of the Financial Stability Board, Mark Carney, gave a widely reported speech in which he referred to the impact of climate change on financial stability as the “the tragedy of the horizon” — an allusion to the costs of inaction falling on future generations. On the opportunity side, however, many organisations have identified “green” and “sustainable” finance as a business model creating a variety of offerings for the market. While Mark Carney’s speech focused on climate change, arguably, sustainability for financial institutions, goes beyond environmental and even social and governance factors, to require their leadership to think holistically about their businesses and the ethical drivers, so that not only are they profitable, but that financial services make a positive contribution to society as a whole. Put another way, ensuring that financial products add real value rather than representing another cost to financing the economy. This concept reflects the highly regulated nature of the industry and aligns with the desire to improve culture, and therefore conduct, which has evolved in response to the excesses and wrongdoing identified after the 2008 financial crisis. The trend to sustainability in financial services It is important to understand the reasons behind the move to sustainability for financial institutions, after all climate change together with ESG concerns has been with us for several decades. A recent global survey of institutional investors found that the top motivations for ESG investing were improved long-term returns, brand and reputation together with reduced investment risk.$^2$ As regards the first of these — improving long-term returns, short-termism has for many years been viewed as an important barrier to companies putting sustainability at the core of their strategy and decision making. Pressure to prioritise quarterly earnings can among other matters discourage businesses from investing in the development of sustainable products.$^3$ The key driver in recent years is the 2015 Paris Agreement, an international treaty on climate change that seeks to limit global warming to well below 2, and preferably below 1.5 degrees celsius compared to pre-industrial levels. To do so, net-zero carbon emissions are required by 2050 if not before. The Paris Agreement specifically identifies finance as having a key role in mitigating the effects of global warming as large scale investments are needed to significantly cut emissions.$^4$ Nor, of course, are financial institutions, which advise on, manage, invest and lend capital, immune themselves from the effects of climate change as their prudential soundness and ability to meet long term commitments can be jeopardised if the value of their capital is impacted. Here, it is worth noting the development of science-based long-term risk analysis. A World Economic Forum study shows that in 2010, none of the top five long-term risks were environmental. Five years later in 2015, one out of five (extreme weather). By 2020, however, all of the top 5 long-term risks were environmental (extreme weather, climate action failure, natural disasters, bio-diversity loss, and human-made environmental disasters).$^5$ In common with other sectors of the economy there is increasing commercial and competitive pressure on financial institutions from investors and those in positions of stewardship to favour green and sustainable investment and, in doing so, to adopt high standards of transparency. What was initially, (largely) voluntary and sometimes amounted to no more than marketing is becoming essential to win business and increasingly (especially in Europe which is in the vanguard), subject to legal and regulatory imperative. Arguably, financial institutions are at the heart of sustainability to a greater extent than carbon dependent industries, because the financial system — remembering the pivotal role of capital — is seen as a catalyst for change across the whole economy. Financial institutions are therefore generally ahead of other industry sectors in terms of being subject to detailed sustainability-related regulations. The COVID-19 pandemic is widely seen to have given sustainability further impetus. Contrary to the fears of many, we have not seen a retreat from steps to arrest climate change — in fact quite the opposite. 2020 may be a turning point strengthening the sector’s commitment to change. This is because many investors are concerned that the damage to the economy brought on by COVID-19 could be repeated by global warming and now place more value on screening out ESG risk.$^6$ The underlying theme: transparency As Mark Carney stated in 2015, "that which is measured can be managed." The market can be empowered in this way to assess environmental risks on companies' businesses models and take investment decisions accordingly. Transparency in this way allows for a differentiation between investments, a better understanding of the attendant risks and an ability to price risk more accurately. There are a plethora of standards, most voluntary, although an increasing number are prescribed. Moreover, some are national and others regional or international. This presents challenges to achieving effective disclosure and heightens the risk of greenwashing, thereby impeding the efficient allocation of capital to sustainable investments. Generally, transparency is best achieved when disclosure is consistent, comparable, reliable (or trustworthy), clear — and to be viable in practice — efficient, in the sense it minimises the costs and burdens of transparency.$^7$ As we discuss below, to ensure that disclosures are consistent and comparable, systems of classification or taxonomies for environmental risks are growing in popularity and whether they meet the efficiency test only time will tell. The importance of transparency extends to social and governance concerns. Businesses (including financial institutions) are publishing information on their policies, for example, regarding diversity and gender equality in the workplace and on ethical considerations in their supply chains. Even when not mandatory, these disclosures are frequently required as part of the terms of doing business. From voluntary standards to legal requirements The 2005 United Nations backed Principles for Responsible Investment (PRI) pre-date many other standards. The PRI are specifically for institutional investors being “a voluntary and aspirational set of investment principles that offer a menu of possible actions for incorporating ESG issues into investment practice.” Today’s 3,000 plus signatories acknowledge that ESG issues can affect the performance of their investment portfolios and commit to incorporating them into their investment decision-making process and to promoting disclosure. Ten years later the pace picked up, the Paris Agreement created a framework within which sustainability disclosures by all companies could take place and be compared, so leveraging peer pressure to help improve standards and reduce emissions. In the same year as the Paris Agreement, the Financial Stability Board established the Task Force on Climate-related Financial Disclosures (TCFD) whose recommendations provide a global principles-based framework for investors who want to understand the climate-related risks that businesses face, and how they are managing them. The TCFD recommendations, which are voluntary, have been widely adopted by private sector companies including financial institutions such as banks, asset managers and pension funds. They cover an organisation’s governance, their strategy over potential climate-related impacts and risk management together with metrics and targets to assess and manage risks and opportunities. Under the framework signatories use a variety of sometimes overlapping industry standards to achieve practical and detailed implementation. Of special note are those issued by the Sustainability Accounting Standards Board (SASB) and the Global Reporting Initiative (GRI), which although different in scope are complementary.\textsuperscript{72} While the TCFD recommendations by themselves have no legal force, companies listed on both the London and Hong Kong Stock Exchanges must now make disclosures consistent with them. The UK’s markets regulator has introduced rules for premium listed entities (initially on a “comply or explain” basis) to improve disclosures, and is to consult this year on extending their scope to other listed issuers and by 2022 to asset managers, life insurers and pension providers.\textsuperscript{73} The UK will also become the first country in the world to make TCFD aligned disclosures mandatory across the economy by 2025, going beyond the “comply or explain” approach.\textsuperscript{74} More generally, the International Organisation for Securities Commissions (IOSCO) has established a work stream on companies’ sustainability disclosures. This follows its report that identified issues arising from multiple and diverse sustainability standards, as well as significant gaps in climate reporting.\textsuperscript{75} In order to achieve a system of disclosure that is effective, not unduly burdensome, nor which disrupts ESG investment and allows for comparison, it is clear that greater international standardisation and convergence is required. More detail may need to be added to the framework provided by the TCFD recommendations. In September 2020, the leading international sustainability standard setters published a statement of intent on global ESG standards to propose a comprehensive corporate reporting system.\textsuperscript{76} This “harmonisation initiative” has received support from many jurisdictions and a new global Sustainability Standards Board has been advocated to achieve more coordination and standardisation. From a governmental perspective, the US has been largely absent from ESG-specific rulemaking. One exception is the Trump-era US Department of Labor rule addressed to pension administrators to take account of ESG factors only if they are “material economic considerations under generally accepted investment theories”\textsuperscript{77}. Under the new administration, however, the US has re-joined the Paris Agreement and a new executive order requires regulators to act in alignment with the President’s policy towards climate change. The recent Acting Chair of the SEC, Allison Herren Lee, pointed out in a speech that “…climate change and ESG are core and center of the SEC”\textsuperscript{78}. We can thus expect to see the SEC and other financial regulators in due course developing more ESG specific rules. The exact focus and scope remain to be seen, but we expect the US generally to take a less prescriptive and more enforcement-driven approach. In 2018, the European Commission, as part of its implementation of the Paris Agreement, launched an Action Plan for financing sustainable growth.\textsuperscript{17} This has a number of related aims from the redirection of capital towards sustainable investments, to bringing sustainability into risk management and promoting both transparency and long-termism. The plan has four legislative aspects: - to reduce the incidence of greenwashing by developing a taxonomy regulation defining what are environmentally sustainable economic activities — this will apply to all who offer financial products in the EU and those larger companies falling under the Non-Financial Reporting Directive (NFRD), which is soon to be reformed (see below); - a disclosure regulation (or SFDR) to require institutional investors and asset managers that manage money or advise on investments to disclose how they integrate ESG factors into their risk processes and how their investments affect ESG factors; - amendments to the EU Benchmarks Regulation to create a new low-carbon and positive carbon impact benchmarks, allowing investors to understand the carbon impact of their investments; and - amendments to investment and insurance sector legislation to require investment firms and insurance distributors to include ESG considerations in their advice to clients as well as obtaining their preferences. While some countries and regions are taking initiatives that complement those of the voluntary private sector, the European Union is pursuing a wider ranging and more prescriptive approach.\textsuperscript{16} DISCLOSURE REGULATION The SFDR applies to institutional investors and asset managers such as banks, investment firms and insurers alongside pension trustees, AIFMs and UCITS Mancos. They must make detailed “entity level” disclosures on their websites on the basis of double materiality — i.e., on the one hand how they manage ESG related risks that could have a material financial impact on their investments or the investments underlying their advice, and on the other hand, how their investment decisions or investment advice materially and negatively affect ESG factors (the so-called “principal adverse sustainability impacts” — or PASI — disclosure). In addition, they must make pre-contractual disclosures with specific requirements applying to products that actively promote environmental aims or have social characteristics — so-called Article 8 products, and those having sustainable investment or a reduction in carbon emissions as their explicit objective — Article 9 products. Some in the industry have complained about a lack of clarity between the two categories.$^{18}$ The regulation has applied from 10 March 2021, although unhelpfully as discussed below detailed technical standards have only recently been finalised, which illustrates the political pressure on governments to press ahead with a sustainability agenda.$^{19}$ As for entity level disclosures, the Commission suggests that relevant financial institutions can comply in the meantime by making use of the rules in the existing NFRD or other international standards.$^{20}$ Additionally, institutions falling under the SFDR are concerned that the time-line for their reporting requirements and the disclosures required by corporates under the NFRD (and its successor) are not aligned leaving them reliant on general sector information and proxies. It is important to remember it is not only businesses within the EU that will be affected by these disclosure requirements. All those offering financial products on the European market and those falling under the NFRD will have to comply. NON-FINANCIAL REPORTING DIRECTIVE The NFRD covers large companies and groups across the EU, including listed companies, banks and insurers. Since 2018 it has required non-financial disclosure in annual reports about how they operate and manage social and environmental challenges. While the Commission has published guidelines on the disclosure of ESG-related information seeking to align them with the TFCD recommendations — companies may use any international (e.g., the UN Global Compact and OECD), EU or national guidelines when reporting.$^{21}$ The EU Commission has published proposals to revise and strengthen the NFRD upgrading it to form a Corporate Sustainability Reporting Directive (CSRD) — following the results of a consultation held last year.$^{22}$ In line with respondents’ suggestions are the use of a common standard to ease issues with comparability of information, requiring digital disclosures and expanding its ambit to catch more companies (e.g. large non-listed companies). There will also be separate, proportionate, but voluntary standards for non-listed SMEs. Importantly, the CSRD introduces an EU-wide “limited” assurance requirement for sustainability information.$^{23}$ TAXONOMY The EU taxonomy regulation is a first serious attempt by government to regulate disclosure not against a financial requirement or risk measure but against a sustainability target. Companies and issuers will access finance for economic activities that are consistent with moving to carbon neutral by 2050. Apart from climate change, it seeks to capture sustainability more holistically, including other environmental objectives (e.g. the protection of water and marine resources, the circular economy, pollution prevention and control and bio-diversity) as well as social aspects. To be aligned with the taxonomy, an economic activity must make a substantial contribution to one of six environmental objectives, for example, climate change mitigation or adaption, and it needs to avoid significant harm to the others. It must also meet minimum social safeguards (e.g., no forced or child labour).\textsuperscript{24} Finally, the economic activity must meet technical screening criteria, to be adopted in the form of binding technical standards to take effect from January 2022 onwards. Recommendations for the technical screening criteria for climate change mitigation and climate change adaptation were first developed by a Commission-appointed Technical Expert Group (TEG) (predecessor to the current Platform on Sustainable Finance). While the final criteria for these two objectives were supposed to be finalized by end of 2020, the political debate has been intense and a Delegated Act has only recently been agreed by the Commission. Notably, questions around the taxonomy-alignment of agriculture, nuclear energy and a possible transition for fossil gas have been postponed. The technical screening criteria are intended to be updated over time, in line with technological developments, with the EU Platform for Sustainable Finance being tasked with advising the Commission on this regular review and update process. Despite Brexit, the UK, host of COP26, has committed to implementing a taxonomy based on the EU taxonomy, but adapted for UK markets.\textsuperscript{25} Recognising the importance of a globally consistent approach for international financial markets, the EU and China under the auspices of the International Platform for Sustainable Finance (IPSF) are reportedly developing a common taxonomy.\textsuperscript{26} The platform is a multi-national forum for co-operation between policymakers to which the UK, EU, China and 15 other jurisdictions belong representing 55% of global greenhouse gas emissions. Although the US may join in 2021 and it accepts a taxonomy is required, a decision is yet to be taken on whether to develop its own or work with other countries.\textsuperscript{27} Improved transparency and standardisation in taxonomies and reporting will help promote sustainable investment. It also recognises that cross-border investment requires the assessment of investee companies by investors in third countries and vice versa. A set of generally accepted international reporting standards would make this process quicker, cheaper and easier. While the EU’s ESMA argues that global and EU-specific standards are not contradictory but potentially complementary, it favours modular international standards which build on TFCD and EU requirements recognising that countries are at different stages of progress, rather than introducing common minimum standards.\textsuperscript{28} Nonetheless, the EU considers that the CSRD sustainability reporting standards to be developed by the European Financial Reporting Advisory Group (EFRAG) should build on and contribute to standardisation initiatives. Sustainability risks for financial institutions PRUDENTIAL REQUIREMENTS FOR BANKS AND INSURERS Banks and especially insurers are susceptible to three main types of risk from climate change. First, physical risks such as natural catastrophes damaging property or those that disrupt supply chains. Second (and ironically), risks arising from the transition to a lower-carbon economy, when carbon-intensive financial assets are revalued. Finally, risks from third-party liability claims by those who suffer loss and damage from climate change and then seek to recover from others (e.g., corporate D&O cover). As a result, climate change poses significant risks to prudential soundness — or balance sheets. In the case of insurers, there is the challenge of pricing policies to reflect adequately these new risks while also ensuring they hold both sufficient, resilient assets against liabilities that may not materialise for decades. Regulators are increasingly focusing on these issues as part of their prudential supervision and of course, managed properly, ESG can help filter long-term risks to improve investment returns. ESG DISCLOSURE AND REPORTING REQUIREMENTS Financial institutions and especially, those who manage and advise on investments, in an increasing number of jurisdictions must make a variety of public and pre-contractual disclosures around their approach to ESG. These need to be ‘clear, fair and not misleading’ as the UK’s conduct regulator would state. At its most basic, a misleading name for an investment fund using the word green or climate. Also as a result of emerging regulations affecting credit rating agencies, the rating process will increasingly require a consideration of sustainability risk to be assessed in a formal manner. Similarly, for larger issuers, regulations affecting how benchmark providers must construct ESG-aligned benchmarks, and an assessment of sustainability risk. While the proposed EU taxonomy will bring more consistency, it is complex requiring legal and technical expertise to be compliant. CORPORATE GOVERNANCE ASPECTS RELATING TO SUSTAINABILITY Those financial institutions that are also public companies, should consider how their public statements about ESG priorities align with their approach to managing sustainable investment strategies. They may choose to disclose against TCFD recommendations that cover an organisation’s governance, their strategy over potential climate-related impacts and risk management together with metrics and targets to assess and manage risks and opportunities. LITIGATION AND REGULATORY ENFORCEMENT RISK When making ESG disclosures, it is important to understand the associated litigation and regulatory enforcement risk relating to ESG factors, and mitigation strategies through relevant contractual terms. Financial institutions may incur liability where ESG statements are misleading or their activities contribute to climate change. Potential issues include: - inadequate due diligence around ESG statements contained in public company disclosures; - inaccurate disclosure and inappropriate sales practices by asset managers over ESG investments, including deceptive "greenwashing" that exaggerates the ESG qualities of an investment; - financial intermediaries facing claims that ESG-related investments are not suitable, or that they did not conduct appropriate due diligence on the investments they promote and sell; and - claims action against financial intermediaries and trustees for breach of fiduciary standards when selecting and monitoring retirement plan investments. In common with other businesses, financial institutions also risk potential anti-trust claims where they come together to collaborate over ESG commitments. Care and advice is required over competition law compliance to avoid unintended consequences, especially as rules may vary from country to country. The data dilemma: due diligence requirements around ESG To perform quality due diligence is always important. For ESG-driven investments, the stakes are particularly high. Should issues emerge subsequently, such as the existence of egregious practices or greenwashing, the reputational damage can be much higher than compared to regular investments. For these reasons, ESG due diligence should involve a comprehensive and holistic evaluation around a business or financial product. Moreover, a thorough analysis is required to confirm the degree of compliance with relevant frameworks and standards. Historically, a lack of data and the necessary tools to interrogate it was a significant hurdle for ESG. Early approaches to ESG due diligence were based on exclusionary screening and value judgements. Nowadays there are a wide number of non-financial metrics, methodologies and approaches and increased levels of disclosure.\textsuperscript{31} For example, there are indices that measure performance against Paris Agreement aligned benchmarks. ESG rating products can spot risks not identified with conventional financial analysis, which nonetheless could impact on financial performance because of additional operational costs or litigation liabilities. Ratings should focus on those risks most relevant to an industry sector (financial institutions having their own specific exposures), although corporate governance risk is common to all businesses. An analysis will look at how an organisation is managing its ESG risks drawing on a wide range of public data giving an indication of its performance in comparison to its peers. Those businesses or products that appear as outliers may justify further investigation. It is important to receive information on an ongoing basis to judge performance against sustainability criteria. Of course, the dilemma is that ESG ratings are still open to interpretation being only as good as the methodology and the data employed, although the amount of data is rapidly increasing, as is the technological power (e.g. artificial intelligence) necessary to interrogate it. There remain, however, significant gaps with investors not receiving all the information they need. Ratings also rely on public information so their outputs will necessarily be subject to data gaps. Again, they also have very different methodologies potentially giving rise to wide variations in ratings for the same company.\textsuperscript{32} Moreover, while matters are improving, there is often a lack of independent verification of accuracy and few regulatory requirements, although levels of scrutiny are rising.\textsuperscript{33} Recent incidents have seen constituent issuers of sustainable funds experiencing, for example, controversies over their supply chains with their market value impacted accordingly. Preferring sustainable lending and investment: from Green bonds to Impact Investment Sustainable finance refers to any form of financial service or product that integrates ESG criteria into business, financing or investment decisions. Financial institutions face increasing commercial and competitive pressure to prefer sustainable lending and investments. Financing is needed to fund sustainability-related projects — not just those focused on reducing carbon emissions, but other initiatives that improve social outcomes such as affordable housing and smart cities. To channel such investments efficiently, investors are looking for sustainable finance instruments that they understand and that meet their risk profiles, underpinned by commercially-attractive projects that deliver measurable and verifiable sustainability outcomes. Since 2015 we have seen a dramatic growth in the issuances of green and social bonds together sustainability-linked loan and bonds. Moreover, surveys show that the number of asset managers allocating a substantial share of their portfolios to sustainable investments is rising rapidly. Around 30 percent of global assets under management — around USD 31 trillion — are now ESG-principled investments and this figure will only rise. In addition, the listing of many top fund managers means that they are now subject to public company requirements on ESG matters — hastening the inclusion of ESG in the investment process. It is fair to say that asset managers in Europe have to date embraced ESG to a greater extent than their equivalents in the US and Asia-Pacific but this may change with the Biden Administration. Banks and insurers are similarly under pressure to avoid financing carbon heavy industries in preference of sustainable lending and investment. A number have announced that they will in due course cease to finance coal projects. NGOs and activist shareholders are calling for the publication of strategies with targets to reduce exposure to fossil fuel assets on timelines set out in the Paris Agreement. Some insurers through their asset management arms have committed to divestment from all companies obtaining more than 5% of their revenue from carbon sources unless they have joined the Science-Based Targets Initiative with a view to transitioning away. Illustrative of the actions of regulators, the Bank of England has set a June 2021 deadline to carry out stress tests on the financial sector to establish how well it can withstand climate change-related shocks. It is fair to say that until recently private equity had trailed other sectors in terms of taking into account ESG matters when allocating capital. However, such terms are now a key requirement of many limited partners. Increasingly, they have the right to walk away if ESG investment mandates are breached, while portfolio companies can obtain improved financing terms depending on their ESG performance. Private equity is sponsoring impact funds to focus on investments with an explicit focus on creating social or environmental benefits. These funds often base their approach on the PRI and many advisors are in the market offering their services to build metrics to measure their impact. COVID-19 and the acceleration of capital to sustainable investments 2020 saw a strengthening of the financial sector’s commitment to change similar to that of energy intensive industries such as oil. There is anecdotal evidence that ESG funds suffered less from COVID-19 inspired market volatility on financial markets. Due to concerns, for instance, over supply chain issues, demand for investments that reflect social and governance standards has significantly increased.\textsuperscript{37} Funds with above-average sustainability ratings saw big inflows and now hold USD 4.6 trillion in assets globally.\textsuperscript{38} There is a growing body of empirical evidence to show that sustainable investment goals can be aligned with and support the performance of a business. This is due to a number of factors such as improved employee productivity, mitigated risk potential and investment optimisation. As an example, data suggests that sustainability can be profitable with exchange-traded funds focusing on socially responsible investments enjoying 43% higher fees than standard ETFs.\textsuperscript{39} Academic evidence also supports the argument that the return on investment can be higher when ESG considerations are factored into the decision making process.\textsuperscript{40} More generally, therefore, corporates that have stronger, more resilient business models, especially as regards their ESG footprint, may represent better value investment to financial institutions in the longer term. Technology and investment funds: how is technology driving the green agenda To pursue ESG friendly investments, financial institutions, and especially, asset managers must analyse large amounts of unstructured and incompatible data. It is here that technology can help. In the context of continuing pressure on margins in the fund management industry, AI could be the new competitive differentiator.\textsuperscript{41} As to the data dilemma over ESG due diligence requirements, AI can help make sense of unstructured and incompatible data sets allowing asset managers to review and score for ESG risk. It can help counter greenwashing by assessing data quality and excluding unreliable sources. The technology can potentially even analyse the commitment of corporate leadership to ESG by evaluating the “sentiment” of their public pronouncements and the extent to which previous goals have been achieved. In this way, more effective research to obtain better insights will improve investment decision-making. It will inform investment strategies that could achieve more alpha for investors. It should also go to developing cheaper and more tailored investment strategies and portfolios for clients, a key want especially among millennials. 1 Speech by Mark Carney, Breaking the tragedy of the horizon – climate change and financial stability, 29 September 2015. 2 [The ESG Global Survey, 2019](#) 3 United Nations, Global Compact, Short-Termism in Financial Markets [site accessed 19 April 2021]. 4 United Nations, The Paris Agreement, 2015. 5 World Economic Forum, The Global Risks Report 2020. 6 Financial Times, Climate change: asset managers join forces with the eco-warriors, 26 July 2020; Larry Fink’s 2021 Letter to CEOs. 7 Speech by Mark Carney, Breaking the tragedy of the horizon – climate change and financial stability, 29 September 2015. 8 United Nations, Principles for Responsible Investment. 9 Funds Europe, Let’s dispel a few myths, October 2020. 10 Nikhil Rathi, FCA, Speech, Green Horizon Summit: Rising to the Climate Challenge, 9 November 2020. 11 Gov.UK, Chancellor sets out ambition for future of UK financial services, 9 November 2020. 12 IOSCO, Sustainable Finance and the Role of Securities Regulators and IOSCO, April 2020. 13 Impact Management Project, Statement of intent to work together towards comprehensive corporate reporting, September 2020. 14 U.S. Department of Labor, New Investment Duties Rule, 23 June 2020. 15 SEC, Speech, A Climate for Change: Meeting Investor Demand for Climate and ESG Information at the SEC, 15 March 2021. 16 IFRS Foundation, Consultation Paper on Sustainability Reporting, September 2020. 17 European Commission, Sustainable Finance [visited 12 February 2021]. 18 Risk.net, EU fund managers confused by new ESG designations, 28 January 2021. [No link] 19 Baker McKenzie, EU Sustainable Finance Disclosure Regulation – How does it affect the Swiss Market?, 23 November 2020. 20 See Directive 2014/95/EU. [No link] 21 European Commission, Guidelines on non-financial reporting: Supplement on reporting climate-related information, 20 June 2019. 22 European Commission, Summary Report of the Public Consultation on the Review of the NFRD, 29 July 2020. 23 European Commission, Press Release, Sustainable Finance and EU Taxonomy, 21 April 2021. 24 OECD Guidelines on Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. 25 Gov.UK, Chancellor sets out ambition for future of UK financial services, 9 November 2020. 26 Speech, IOSCO Chair and Head of HK Securities and Futures Commission, Climate change and finance, 11 February 2021. 27 FT, John Kerry warns EU against carbon border tax, 12 March 2021. 28 ESMA, Steven Maijor, The three (apparent) paradoxes of sustainability reporting and how to address them, 8 December 2020. 29 PRA, The impact of climate change on the UK insurance sector, September 2015. 30 Money Marketing, ESG: The adviser’s dilemma, 20 November 2020. 31 Boffo, R., and R. Patalano (2020), ESG Investing: Practices, Progress and Challenges, OECD Paris. 32 FCA Speech, Richard Monks, Building trust in sustainable investments, 23 November 2020. 33 FT Adviser, ESG needs its own due diligence, 15 April 2019. 34 Baker McKenzie, Sustainable Finance, A Growth Opportunity for Business, 2020. 35 Financial Times, Climate change: asset managers join forces with the eco-warriors, 26 July 2020. 36 Blackpeak, Private Equity and ESG, 29 June 2020. 37 BusinessGreen, How COVID-19 is refocusing sustainable finance, 16 April 2020. 38 Bank of England, Speech by Andrew Hauser, Exec. Director, Markets to Investment Association, 16 October 2020. 39 Wall Street Journal, Tidal Wave of ESG Funds Brings Profit to Wall Street, 16 March 2021. 40 Khan, Mozaffar N, George Serafeim, and Aaron Yoon, Corporate Sustainability: First Evidence on Materiality, Harvard Business School Working Paper, No. 15-073, March 2015. 41 IOSCO, The use of artificial intelligence and machine learning by market intermediaries and asset managers, June 2020. The Resilience, Recovery & Renewal Model Our Resilience, Recovery & Renewal model is helping organizations navigate the business and legal impact of the COVID-19 pandemic. While most businesses will pass through all three phases of the model, the phases themselves are non-linear and may recur or overlap, particularly for those with global operations. Wherever you are in your response to the pandemic, we will help you with the services and resources you need. Visit our Resilience, Recovery & Renewal Roadmap to Stability hub for more information. Also, visit our 3R Resource Center for the latest legal and regulatory updates from around the world. Baker McKenzie helps clients overcome the challenges of competing in the global economy. We solve complex legal problems across borders and practice areas. Our unique culture, developed over 70 years, enables our 13,000 people to understand local markets and navigate multiple jurisdictions, working together as trusted colleagues and friends to instill confidence in our clients. bakermckenzie.com © 2021 Baker McKenzie. All rights reserved. Baker & McKenzie International is a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a “partner” means a person who is a partner or equivalent in such a law firm. Similarly, reference to an “office” means an office of any such law firm. 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Washington County COVID-19 Hospitality Industry Recovery Program (CHIRP) FULL PROGRAM GUIDELINES Introduction The Commonwealth of Pennsylvania has allocated $145 million to counties for a grant program to provide financial relief to businesses with a primary activity in NAICS Code subsector 721 (Accommodations) and 722 (Food Service and Drinking Places). The COVID-19 Hospitality Industry Recovery Program (CHIRP) was created by legislation (Senate Bill 109, now known as Act 1 of 2021) and signed by Governor Wolf on Friday, February 5th, 2021. Washington County has received approximately $2.3 million in funding to provide grants to eligible businesses through this program. The eligibility, application requirements, program design, and program administration are all developed from the text of Act 1 of 2021. The application window for this program will open at Noon on Monday, March 15 th , 2021 and remain open until all available grant funds have been awarded, as stipulated by the legislation. The Washington Industrial Development Corporation (WIDC), an affiliate of the Washington County Chamber of Commerce, was selected by the Washington County Commissioners to serve as the administrative entity for this program as a Certified Economic Development Organization (CEDO). The WIDC has partnered with the Mon Valley Alliance (MVA), another Washington County CEDO, to execute the program. While every effort has been made to draft these guidelines in conformity with Act 1 of 2021, any discrepancies between these guidelines and the statute should be resolved in favor of the legislative language. Program Eligibility Eligible applicants must meet the following criteria: - Applicants may only apply for one CHIRP grant, even if they have multiple locations inside or outside Washington County, PA. o A single entity with multiple locations, such as an incorporated business owning two coffee shops located in Washington County, may only apply and utilize grant funds as a single entity for both businesses located in Washington County, PA. o A single entity with multiple locations in different counties, such as an incorporated business owning two coffee shops across two counties, may only apply and utilize grant funds as a single entity and should apply in the county where the incorporated business entity is headquartered. - Applicants must have a business located in Washington County, PA that was in operation as of February 15, 2020, remains in operation, does not intend to permanently cease operations within one year of the date of application, and, if required, paid income taxes to the Federal and State Government, as reported on individual or business tax returns. - Applicant business is not a publicly traded entity. - The primary activity of the applicant business within the Commonwealth of Pennsylvania has a NAICS designation within the Accommodation subsector (721) or Food Services and Drinking Places subsector (722) and where accommodations, food or drink is served to or provided for the public, with or without charge. o A full description of the eligible businesses and business activity under NAICS subsector 721 and 722 can be found at: https://www.census.gov/naics/. o Primary activity is defined as the primary means by which the business generates revenue. For example, a business that serves food, but is a venue engaged primarily in another activity, such as a movie theater, would not be eligible to apply. - Applicant business has fewer than 300 full-time equivalent employees as of February 15, 2020. - Applicant business has a maximum tangible net worth of not more than $15,000,000 computed in accordance with generally accepted accounting principles, as of February 15, 2020. - Applicant business must be able to demonstrate and document a negative financial impact from COVID-19 of at least 25% revenue loss, defined as a reduction in revenue in calendar year 2020, in one of the following ways (please note: applicants will need to submit appropriate supporting documentation): o a. The applicant had gross receipts during the first, second, third or fourth quarter in calendar year 2020 that demonstrate at least a 25% reduction from the applicant's gross receipts during the same quarter in calendar year 2019. The applicant will need to submit a 2019 tax return and a Profit & Loss statement from a quarter in 2019 and the corresponding quarter in 2020 to meet the requirements of this criteria. o b. If the applicant was not in business during the first or second quarter of calendar year 2019 but was in business during the third and fourth quarters of calendar year 2019, the applicant had gross receipts during the first, second, third or fourth quarter of calendar year 2020 that demonstrate at least a 25% reduction from the applicant's gross receipts during the third or fourth quarter of calendar year 2019. The applicant will need to submit a 2019 tax return and a Profit & Loss statement from a quarter in 2019 and the corresponding quarter in 2020 to meet the requirements of this criteria. o c. If the applicant was not in business during the first, second or third quarter of calendar year 2019, but was in business during the fourth quarter of calendar year 2019, the applicant had gross receipts during the first, second, third or fourth quarter of calendar year 2020 that demonstrate at least a 25% reduction from the fourth quarter of calendar year 2019. The applicant will need to submit a 2019 tax return and a Profit & Loss statement from a quarter in 2019 and the corresponding quarter in 2020 to meet the requirements of this criteria. o d. If the applicant was not in business during calendar year 2019, but was in operation on February 15, 2020, the applicant had gross receipts during the second, third or fourth quarter of calendar year 2020 that demonstrate at least a 25% reduction from the gross receipts of the entity during the first quarter of calendar year 2020. The applicant will need to submit a Profit & Loss statement from the first quarter of 2020 and from either the second, third, or fourth quarter in 2020 that demonstrates a 25% or more revenue loss. o e. An applicant that was in operation in all four quarters of calendar year 2019 is deemed to have experienced the revenue reduction in subparagraph (a) if the applicant experienced a reduction in annual receipts of at least 25% in 2020 compared to 2019 and the applicant provides copies of its annual 2019 and 2020 Federal tax forms substantiating the revenue decline. - If an applicant changed ownership or control in calendar year 2020, the applicant may measure its reduction in revenue in calendar year 2020 under any of the above using the gross receipts of the entity for 2019. o *PLEASE NOTE: As this is a competitive grant program, applicants are strongly encouraged to submit a full 2019 and full 2020 Profit & Loss [P&L] statement and 2019 tax returns to demonstrate the total revenue loss if the business was in operation for all of 2019 and 2020. Please note, the eligibility parameters for this program are based on Act 1 of 2021 as signed into law by Governor Wolf on February 5th, 2021. Grant Awards & Eligible Use of Grant Funds Grant awards will be determined based upon eligible operating expenses. Act 1 of 2021 requires grants to be awarded in increments of $5,000. Washington County has decided to cap grants at a maximum of $25,000 to benefit a greater number of companies while still providing an impactful benefit to eligible businesses. Eligible applicants must submit documentation to justify their grant request in full up to $25,000. The WIDC may determine the amount of funds awarded to be less than the amount an applicant applies for and the legislation requires that awards must be made increments of $5,000. As an example, if an eligible applicant submits an application with $17,600 in eligible expenses the grant award would be for a maximum of $15,000. Grant funds may be used for eligible expenses incurred and paid between March 1, 2020 up to the date of application. Eligible expenses are defined as an operating expense, including a payroll and non-payroll expense that is both ordinary and necessary. An ordinary expense is one that is common and accepted in an eligible applicant's industry. A necessary expense is one that is helpful and appropriate for an eligible applicant's trade or business. For purposes of determining an eligible operating expense, the following limitations shall apply: - For a mortgage obligation, the mortgage must have been in force before February 15, 2020. - For rent, under lease agreements, the lease agreement must have been in force before February 15, 2020. - For utility costs, service must have been activated before February 15, 2020. - If an existing mortgage obligation or lease agreement in force before February 15, 2020, is refinanced or restructured after February 15, 2020, the mortgage obligation or lease agreement is deemed to have been in force before February 15, 2020. Awardees must certify that grant funds are not being used for any eligible operating expenses that are impermissible per Act 1 of 2021, as described below, in addition to any other prohibitions detailed in the program guidelines and program grant agreement: - Eligible operating expenses for which an eligible applicant receives or received payment, reimbursement, and/or loan forgiveness from the following sources: o Any Washington County CARES Grants received in 2020 or 2021. o Any PA Small Business Grant Program of 2020 administered by the CDFI Network. o Any forgiven portion of federal SBA EIDL and/or PPP funds. o Any of public sector funding due to COVID-19 from any sources public or private between March 1st, 2020 through the date of application for this program as described in Act 1 of 2021. Application Process and Requirements To apply, eligible businesses will be required to complete an online application – the online application and other program information can be found at www.WashCoGrant.com. The online application will be available at 12:00pm (noon) on Monday March 15th, 2021; applications may not be submitted online prior to this specified date and time. Applications will be accepted until all grant funds have been awarded. This is not a first come, first served/funded program; applicants should take time to ensure they have all materials required to apply before submitting an application and submit a thorough, thoughtful, and accurate application. Applicants will be required to provide general information including, but not limited to, the following: - Physical location and business contact Information. - Mailing address of the business. - Applicant entities primary business activity (for eligibility purposes). - Number of employees. - Information on other business relief dollars received due to COVID-19. - Amount of grant dollars being requested for consideration. - 2019 and 2020 Profit & Loss statements - federal tax returns Applicants will be asked to provide brief narrative responses to the following questions: - Basic Description of the business, including how COVID-19 has impacted the business and how the business has adapted. - List of eligible operating expenses for reimbursement from CHIRP grant. Documentation should be submitted through the application website via the online application and applicants will be required to provide all the following documentation, as described below: - 2019 Federal Tax Return for the Applicant Entity. - Proof of financial impact due to COVID-19. Please refer to the "Program Eligibility" section of this document to determine the required documentation based upon your response to the application question regarding financial impact. Grant applications will also require acknowledgements and good faith certifications to be considered a completed application for submission and review. Applications will be reviewed on a rolling basis. It is expected that it will be several weeks before the first grant awards are announced. As grant awards are determined, grant awardees will receive an email from the WIDC to begin the contracting and disbursement process. Once all grant awards have been awarded, an email will be sent to all applicants regardless of award determination, to inform everyone that the process is complete. During the review period, applicants should keep the following in mind: - Submission of an application is not a guarantee of funding. - The program is not a first come, first served/funded program. This project was financed by a grant from the Commonwealth of Pennsylvania Department of Community & Economic Development - Please do not email or submit questions asking for an update on the status of or feedback on a particular application. This information will not be provided. - If the review team needs additional information or explanation, applicants will be contacted directly. Award of Grant and Grant Contracting Completed applications will be reviewed and considerations for grant awards will be based on satisfaction of eligibility criteria and meeting program guidelines. Additional priority will be given to applications that: - have not received a loan or grant issued under the authority of the Commonwealth or the Commonwealth's political subdivisions or by the Federal Government under the CARES Act or Consolidated Appropriations Act, 2021; - were subject to closure by the proclamation of disaster emergency issued by the Governor on March 6, 2020, published at 50 Pa.B. 1644 (March 21, 2020), and any renewal of the state of disaster emergency; or - can demonstrate a reduction in revenue which meets one of the following: o (A) A reduction in gross receipts of 50% or more for the period beginning after March 31, 2020, and ending before December 31, 2020, in comparison to the period beginning after March 31, 2019, and ending before December 31, 2019. o (B) If the eligible applicant was not in operation during the entire comparison period under clause (A), but was in operation on February 15, 2020, a monthly average reduction in gross receipts of 50% or more for the period beginning after March 31, 2020, and ending before December 31, 2020, in comparison to the period beginning after January 1, 2020, and ending before April 1, 2020. Overall evaluation of need and grant award decision criteria will include: - Complete and thorough application. - Well explained and demonstrable need due to COVID-19 disruptions. - Achieves program goal(s) based on economic impact of the applicant entity and sector. - Supports the economy of our communities Applicants awarded grant funding will be contacted via email by the WIDC and required to sign a grant agreement, certification form and provide any additional necessary documentation as part of the award and disbursement process. Upon execution of the grant agreement, certification form and any additional necessary documentation and it being returned to the WIDC, efforts will be made to disburse funds as soon as possible. Grant fund disbursement will be done by Washington County. 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Crisis News Release — SVC Writing for PR FOR IMMEDIATE RELEASE Sightseeing Plane Carrying Cruise Ship Passengers Crashes in Southeast Alaska Seattle, WA (June 16, 2016) -‐-‐ A sightseeing plane carrying eight passengers from the ms Westerdam, a Holland America Line cruise ship, crashed in Southeast Alaska. Nine people aboard, including the pilot, were killed. The plane, operated by Promech Air, was on a sightseeing tour of the Misty Fjords. It is not immediately known what caused the crash, which happened about 20 miles north of Ketchikan, Alaska. Holland America said that the passengers were on a seven-‐day cruise aboard the ms Westerdam, which left Alaska on June 20. Clint Johnson, head of the National Transportation Board's Alaska office, said that it was too early to determine what caused the crash. It is unknown whether the DeHaviland DHC-‐3 Otter turboprop experienced a mechanical malfunction that caused it to crash, or if limited visibility caused it to fly into the mountainside. The plane had been reported missing after failing to return to port on time. A helicopter search team spotted the wreckage of the plane on a granite rock face of a cliff 800 feet above Ella Lake. The plane was severely damaged and initial contact with the downed plane determined that there were no survivors. The crash site is located in steep, mountainous terrain which, along with poor weather conditions, prevented the rescue team from immediately recovering the bodies. Another attempt to reach the crash site will be made Friday. The NTSB is sending its Alaska team to investigate the crash-‐-‐the "go-‐team" will include three members from Alaska and at least two people from Washington, D.C. "At this moment, all of us share in the pain and anguish of this terrible event. There is nothing I can say that can alleviate the overwhelming sense of loss that we and the loved ones of those affected are feeling," Marcus Sessoms, president of Promech Air, said in a statement. Stein Kruise, chief executive of Holland America Line said, "We are incredibly distressed by this situation, and our thoughts and prayers are with those onboard the plane and their families." Holland America Line is extending its full support to traveling companions of the guests involved. The names of the victims are being withheld until their families have been notified.	<urn:uuid:6bf6f5e3-e599-4291-bc6e-a23743e154b5>	CC-MAIN-2019-09	http://cynthiamullis.com/design/wp-content/uploads/2015/03/Mullis_svcPR_crisisRelease.pdf	2019-02-24T03:25:06Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-09/segments/1550249578748.86/warc/CC-MAIN-20190224023850-20190224045850-00170.warc.gz	69,051,053	1,978	eng_Latn	eng_Latn	0.999302	eng_Latn	0.999302	[ "eng_Latn" ]	false	rolmOCR	[ 2375 ]
Study highlights barriers to treating breast cancer among women in Doha Posted by Qatar is Booming on Jul 12, 2011 in Healthcare \| 0 comments A study recently published in Avicenna, an open access peer reviewed journal from QScience.com and headed by Dr. Tam Truong Donnelly of the University of Calgary-Qatar, revealed that women in Qatar often seek medical treatment for breast cancer symptoms in late stages of the disease. The study highlights a direct statistical link between early detection of breast cancer by prescreening and improved prognosis and shows a low rate of participation in prescreening among Arabic women in Qatar. The Qatar-based research team has embarked on a three-year investigation of local mindsets and ways to encourage more prescreening among women in Qatar and the Middle East. Commenting on the study, Dr. Donnelly said that “It is widely understood throughout the medical community and many parts of the world that early detection greatly improves the prognosis in breast cancer patients,” he added that “We want to understand why women in Qatar are not aware of or participating in prescreening activities and what culturally-appropriate and effective strategies will help change this.” According to the study, the causes of breast cancer can be many and are difficult to assess case-by-case. In addition to genetic predisposition, the rising incidence rate in Qatar may be associated with lifestyle factors such as fatty diets, physical inactivity, smoking, and low rate of breastfeeding. “Over the past decade, Qatar has undergone tremendous change socially,” Dr. Donnelly said, adding that “Adoption of a western lifestyle as well as improvements in healthcare and other health services have been an important factor in the increase in the disease. In any case, we need to do more to help promote healthy lifestyles and to learn how mortality rates among women here are facing a great threat.” Joining Dr. Donnelly in the study are is Chairman of Hamad Medical Corporation’s Medical Research Center Dr. Al-Haseeth Al-Khater, from the Supreme Council of Health; Dr. Mohamed Al Kuwari, Executive Director of HMC’s Department of Nursing; Dr. Nabilia Al-Meier, Senior Consultant of hematology/oncology at Al-Amal Hospital; Dr. Salha Bugassoum, Director of Primary Health Care at Qatar’s Supreme Council of Health; Dr. Maryam Abdul Malik, Senior Consultant at HMC’s Medical Research Center; Dr. Rajvir Singh, Research Associate at the University of Calgary-Qatar Floor Christia-de Jong and a team of research assistants. The team will conduct phase one of the study over three years, which began in March of 2011. The team aims to gather interview data to better understand the breast health experience of Arabic women and to find effective ways to promote breast cancer screening in Qatar. Following that, the team will look into implementing strategies that assist women in participating in breast cancer screening techniques: self examination, clinical examination, and mammogram that are shown to markedly improve the chance of early detection and similarly the prognosis among those breast cancer patients. In the final stage, the team will monitor the effectiveness of the strategies and further facilitate them in order to sustain and increase participation of Arabic women in breast cancer screening. “Through talking with the women in Qatar and learning about their level of awareness and their thoughts around breast cancer and its screening, we hope to educate and transform fears into a sense of ownership and showing them that their actions can save their lives, that the disease is not the only deciding factor in survival,” Dr. Donnelly said. In addition to talking with the women, Arabic men and health care providers in Qatar will also be asked to provide information on how best to support women to combat breast cancer. Breast cancer is the most common type of cancer worldwide and the incidence is increasing, according to the study. The study also sites statistics from Qatar’s National Cancer Disease Registry and the WHO showing that breast cancer is by far the most common cancer among women in Qatar and that the incidence and mortality rates are higher than any other type of cancer in the country. While the increase in breast cancer in developed countries has risen markedly over the past several decades, the study showed that in these countries it has stabilized or risen only slightly in recent years. Yet the rate in Middle Eastern countries continues to rise, and Qatar is no exception, falling only slightly behind Kuwait and Jordan and significantly surpassing rates in Saudi Arabia and Yemen.	<urn:uuid:f78d9693-cac6-445d-92bb-7aa0f168266e>	CC-MAIN-2019-04	http://www.tamtruongdonnelly.com/docs/media-reports/Qatar-is-Booming-20110712.pdf	2019-01-24T10:14:10Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-04/segments/1547584520525.90/warc/CC-MAIN-20190124100934-20190124122934-00498.warc.gz	385,087,983	898	eng_Latn	eng_Latn	0.998629	eng_Latn	0.998629	[ "eng_Latn" ]	false	docling	[ 4673 ]
Victor Roudometof and Vasilios N. Makrides (eds), Orthodox Christianity in 21st Century Greece: The Role of Religion in Culture, Ethnicity and Politics (Ashgate, Aldershot and Burlington, VT, 2010), 274 pp., ISBN 978-0-7546-6696-7 (Hbk), £55.00 Many scholars continue to view Orthodoxy and Greece through the prism articulated by Huntington in his Clash of Civilizations. But his view is too general, better suited to a global strategic thinker. The editors of this volume offer a potent antidote. The end result is a solid contribution to the European sociology of religion: the Church as an institution; Church–state relations; pluralism and treatment of religious minorities in Greece; and the role of faith in constructing and defending national identity. Writing with clarity and precision, the authors debunk two prevalent myths regarding Church–state–society relations. First, there is a clear distinction between modernizers and traditionalists, with the Church officially assuming the role of guardian of tradition. Much ink is spent on the late Archbishop Christodoulos, exposing an intriguing and paradoxical figure. On the one hand, Christodoulos uses his position to defend ‘Greekness’ against the threat of globalization, European policy directives and ‘national alienation’ (p. 33). On the other hand, under his leadership the Church deploys very modern instruments to reach the public by reinvigorating non-public mechanisms of welfare. provision (Fokas), permitting Christian rock bands such as the Free Monks (Molokotos-Liederman), rethinking the position of women in Orthodoxy (Sotiriou), and revisiting the Church’s stance on non-Orthodox minorities in Greece (Yannas and Antoniou). As Roudometof and Anastassiadis show in their respective chapters, nationalist rhetoric and support for localism serve a modernizing purpose. ‘For militant church reformers, facing internal opposition’ and seeking ‘to modernize a fragile and staggering church … finding an external adversary … is the key to survival, if not success’ (p. 57). Second, the Church is an institution unlike others, not only substantively but also organizationally. In an interesting chapter, Makrides discusses the implications of the 2005 ‘crisis’ (in truth more of a corruption scandal) on the Church and Church–state relations. What emerges from the analysis is an institution, albeit privileged, that seems remarkably similar to others. It is rife with intra-organizational conflict, spiritual as well as political disagreements, centralizing and controversial decision-making tendencies and some corrupt individuals who take advantage of their position to pursue personal agendas. These are normal pathologies of any bureaucracy, including the bureaucracies of other religions. What is interesting are the political repercussions at a time when Archbishop Christodoulos sought a more publicly visible and influential Church in Greece. Because of his sympathies for the Right, mostly politicians and intellectuals of the Left used the allegations against Church officials and individuals close to Christodoulos as payback to undermine his political ambitions. Reacting against Christodoulos’s ‘expressive interventionism’, opponents sought to discredit his personality and behaviour by pointing out extravagant vacations, links to individuals of dubious reputation, and unwillingness to punish wrongdoers until after scandals hit the morning papers. For political reasons, even the most virulent critics were careful to make their opposition personal and not institutional. Their main point was to suppress any ‘gains’ the Church had made among Greek voters in the aftermath of the identity cards crisis in 2000, to ‘prove the state’s superiority over the church … and to weaken its wide social influence’ (p. 61). But one may ask: doesn’t undermining the leader of the Church also undermine the institution itself, because the leader represents the institution? Haven’t the scandals, especially the more recent one about Vatopedi—which the authors do not address—shaken trust in the institution and leaders of the Church? Don’t these ‘personal’ attacks aim to reconfigure political–institutional relations? Can they ever be just personal? What would have made this otherwise satisfying volume even better is the presence of a theoretical framework that ties the chapters together. Edited volumes usually suffer from the absence of a central argument, and this book is no exception. The value of individual contributions is significant but the absence of a framework reduces its overall utility and generalizability. For example, the editors and Stathopoulou argue that Greece is not exceptional. Well said, but then why is Greece theoretically important, and why does it not differ from other European countries? Without an overall framework that places groups within and across societies in particular categories, it is very difficult to distil the argument’s implications for modernity and its ability to be replicated substantively in similar cultural settings, such as those of Serbia or Bulgaria, or ostensibly dissimilar settings, such as those of Germany or Italy. The authors succeed admirably in exploring the role of Orthodox Christianity in twenty-first-century Greece, but the book on Orthodox Christianity in twenty-first-century Europe still remains to be written. Nikolaos Zahariadis Department of Government University of Alabama at Birmingham, 410 HHB, 1530 3rd Avenue South Birmingham, AL 35294-1152, USA © 2012, Nikolaos Zahariadis http://dx.doi.org/10.1080/19448953.2012.747875	<urn:uuid:4ecbe330-b6e1-4008-b719-8aeac2101762>	CC-MAIN-2017-43	http://roudometof.com/docs/orthodox_christianity_21st_century_journal_balkan_eastern_studies.pdf	2017-10-23T22:20:10Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-43/segments/1508187826840.85/warc/CC-MAIN-20171023221059-20171024001059-00561.warc.gz	284,691,851	1,143	eng_Latn	eng_Latn	0.973185	eng_Latn	0.994999	[ "eng_Latn", "eng_Latn", "eng_Latn" ]	false	docling	[ 1458, 5079, 5598 ]
Athens, September 27 th 2021 Announcement of regulated information N. 3556/2007 According to Law 3556/2007 and the Article 19 of Regulation (EU) 596/2014, it is notified that Sterner Stenhus Greece AB, an entity closely related with the President of the Board of Directors of "PREMIA SOCIETE ANONYME" (the "Company"), Mr. Elias Georgiadis, on 24/9/2021 acquired 23,000 shares of the Company with a total price of 34,352.77 euros and an average acquisition price of 1,4936 euros per share.	<urn:uuid:2aa21c04-741b-4318-872d-ac4e990af7ef>	CC-MAIN-2022-49	https://www.premia.gr/wp-content/uploads/2021/11/Announcement_of_Regulated_Information_27092021.pdf	2022-12-02T00:30:01+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2022-49/subset=warc/part-00076-a0906200-461b-4808-9b94-6c53daf73f61.c000.gz.parquet	1,016,590,391	144	eng_Latn	eng_Latn	0.921148	eng_Latn	0.921148	[ "eng_Latn" ]	false	rolmOCR	[ 490 ]
Guerriero, C; Cairns, J; Perel, P; Shakur, H; Roberts, I; on behalf of CRASH 2 trial collaborators, (2011) Cost-Effectiveness Analysis of Administering Tranexamic Acid to Bleeding Trauma Patients Using Evidence from the CRASH-2 Trial. PloS one, 6 (5). e18987. ISSN 1932-6203 DOI: https://doi.org/10.1371/journal.pone.0018987 Downloaded from: http://researchonline.lshtm.ac.uk/767/ DOI: 10.1371/journal.pone.0018987 Usage Guidelines Please refer to usage guidelines at http://researchonline.lshtm.ac.uk/policies.html or alternatively contact [email protected]. Available under license: http://creativecommons.org/licenses/by/2.5/ Cost-Effectiveness Analysis of Administering Tranexamic Acid to Bleeding Trauma Patients Using Evidence from the CRASH-2 Trial Carla Guerriero¹, John Cairns¹, Pablo Perel², Haleema Shakur², Ian Roberts², on behalf of CRASH 2 trial collaborators ¹ Department of Health Services Research and Policy, London School of Hygiene and Tropical Medicine, London, United Kingdom, ² Clinical Trials Unit, London School of Hygiene and Tropical Medicine, London, United Kingdom Abstract Objective: To assess the cost effectiveness of giving tranexamic acid (TXA) to bleeding trauma patients in low, middle and high income settings. Methods: The CRASH-2 trial showed that TXA administration reduces the risk of death in bleeding trauma patients with a small but statistically significant increase in non-intensive care stay. A Markov model was used to assess the cost effectiveness of TXA in Tanzania, India and the United Kingdom (UK). The health outcome was the number of life years gained (LYs). Two costs were considered: the cost of administering TXA and the cost of additional days in hospital. Cost data were obtained from hospitals, World Health Organization (WHO) database and UK reference costs. Cost-effectiveness was measured in international dollars ($) per LY. Both deterministic and probabilistic sensitivity analyses were performed to test the robustness of the results to model assumptions. Findings: Administering TXA to bleeding trauma patients within three hours of injury saved an estimated 372, 315 and 755 LYs per 1,000 trauma patients in Tanzania, India and the UK respectively. The cost of giving TXA to 1,000 patients was $17,483 in Tanzania, $19,550 in India and $30,830 in the UK. The incremental cost of giving TXA versus not giving TXA was $18,025 in Tanzania, $20,670 in India and $48,002 in the UK. The estimated incremental cost per LY gained of administering TXA is $48, $66 and $64 in Tanzania, India and the UK respectively. Conclusion: Early administration of TXA to bleeding trauma patients is likely to be highly cost effective in low, middle and high income settings. Trial Registration: This paper uses data collected by the CRASH 2 trial: Controlled-Trials.com ISRCTN86750102, Clinicaltrials.gov NCT00375258 and South African Clinical Trial Register DOH-27-0607-1919. Introduction The CRASH-2 trial showed that giving TXA to bleeding trauma patients results in a statistically significant and clinically important reduction in all-cause mortality (RR = 0.91, 95% CI 0.85 to 0.97), with no apparent increased risk of vascular occlusive events [1]. The trial inclusion criteria were clinical and did not depend on the results of laboratory tests. Patients were enrolled if they were judged by the doctor to have on-going significant haemorrhage, as evidenced by low blood pressure and a fast pulse, or if they were considered to be at risk of significant haemorrhage, for example, patients with compensated haemorrhage and stable vital signs, or those in whom bleeding might have stopped but who might start bleeding again following resuscitation. Further analyses have shown that the beneficial effects of TXA depend on the promptness with which TXA treatment is initiated. Early treatment, within about three hours of injury, appears to be more effective than later treatment. If administered within three hours TXA reduces the risk of death by 13% (RR = 0.87, 95% CI 0.81 to 0.95), while if TXA is administered after three hours it is not effective and can even been harmful [1]. On the basis of the CRASH-2 trial results, it has been estimated that the widespread use of TXA could save between 70,000 and 100,000 lives per year around the world. Because over 90% of trauma deaths are in low and middle income countries the potential for TXA to save lives is particularly high in these settings [2]. Nevertheless, TXA is unavailable in many low and middle income countries. Indeed, some hospitals in Africa that took part... in the CRASH-2 trial, have reported that TXA is unavailable for routine clinical use. In high income countries, due to the low cost of the intervention, TXA is likely to be highly cost effective. Although TXA is relatively inexpensive, evidence on the cost effectiveness of TXA in trauma is an important factor in the decision to include TXA on the WHO list of essential medicines. Economic evaluations of TXA in elective surgery show that TXA is a cost-saving intervention [3,4]. A recent study of the cost effectiveness of TXA in four Sub-Saharan countries shows that in countries where there is either a shortage of blood, or where blood is not properly screened, TXA can reduce mortality. In countries where blood is available, TXA can reduce blood borne infections [4]. The objective of the present study is to assess the cost effectiveness of giving TXA to bleeding trauma patients. The cost of TXA and its effectiveness will vary between countries. In Low Income Countries (LICs), TXA is likely to cost less than in High Income Countries (HICs) because both administration cost and cost per day in a general ward are lower. However, in both LICs and Middle Income Countries (MICs) life expectancies are shorter and there will be a lower number of life years gained per patient. Using World Bank country classification criteria, the cost effectiveness of TXA was evaluated in three countries: Tanzania (LIC with Gross Domestic Product (GDP) per capita $509; India (MIC with GDP per capita $1,134); and the UK (HIC with GDP per capita $35,165) [5]. Tanzania was chosen in order to assess the cost-effectiveness of TXA when income per capita and life expectancy are low [6,7]. India was selected because it is one of the MICs where TXA can avert the highest number of trauma deaths [2]. The UK was selected because within HICs it has an average GDP per capita and life expectancy. Materials and Methods* An economic evaluation was carried out to investigate the cost-effectiveness of administering TXA for the treatment of significant haemorrhage following trauma. Cost-effectiveness was measured by the incremental cost per life-year gained. The life-years gained are estimated from a simple Markov model where patients are either alive or dead, and by comparing the life-years experienced by a cohort who are given TXA with one that does not receive TXA. The model has an annual cycle and a lifetime horizon. Transitions between alive and dead in the first year are estimated from the CRASH-2 data, and in subsequent years from life tables. Life-years gained were discounted using an annual rate of 3.5%. The model was developed in Excel and STATA 11 software was used for the statistical analysis. The cumulative risk of death during the first year in the placebo arm was estimated using CRASH-2 data. After the first year, patients were assumed to experience the same probability of death as the general population of a similar age, estimated using country specific life tables from WHO [8]. Assuming that TXA is administered within three hours (because after this time it is unlikely to be effective), the risk of death in the first year after trauma in the intervention group was calculated by multiplying the baseline cumulative hazard of the placebo group by the relative risk reduction of all cause mortality estimated in the CRASH-2 trial (RR = 0.87, 95% CI 0.81 to 0.95) [2]. Beyond twelve months the risk of death in the intervention arm was assumed to be equal to the one estimated for the placebo arm. Since the CRASH-2 trial recorded data up to 28 days or death, a parametric survival function was fitted to extrapolate mortality experience over the twelve months following injury. Different parametric survival functions (Weibull, Gompertz, log-logistic, log-normal and generalised gamma) were compared using the Akaike Information Criterion (AIC), and Cox-Snell residuals were plotted as a confirmatory test [9]. The Gompertz model provided the best fit to the data. The Gompertz generic survival function is [9]: \[ S(t) = \exp(-\gamma^t \lambda(e^{\gamma t} - 1)) \] Where $t$ is the time-frame over which the cumulative probability of survival is estimated, $\gamma$ is an ancillary parameter that determines whether the hazard of death increases over time (if $\gamma$ is positive) or decreases (if $\gamma$ is negative). When covariates are considered in the analysis $\lambda$ is given by the following equation [9]: \[ \lambda = \exp(const + x_1 \beta_1 + x_2 \beta_2 + x_3 \beta_3) \] If data from the CRASH-2 trial are used the formula reported above becomes: \[ S(t) = \exp\left(-(-0.20)^{-1}\lambda(\exp^{-0.20t} - 1)\right) \] $\gamma (-0.20, 95\% \text{ CI } -0.21 \text{ to } -0.18)$ is negative meaning that after trauma the hazard rate decreases over time. Age, gender and GDP group were explored as covariates in the Gompertz model. A GDP per capita was assigned to each country in the trial according to the latest World Bank estimates and two binary variables, $X_2$ and $X_3$ were constructed to estimate whether the likelihood of death changes according to the GDP [6]. $X_2$ took the value 1 for LICs and 0 otherwise. Similarly $X_3$ took the value of 1 for MICs and 0 otherwise. As expected the baseline probability of death increases with age (age coefficient = 0.020, 95% CI 0.016 to 0.024) while gender was not found to be statistically significant $(-0.06, 95\% \text{ CI}-0.22 \text{ to } 0.11)$. Both GDP coefficients were found to be highly significant ($\beta_2 = -0.31; \beta_3 = -0.61$). Thus, the function for $\lambda$ is: \[ \lambda = \exp(-4.26 + 0.020 \times \text{Age} - 0.31 \times \text{LIC} - 0.61 \times \text{MIC}) \] Since the number of life-years saved will depend in part on the age of the patient, the aggregate effect across all trauma victims was estimated by first running the model for different age groups, and then calculating the average result. Five age groups were identified each representing a similar proportion of the total trial participants: 16 to 20 years; 21 to 25 years; 26 to 34; 35 to 50; and more than 50 years. Patients in each group were assigned a starting age equal to the mean observed for that age group in the trial. The cumulative hazard rate, the probability of death in the first year after trauma, was estimated for each of these five mean ages. The overall number of life years saved in each country was then calculated as a weighted average of the results for the five age groups using the age distribution for trial participants in countries of the relevant income group. Figure 1 shows the extrapolated hazard rate function during the first fifty days after trauma modelled from the observed 28 day data for the placebo group in the trial. The modelled hazard rate decreases to almost zero in the first 28 days after hospital admission and then remains constant. This finding is consistent with previous studies suggesting that the majority of trauma-related deaths occur within a few weeks after injury. The figure also validates the model assumption that after one year the baseline risk of death is the same observed in the general population [10]. The incremental cost of TXA versus no TXA was calculated from a health service perspective [11]. Two cost items were considered in the present study: the cost of administering TXA to bleeding trauma patients and the incremental cost of non-intensive care hospital stay. Given that costs associated with TXA administration occur within one year post trauma, costs were not discounted. Costs have been converted from national currencies into international dollars ($) using Purchasing Power Parities (PPPs) [12]. In the main analysis, the cost of TXA ($5.70 per g) was taken from the British National Formulary and converted into international dollars [13,14]. The same price was assumed for Tanzania and India in the absence of recent studies reporting the cost of TXA. The influence of different drug prices on the cost effectiveness of TXA was explored in one way and probabilistic sensitivity analyses. A dose of 2 g (1 g loading dose and 1 g maintenance dose) has been assumed as per the CRASH-2 trial protocol [2]. The CRASH-2 trial investigators estimate that the nursing time required to administer TXA ranges between 10–60 minutes. In Tanzania, a nurse’s salary depends on both rank and on the location of the hospital. It can range between $800 per month, for a principal nursing officer, to $300 per month, for a newly started nurse (2008-9 prices) [15]. For the analysis, an average salary of $450 per month, which is the salary of a nursing officer, is assumed [15]. Using this estimate the average cost per hour was estimated to be $2.40 (range:$1.60–$4.20) [15,16]. The average salary for a nurse in India varies by type of employer. Nurses working in public hospitals earn on average 30,000Rs ($2,044) per month while nurses employed in the private sector have a salary ranging between 7,000 and 10,500Rs per month ($480–$720) [17,18,19]. Assuming that a nurse works an average of 37.5 hours per week, the average cost per hour of a nurse in India was assumed to be $8.08 (range: $2.83–$14.06). In the UK, the average cost per hour of a nurse is $38 [13,20]. The disposables used for TXA administration are two 10 ml syringes, two green needles, two bags of saline (100 ml and 500 ml for loading and maintenance doses respectively) and an IV administration set [21]. The cost of a syringe and needle was obtained from the study by Dziekan et al. [22] who estimated the average unit cost of syringes and needles in different regions of the world. The cost of saline and an IV administration set was obtained from the British National Formulary and converted into international dollars [14]. Storage and distribution costs per intervention are negligible. The overall cost of administering TXA per patient is estimated to be: $17.48; $19.55; and $30.83 in Tanzania, India and the UK respectively. The improvement in survival following administration of TXA in the CRASH-2 trial was associated with a slight increase in the number of days spent in non-ICU hospital facilities (mean difference = 0.04, 95% CI 0.007 to 0.08, p = 0.0095). Since the incremental cost of non-ICU days associated with TXA will vary between countries, the mean length of stay of CRASH-2 patients in the placebo arm was calculated for low, middle and high income countries. As reported in Table 1, LICs patients tend to stay longer in the hospital. Table 1 shows the unit cost of a non-ICU day. For Tanzania and India these were taken from WHO-CHOICE and uplifted to 2008-9 estimates, while for UK they were taken from Reference Costs [23,24,25,26]. When more than one cost estimate was available per country, the average was used. Sensitivity analysis One way sensitivity analysis was undertaken in order to assess the impact of uncertainty regarding the input parameters. The incremental cost per life year saved for TXA versus no TXA was estimated for different values of the RR of death with TXA (95% CI 0.81 to 0.95) [2]. One way sensitivity analysis was also conducted on the increase in non-ICU hospital stay following TXA administration (95% CI 0.007 to 0.08). Due to the low cost of labour in both Tanzania and India, the drug cost constitutes almost 70% of the overall intervention cost. A cost-effectiveness analysis conducted by Casati et al. (1999) estimated that TXA would cost $2.57 per g, while a study conducted recently in India reported that TXA administration would cost $6.60 per g [27,28]. In order to account for price variability between countries Table 1. Resource use and Unit Costs. \| Resource Use and Unit Cost \| Tanzania \| India \| UK \| \|---------------------------\|----------\|-------\|----\| \| Resource use \| \| \| \| \| TXA dosage (gram) \| 2 \| 2 \| 2 \| \| 100 ml saline bag \| 1 \| 1 \| 1 \| \| 500 ml saline bag \| 1 \| 1 \| 1 \| \| Minutes spent by nurse preparing & administering TXA \| 21 \| 21 \| 21 \| \| Average number of non-ICU days \| 10 \| 7 \| 8 \| \| Unit Cost ($) \| \| \| \| \| TXA per gram \| 5.70 \| 5.70 \| 5.70 \| \| Nurse per hour \| 2.37 \| 8.08 \| 38 \| \| Syringes and needles \| 0.18 \| 0.19 \| 0.23 \| \| IV administration set \| 4.35 \| 4.35 \| 4.35 \| \| Non-ICU hospital cost per day \| 13 \| 28 \| 429 \| doi:10.1371/journal.pone.0018987.t001 The cost effectiveness of TXA was estimated assuming a price ranging between $2.57, from the Casati et al. study, and $45.67 estimated by Eaton et al. [29]. Finally one-way sensitivity analysis was performed to estimate how the TXA cost effectiveness changes according to different estimates of the cost of a non-ICU day. The lowest estimates, for both Tanzania and India, were the cost per day in a primary health centre ($9.84 and $18.75 respectively) while the highest estimates ($18.69 and $35.41) were obtained from tertiary hospitals [23,24]. In the UK, the minimum and the maximum non-ICU ward cost ($90–$784) were both obtained from UK reference costs [26]. Further sensitivity analyses were performed to evaluate how the results of the study change if different parametric distributions are adopted (Weibull, lognormal and log-logistic) when estimating survival beyond 28 days. Monte Carlo simulations were used to explore further the robustness of the estimated cost-effectiveness. Uncertainty in the data was captured by fitting probability distributions to each parameter. The Beta distribution was selected for binomial data. All cost parameters, were assumed to follow a Gamma distribution while a Log normal distribution was chosen for relative risk parameters. Lastly, to reduce the uncertainty in the estimated survival parameters, a Cholesky decomposition of the covariance matrix was used to ensure that the parameters of Gompertz parametric model, $\gamma$ and $\lambda$, were appropriately correlated on a log scale [30]. One thousand random samples were taken from all distributions and 1,000 estimates of the incremental cost, incremental life years saved and net monetary benefit were simulated. The probability that TXA was a cost-effective intervention was estimated by counting the proportion of simulations which produced positive net monetary benefits. Results were displayed with a cost effectiveness acceptability curve (CEAC) that shows the probability that the intervention is cost effective for different willingness-to-pay values for a life year saved. Results Base case analysis Giving TXA increases costs because of the TXA administration cost and the longer non-ICU hospital stay (Table 2). The incremental cost of TXA per 1,000 patients is $18,025, $20,670 and $48,002 in Tanzania, India and the UK respectively (Table 2). Life years saved were estimated taking into account the age distribution of the trauma patients. The number of life years saved depends on both the baseline risk of death after trauma and on the life expectancy. TXA would save 372 LYs per 1,000 patients in Tanzania (which has lower life expectancy but a higher baseline risk of death). While in India TXA would save 315 LYs per 1,000 trauma patients. In the UK, where life expectancy is high, TXA can potentially save 755 LYs per 1000 patients. The incremental cost per life year saved is $48, $66 and $64 for Tanzania, India and the UK respectively (Table 2). One way sensitivity analysis Results of one way sensitivity analysis are reported in Table 3. In all three countries, the price of TXA has a high impact on the cost effectiveness of the intervention. If the price of 2 g of TXA is $2.57 the cost-effectiveness of TXA would be $8 per LY (Tanzania), $12 per LY (India) and $26 per LY (UK). While, if TXA unit cost is $45.6 per patient, as suggested in the study conducted by Eaton et al. [29], TXA incremental cost per LY saved would be $124, $148, $86 in Tanzania, India and the UK respectively. Another important determinant of TXA cost effectiveness is the RR reduction associated with drug administration. If TXA was associated with a 19% reduction in the probability of death (lower bound of the 95% confidence interval) the incremental cost of TXA would be $33 in Tanzania, $45 in India and $43 in the UK. Neither the cost per day spent in a general ward, nor an increase in time spent in a general ward affect the cost effectiveness of TXA in Tanzania and India. In the UK, where the cost of a general ward is higher an increase in the mean length of non-ICU hospital stay would have a greater effect on the incremental cost-effectiveness ratio. The selection of the parametric distribution with which to extrapolate survival beyond study follow up can influence significantly the results of a cost effectiveness analysis [31]. The AICs and the Cox-Snell residual plots indicated that the Gompertz model was the best-fitting model (e.g. the AICs were 10087 Table 2. Cost, Effectiveness and Cost-effectiveness of TXA in Tanzania, India and the UK. \| Item \| Tanzania \| India \| UK \| \|-------------------------------------------\|------------\|----------\|----------\| \| Non-ICU hospital stay ($) \| \| \| \| \| TXA \| 135,183 \| 213,435 \| 3,272,416\| \| No TXA \| 134,641 \| 212,315 \| 3,255,244\| \| TXA administration cost ($) \| \| \| \| \| TXA \| 17,483 \| 19,550 \| 30,830 \| \| Overall incremental cost ($) \| \| \| \| \| TXA \| 18,025 \| 20,670 \| 48,002 \| \| Life years gained discounted \| \| \| \| \| TXA \| 13,079 \| 18,176 \| 24,162 \| \| No TXA \| 12,707 \| 17,861 \| 23,407 \| \| Incremental life year saved \| \| \| \| \| TXA \| 372 \| 315 \| 755 \| \| Incremental cost per life year saved ($) \| \| \| \| \| TXA \| 48 \| 66 \| 64 \| per 1,000 patients. doi:10.1371/journal.pone.0018987.t002 (Weibull), 9997 (lognormal), 10064 (log-logistic) and 9459 (Gompertz)). Using different parametric distributions produced higher cumulative baseline hazards at one year and consequently lower cost per life year saved. For instance, the incremental cost per life year saved is $31, $37 and $34 in Tanzania, India and the UK respectively if a Weibull parametric function were to be adopted. The modelled gain in life years with the Gompertz model owes very little to the extrapolation beyond 28 days, the cost per life year saved increases from $48.4 to $48.6 (Tanzania), from $65.6 to $65.8 (India) and from $63.5 to $63.8 (UK). Probabilistic Sensitivity analysis* The CEAACs in Figure 2 show the probability that TXA will be cost effective for a range of willingness-to-pay values. Because of the cost of administering the drug and the incremental non-ICU stay, the routine administration of TXA is never a cost saving intervention. For any given willingness to pay between $25 and $250 there is a greater chance of TXA being cost-effective in Tanzania than in India or the UK. Overall, TXA is likely to be a cost effective intervention even if the willingness to pay for an additional life year saved is as low as $100. Discussion This study evaluated for the first time the cost effectiveness of giving TXA to bleeding trauma patients in the UK, India and Tanzania, using primary data from the CRASH-2 trial which provides the best source of scientific evidence that TXA reduces the probability of death after trauma worldwide. This evaluation suggests that TXA is not only life saving, as shown by the CRASH-2 trial, but also that it is a highly cost effective intervention if administered routinely to bleeding trauma patients in high, middle and low income countries [2]. Early administration (within three hours) of TXA would cost $48, $66 and $64 per LY saved in Tanzania, India and the UK respectively. According to the WHO Commission on Macroeconomics, healthcare interventions costing less than GDP per capita per Disability-Adjusted Life Year (DALY) averted should be considered “very cost effective” [32]. DALYs are a measure of the years of life lost from disease and years lived with a disability. According to the World Bank classification, GDP per capita in low income countries ranges from $380 to $975, in lower middle income countries between $976 and $3855, upper middle income between $3,856 and $11,905 and high income countries GDP above $11,906 [33]. Thus, if the life years saved by TXA are spent in perfect health (one LY saved is equal to one DALY averted) TXA is a highly cost effective intervention in all the countries considered. The sensitivity analyses presented reinforce this conclusion. However, a number of limitations should be considered when interpreting these results. It was necessary to model survival over 12 months using data for the first 28 days following the trauma and different statistical models will produce different estimates of benefit. However, different models were explored and the one selected as well as providing the best fit to the data also produced more realistic estimates of the impact on long term survival. In this evaluation those predicted to survive the first year following the trauma are assumed then to have the same life expectancy as members of the general population of similar age and gender. A related limitation is that the measure of incremental cost-effectiveness is cost per life year gained rather than cost per quality-adjusted life year (QALY) (a year in perfect health is considered equal to one QALY) gained or DALY averted. Depending on the extent to which these patients do not enjoy perfect health, the cost per QALY gained or the cost per DALY averted will be higher than the cost per life year saved. A further potential limitation is that the analysis does not allow for future health service savings. CRASH-2 showed that after 28 days the proportion of patients reporting no symptoms at discharge was significantly higher in the TXA group (14.7%) versus placebo (13.3%) (RR = 1.11, 95% CI 1.04 to 1.19, p = 0.0023) [2]. If TXA patients are more likely to survive without disability this study under-values the potential cost saving arising from the administration of TXA since healthier people will have lower future utilization of health care services. Identifying cost effective interventions to decrease the number of injury related deaths is a major public health challenge. According to the Disease Control Priority Project in 2001 unintentional injuries alone account for 6% of all deaths worldwide [34]. The majority of unintentional injuries-related deaths, more than 90%, occur every year in low and middle income countries posing a further financial burden on these countries’ economies and underfinanced health care systems [34]. This study suggests that TXA is a highly cost effective intervention in three very different settings. Given that TXA is effective and it is of relatively low cost it is not surprising that it is cost-effective in high income settings. However, it was important to demonstrate that it was likely to be cost-effective in countries with much more limited health care budgets, such as in Tanzania and India where due to the high numbers of trauma victims this simple intervention can avert thousands of deaths every year. Further research is needed to evaluate the effects of TXA on the quality of life of trauma patients. Acknowledgments The views and opinions expressed therein are those of the authors and do not necessarily reflect those of the Department of Health. Author Contributions Conceived and designed the experiments: CG JC HS IR. Analyzed the data: CG JC. Contributed reagents/materials/analysis tools: HS PP IR. Wrote the paper: CG JC IR. Interpretation of the analysis: CG JC HS PP IR. Played a role in the design and the execution of the study, and commented on the manuscript, with CG taking the lead: CG JC PP HS IR. References 1. Roberts I, Shakur H, Atolabi A, Brohi K, Coats T The effect of tranexamic acid on death due to bleeding: Time to treatment is critical. 2. CRASH-2 trial collaborators (2010) Effects of tranexamic acid on death, vascular occlusive events, and blood transfusion in trauma patients with significant haemorrhage (CRASH-2): a randomised, placebo-controlled trial. Lancet Jul 3;376(9734): 23–32. 3. Johansson T, Pettersson LG, Lsander B (2005) Tranexamic acid in total hip arthroplasty saves blood and money: a randomized, double-blind study in 100 patients. Acta Orthop 76: 314–319. 4. Gomes C, Cairns J, Jayasinghe S, Roberts I, Perel P, et al. (2010) Giving tranexamic acid to reduce surgical bleeding in sub-Saharan Africa: an economic evaluation. Cost Eff Resour Alloc 8: 1. 5. World Bank (2010) GDP (current US$). 6. World Bank (2010) Health Indicators. 7. World Bank (2010) Economic Policy and External Debt. 8. WHO (2010) Life Tables for Member States. 9. Mario Cleves, William W Gould, Roberto G Gutierrez, Marchenko Y, eds. An introduction to survival analysis using STATA 2nd Edition. 10. Tien P, Chu, Brezgerman F (2004) Causes of death following multiple trauma. Current Orthopaedics 18: 304–310. 11. National Institute for Clinical Excellence (NICE) (2008) Updated guide to the methods of technology appraisal. pp 29–49. 12. Penn World Table (2010) Purchaser Power Parities. In: University of Pennsylvania, editor. 13. OECD (2008) Purchasing Power Parities (PPP). 14. British National Formulary (2009). 15. Private Communication with Muhimbili National Hospital Tanzania (2010). 16. CIA (2010) The World Factbook. Country Comparison to the World. Inflation Rate (Consumer Prices). 17. Batalla JS, Meher MA (2010) Nursing a Foreign Dream Hindustan times. 18. GMC Christian Hospital India (2010). 19. Private Communication with Care Hospital India (2010). 20. Currie I. (2009). Unit costs of health and social care; Canterbury PSSRU, University of Kent, editor. pp 35–178. 21. Trials Co-ordinating Centre (LSHTM) (2009) CRASH 2 trial (Clinical Randomization of an AntiFibrinolytic in Significant Hemorrhage) and Woman trial (World Maternal AntiFibrinolytic Trial); London. 22. Dziekaa G, Chisholm D, Johns B, Rovira J, Hutin YJ (2003) The cost-effectiveness of policies for the safe and appropriate use of injection in healthcare settings. Bull World Health Organ 81: 277–285. 23. WHO-CHOICE (2005) United Republic of Tanzania. Estimates of Unit Costs for Patient Services for United Republic of Tanzania. 24. WHO-CHOICE (2005) India. Estimates of Unit Costs for Patient Services for India. 25. Bureau of National Statistics (2009) United States Department of Labor. Historical Consumer Price Index U.S. city average. 26. Department of Health, (2010) NHS reference costs 2008-2009. 27. Casan V, Guzzoni D, Oppizzi M, Cosolini M, Torri G, et al. (1999) Hemostatic effect of aspirin and tranexamic acid in coronary artery bypass grafting in primary cardiac surgery. Ann Thorac Surg 68: 2252–2256; discussion 2256–2257. 28. Rajkumar S, Maharaj M, Chandrabas R, Padhy RK, PV S (2005) Tranexamic acid in controlling the postoperative bleeding in open heart patients. Indian Journal of Thoracic Cardiovascular Surgery 2005: 207–211. 29. Eaton MP (2008) Antiﬁbrinolytic therapy in surgery for congenital heart disease. Anesth Analg 106: 1087–1100. 30. Briggs A, Claxton K, Sculpher M Decision Modelling for Health Economic Evaluation Oxford Handbook in Economic Evaluation Press OU, editor. 31. Gerdham UG, Zedrachus N (2003) Predicting survival in cost-effectiveness analyses based on clinical trials. Int J Technol Assess Health Care 19: 507–512. 32. Commission on Macroeconomics and Health (2001) Macroeconomics and health: investing in health for economic development. Geneva: World Health Organization. 33. World Bank (2010) Country Classification. 34. Robyn Norton, Adam A Hyder, David Bishai, Margie Peden (2006) Unintentional Injuries. Disease Control Priorities in Developing Countries (2nd Edition). New York: Oxford University Press, pp 737–754.	<urn:uuid:cb4e2eb5-2aa3-4f8b-960e-ac3877af2792>	CC-MAIN-2019-13	http://researchonline.lshtm.ac.uk/767/1/pone.0018987.pdf	2019-03-22T19:40:11Z	s3://commoncrawl/crawl-data/CC-MAIN-2019-13/segments/1552912202688.89/warc/CC-MAIN-20190322180106-20190322202106-00418.warc.gz	174,551,263	7,749	eng_Latn	eng_Latn	0.953261	eng_Latn	0.994928	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	docling	[ 642, 4609, 11930, 16282, 23079, 25135, 33143 ]
Carbonic-calcium system, nutrients and total organic nitrogen in continental runoff to the Galician Rías Baixas, NW Spain Fiz F. PÉREZ, Xosé Antón ALVAREZ-SALGADO, Gabriel ROSON, Aida F. RIOS Consejo Superior de Investigaciones Científicas, Instituto de Investigacións Mariñas, Eduardo Cabello, 6, 36208 Vigo, Spain. Received 6/02/92, in revised form 12/08/92, accepted 17/10/92. ABSTRACT Biogenic element levels in continental runoff and their behaviour during estuarine mixing are studied in the Galician Rías Baixas for the upwelling season (May-October). Alkalinity, calcium, both with average concentrations of about 350 μmol.kg$^{-1}$, and reactive silica, with 105 μmol.kg$^{-1}$, show near conservative distributions along the estuarine side of the rías. A good agreement was found between values obtained by direct measurement in the river and those calculated by extrapolation to zero salinity from the mixing diagrams. On the other hand, nitrate (10-40 μmol.kg$^{-1}$) and mainly phosphate (1 μmol.kg$^{-1}$) are strongly affected by the biological activity of benthic algae during estuarine mixing. TON and ammonium in the innermost parts of the Ría de Arousa are also determined. The levels and time variations of these variables are very similar between stations with different water bodies. They show a tendency to increase in time during summer (from 20 to 50 μmol.kg$^{-1}$ for TON and from 15 to 25 μmol.kg$^{-1}$ for NH$_4^+$) independent of the water body present in the column. Oceanologica Acta, 1992. 15, 6, 595-602. RÉSUMÉ Système carbone-calcium, éléments nutritifs et azote organique total (TON) dans les apports d'eau continentale aux Rías Baixas, nord-ouest de l'Espagne On étudie les concentrations d'éléments biogéniques dans les apports d'origine continentale et leur comportement pendant le mélange estuarien dans les Rías Baixas de la Galice au cours de la saison d'upwelling (mai-octobre). L'alcalinité, le calcium, présentant tous deux une concentration moyenne d'environ 350 μmol.kg$^{-1}$, et le silicate, avec 105 μmol.kg$^{-1}$, montrent une évolution quasi conservative dans la zone estuarienne des rías. De plus, une bonne concordance est obtenue entre les concentrations mesurées directement dans le fleuve et celles résultant de l'extrapolation des diagrammes de mélange au zéro de salinité. Cependant, les teneurs en nitrate (10-40 μmol.kg$^{-1}$) et principalement en phosphates (1 μmol.kg$^{-1}$) sont fortement influencées par l'activité biologique des INTRODUCTION The Rías Baixas comprise four coastal embayments into the Galician coast, NW Spain, which behave as partially mixed positive estuaries (Beer, 1983). Two sides, oceanic and estuarine, can be distinguished (Fig. 1). The former, with salinity over 30, is volumetrically dominant in the rías. The latter include only the innermost and shallowest areas, where salinity is lesser due to continental runoff. From May to October, an enhancement of the water interchange between the coastal shelf and the oceanic side due to wind-driven upwelling takes place. The colder nutrient-rich upper layer of the Eastern North Atlantic Central Water (ENAW) reaches the shelf and enters the rías, fertilizing them (Otto, 1975; Fraga, 1981; Blanton et al. 1987). As a result, upwelling is the main factor responsible for the high primary production found during spring and summer, from 700 to 1 200 mg C.m$^{-2}$.day$^{-1}$ (Prego, 1990), which supports the most intensive raft culture of edible mussels in the world (Tenore et al., 1982): 180 000 metric tons total wet weight during 1989, 90% from Ría de Arousa. The obvious economic interest of this large-scale mussel farming has stimulated detailed investigation of water fluxes and biogenic element budgets along the oceanic side of the rías. Since the first study for Ría de Arousa by Otto (1975) using a two-layer box model, some others have been carried out (González et al., 1979; Prego and Fraga, 1992; Ríos, 1992). In order to run such circulation models it is necessary to know in advance the continental runoff and its chemical composition. However, strong biogeochemical processes occur on the estuarine side of the rías (Margalef, 1958), especially due to the activity of benthic algae like Ulva and Fucus and the marine angiosperm Zostera (Niell, 1977). Consequently, biogenic element levels associated with continental runoff can be affected during estuarine mixing (Bennekom and Salomons, 1981) and, therefore, direct measurements in the river can be unsuitable to the budget in the oceanic side of the rías. The aim of this work is to establish the chemical composition of river inputs to the Rías Baixas and to determine how it is modified on their estuarine side during the upwelling season. Rivers Ulla and Umia, which enter the Ría de Arousa, and river Oitaben which enters the Ría de Vigo are studied (Fig. 1). Furthermore, the study will permit comparison of the Rías Baixas with other similar estuarine systems on the European Atlantic coast, away from industrial inputs. MATERIAL AND METHODS Sampling From May to October 1989, water samples were collected every fifteen days (4 and 17 May, 6 and 21 June, 5 and 19 July, 2 and 28 August, 13 and 27 September and 11 and 25 October) at the bridges of Catoira (E1) and Padrón (R1) on the River Ulla and the bridges of Cambados (E2) and Caldas de Reis (R2) on the River Umia (Fig. 1), in collaboration with the Departamento de Química-Física of the Universidad de Santiago. Stations E1 and E2 lie on the estuarine side of Ría de Arousa where salinity is always greater than 5. Station R1 is in the lower course of the river Ulla and, at high tide, salinity is less than 2. Station R2, in the middle course of the river Umia, does not show any direct marine influence. All stations are very shallow, no more than 2 m deep. Samples were collected near the surface. On the other hand, from January 1982 to November 1983, monthly samples from the River Oitaben were taken at Sotomaior (station R3), about 7 km from the river mouth. In addition, we use the data taken in San Simon Bay (Ría of Vigo) on 28 May 1983. The basins of the rivers Ulla, Umia and Oitaben have a total surface area of 2 925, 450 and 350 km$^2$ and average rainfalls of 1 600, 1 900 and 2 500 mm.year$^{-1}$, respectively. Mean annual fluxes are 100, 21 and 22 m$^3$.s$^{-1}$ respectively, although during summer they are less than 30 % of these values (Rosón et al., 1991; Rios et al., 1992). Analytical methods Salinity was calculated from conductivity measurements with an Autosal 8 400A (Unesco, 1981). Calcium was determined by potentiometric titration with a selective electrode, using EGTA as a complexing agent and borax as a buffer (Rosón and Pérez, 1991). Alkalinity was determined by potentiometric titration with HCl 0.13 N (Pérez and Fraga, 1987). Nutrient samples were frozen until they were analyzed by segmented flow spectrophotometric methods according to Hansen and Grasshoff (1983) with slight modifications (Mouriño and Fraga, 1985; Alvarez-Salgado et al., 1992) using a Technicon AAII. Total Nitrogen (TN) was determined for oxidation to nitrate with peroxidisulphate under UV light of a sample buffered with tetraborate also by Technicon AAII. The TON was calculated by subtracting the Total Inorganic Nitrogen (NO$_3^- + NO_2^- + NH_4^+$) to the TN. All concentrations are expressed in µmol.kg$^{-1}$. Data processing The simplest method of estimating the input of each biogenic element associated with continental runoff to a ría is the measurement of their concentrations at places close to the mouth of the river but away from marine influence. However, this method can be unsuitable for the budgets on the oceanic side of the rías because they may be altered on the estuarine side by biogeochemical processes. On the other hand, when measurements are carried out on the estuarine side, it can be assumed that the mixing of the continental and oceanic water bodies is linear with respect to a conservative parameter as salinity. The biogenic element vs. salinity plots can be a tool for understanding the behaviour of such elements during estuarine mixing. If the resulting curve is close to a straight line, they behave conservatively and the extrapolation to zero salinity of the data fitted by linear regression can be used to estimate the concentrations in the river. On the other hand, deviations from linearity can be due to variability in the river and ocean end members (Loder and Reichard, 1981) and/or uptake-recycling as a consequence of biological activity and water-sediment exchange. RESULTS AND DISCUSSION Carbonic-calcium system The variability of the carbonic-calcium system in the rías is due both to the photosynthesis-mineralization cycle and to the formation and dissolution of calcareous structures. As previously mentioned, on the oceanic side of the rías there are large numbers of mussel rafts which are capable of producing slight changes in the alkalinity and calcium distributions. To study these changes, it is necessary to take into account the runoff contributions, although these are very weak and furthermore decrease by dilution more than ten times in water of salinity higher than 33. The calcium and alkalinity vs. salinity plots on the estuarine side of the rías -stations E1, E2 and San Simón Bay-fall on straight lines with $r^2 > 0.90$ (Fig. 2), and consequently behave conservatively during estuarine mixing. The concentrations by extrapolation at zero salinity are very low compared with other Iberian rivers (Catalán, 1981) and similar to the average dissolved --- Figure 2 Alkalinity and calcium vs. salinity plots at stations E1 and E2 (May-October 1989) and in San Simón Bay (May 1983). Linear regression coefficients are expressed in the µM escale. Distributions de l'alcalinité et du calcium vs. salinité dans les stations E1 et E2 (mai-octobre 1989) et dans la baie de San Simón (mai 1983). Les coefficients des régressions linéaires sont donnés en µM. Table 1 Recorded averages, standard deviations, maximum and minimum values of salinity (USP), alkalinity, calcium, nitrate, phosphate and silicate (µmol.kg$^{-1}$) at the river stations R1 and R2 (Padrón and Caldas in the rivers Ulla and Umia respectively) from May to October 1989. Valeurs moyennes, déviation standard, maxima et minima de salinité (USP), alcalinité, calcium, nitrate, phosphate et silicate (µmol.kg$^{-1}$) dans les stations R1 et R2 (Padrón et Caldas dans les fleuves Ulla et Umia respectivement) de mai à octobre 1989. \| \| S \| Alk \| Ca$^{2+}$ \| NO$_3^-$ \| PO$_4$H$^{2-}$ \| SiO$_2$ \| NH$_4^+$ \| \|-------\|-----\|-----\|-------------\|------------\|------------------\|----------\|-----------\| \| R1\| \| \| \| \| \| \| \| \| Mean \| 0.478 \| 392 \| 200 \| 22 \| 0.39 \| 89 \| 11 \| \| Std \| 127 \| 180 \| 5 \| 0.48 \| 21 \| 16 \| \| \| Min \| 0.040 \| 146 \| 79 \| 12 \| 0.04 \| 63 \| 1 \| \| Max \| 1.941 \| 635 \| 614 \| 31 \| 1.79 \| 137 \| 16 \| \| R2\| \| \| \| \| \| \| \| \| Mean \| 0.020 \| 146 \| 35 \| 41 \| 2.5 \| 29 \| 13 \| \| Std \| 13 \| 1.3 \| 1.3 \| 14 \| 6 \| \| \| \| Min \| 0.010 \| 69 \| 9 \| 13 \| 0.04 \| 9 \| 5 \| \| Max \| 0.030 \| 254 \| 88 \| 57 \| 4.26 \| 54 \| 25 \| Contents of surface waters discharging to the ocean (Meybeck, 1981). Alkalinity shows standard deviations close to one-fifth of its values, while calcium concentrations are very higher. With regard to the concentrations obtained in the river basins during the same period (Tab. 1), at station R1 (river Ulla) the mean alkalinity (392 µmol.kg$^{-1}$) is similar to those obtained by extrapolation to zero salinity at E1 (364 µmol.kg$^{-1}$). However, the average alkalinity in the middle reach of the river Umia, station R2, is lower (146 µmol.kg$^{-1}$) than those obtained by extrapolation at E2 (325 µmol.kg$^{-1}$). This may be due to the fact that station R2 is far from the river mouth, about 20 km, and the drainage basin between R2 and E2 is not taken into account. Since the extrapolated values at E1 and E2, and the measurements made at R1 are not significantly different, an average alkalinity of 366 ± 91 µmol.kg$^{-1}$ is obtained for the continental runoff to Ría de Arousa by regression of all these data. On the other hand, the alkalinity in the river Oitaben (station R3) was 68 µmol.kg$^{-1}$ two weeks after sampling in San Simón Bay, where the calculated value by extrapolation to zero salinity was very similar (45 µmol.kg$^{-1}$), lower than those measured in the basins of the Ría de Arousa. Calcium at stations R1 and R2 shows large standard deviations (Tab. 2). The average values obtained in the river Ulla (200 µmol.kg$^{-1}$) are similar to those extrapolated to zero salinity at E1 (366 µmol.kg$^{-1}$). However, the average values at R2 (35 µmol.kg$^{-1}$) are lower than those obtained by extrapolation at E2 (273 µmol.kg$^{-1}$), E1, or that measured at R1. These were the same as we observe for alkalinity. Except for the R2 measurements, the average concentration of calcium in the continental runoff to Ría de Arousa is 0.3 ± 0.2 mol.m$^{-3}$. Rivers Ulla and Umia had a total average flow of 35 m$^3$.s$^{-1}$ (Rosón et al., 1991) from May to October 1989 (about 500×10$^6$ m$^3$) which means a total input of 5,800 tons of calcium, more than a half that withdrawn by mussels from the oceanic side of the ría, assuming that calcium represents 15 % of total wet weight of mussels (Rosón, 1992). Nutrients The nitrate vs. salinity plots of the data recorded at stations E1, E2 and in San Simón Bay are shown in Figure 3. At station E2, with $ r^2 = 0.97 $, a conservative mixing pattern can be observed and the nitrate extrapolated to zero salinity (42 µmol.kg$^{-1}$) coincides with the average concentration at station R2 (41 µmol.kg$^{-1}$). However, in San Simón Bay, and mainly at station E1, strong biogeochemical processes leads to a non conservative behaviour of nitrate, enhanced by low and variable concentrations in the rivers, as we shall see below. At stations R1 and R2, the minimum nitrate values were recorded in autumn, showing a standard deviation of 23 % and 32 % of the mean value, respectively (Tab. 1). At station R3 the average nitrate for the two years’ sampling is 11 µmol.kg$^{-1}$ with a standard deviation of only 4 (36 %). Maximum values were recorded in January and the two lowest values in September and June. Nitrate contributions of these Galician rivers to the oceanic side of the rías are relatively low: about 10 to 40 µmol.kg$^{-1}$. These values are much lower than those in other European rivers. Thus, Denant and Saliot (1990) give values of 74 to 134 µM in the Rhone delta describing a similar pattern with minimum values during autumn and a seasonal variation of about 30 %; Tréguer and Quéguiner (1989) show values between 90 and 464 µM (60 %) for the river Aulne. Although certain domestic inputs exist, Table 2 Average values of salinity and nutrients on the oceanic side of Ría de Arousa (station 01). Valeurs moyennes de salinité et des nutriments dans la zone océanique de la Ría de Arousa. \| \| S \| NH$_4^+$ \| TIN \| PO$_4$H$^{2-}$ \| \|-------\|-----\|------------\|-----\|-------------------\| \| 12 May\| 33.701 \| 0.74 \| 0.88 \| 0.20 \| \| 22 May\| 34.246 \| 1.48 \| 1.76 \| 0.36 \| \| 8 June\| 35.012 \| 1.17 \| 2.37 \| 0.41 \| \| 26 June\| 34.564 \| 1.80 \| 2.49 \| 0.64 \| \| 6 July \| 34.793 \| 0.47 \| 1.45 \| 0.34 \| \| 17 July\| 35.322 \| 1.15 \| 2.86 \| 0.25 \| \| 3 August\| 35.481 \| 1.08 \| 5.09 \| 0.49 \| \| 24 August\| 35.477 \| 1.22 \| 6.07 \| 0.64 \| \| 14 September\| 35.374 \| 1.12 \| 7.58 \| 0.69 \| \| 28 September\| 35.141 \| 1.70 \| 4.29 \| 0.57 \| \| 13 October\| 35.466 \| 1.95 \| 7.92 \| 0.55 \| \| 27 October\| 34.791 \| 6.83 \| 10.52 \| 0.79 \| \| MEAN \| 34.95 \| 1.73 \| 4.44 \| 0.50 \| \| STD \| 0.54 \| 1.59 \| 2.91 \| 0.18 \| these findings indicate the "quasi-unpolluted" character of the rivers studied (Meybeck, 1982). With regard to reactive silica, this behaves conservatively and gives high correlation coefficients and similar y-axis intercept values vs. salinity for the three estuarine areas (Fig. 3): 119, 113 and 103 μmol.kg⁻¹ for rivers Ulla, Umia and Oitabén, respectively. The values recorded directly in the river are slightly lower at R1 (89 μmol.kg⁻¹), and much lower at R2 (29 μmol.kg⁻¹). From May to October 1983 the average value of reactive silica at R3 was 105 ± 36 μmol.kg⁻¹, and the value measured at the same time in San Simón Bay was 136 μmol.kg⁻¹, slightly higher than estimates by extrapolation. Pérez et al. (1987) calculated by extrapolation reactive silica concentrations of 95 μmol.kg⁻¹, for the continental input to the Ría de Vigo. Therefore, excepting again R2 values, the continental input to the Rías Baixas has a mean Si (OH)₄ concentration of 105 μmol.kg⁻¹. These results are somewhat higher than those in the river Rhône, 50 to 80 μmol.kg⁻¹ (Denant and Saliot, 1990). These high reactive silica values are a consequence of the geological composition of the Galician river basins, and are practically unaffected by biological activity on the estuarine side of the rías, leading to the conservative behaviour of this nutrient during estuarine mixing. At E2, except for samples taken on 19 July, 27 September and 25 October (represented by squares in Fig. 3), the phosphate shows nearly constant levels (0.9 ± 0.2 μmol.kg⁻¹). Thus the phosphate runoff contribution to the oceanic side of the rías seems to be small if the dilution is taken into account. Only when there is strong mineralization, independent of salinity, are the inputs significant from the estuarine side. Sampling in San Simón Bay was carried out at the end of May, during a period of high photosynthetic activity. Under these conditions, the silicate distribution in San Simón Bay testifies to biological activity at salinities above 26, where its concentration falls to zero. At salinity lower than 26, estuarine mixing is sufficiently rapid, with respect to photosynthesis, to maintain a conservative silicate distribution. Similar patterns occur with nitrate and phosphate plots (Fig. 3), showing good agreement in their y-intercept values with measurements in the river (13 and 0.05 μmol.kg⁻¹ of NO₃⁻ and HPO₄²⁻, respectively, 17 May 1982 at station R3). Nitrate seems to be the limiting nutrient on the more saline side of San Simón Bay. During spring, in the Rade de Brest, Tréguer and Quéguiner (1989) found a similar pattern in nitrate distribution. Nitrate stops behaving conservatively at salinities above 29. Furthermore, in the Rhône Delta, Denant and Saliot (1990) have shown a non-linear behaviour in the spatial distribution of nitrate, phosphate and silicate in May and October. They have also suggested that the loss of nutrients is due to uptake by biota. When nutrient vs. salinity plots do not fall in a straight line, as is the case at E1, anomalies from the conservative mixing line can be estimated from the salinity and nutrient values at E1, R1 and on the oceanic side of the ría, O1 (Tab. 2). Thus, for each measurement made at E1, the nutrient anomaly, &N, can be calculated (Liss, 1976) from equation (1). \[ \&N = [N]_{E1} - \frac{(S_{O1} - S_{E1})[N]_{R1} + (S_{E1} - S_{R1})[N]_{O1}}{S_{O1} - S_{R1}} \] (1) where $ S_{O1}, S_{E1} $ and $ S_{R1} $ are the salinities at stations O1, E1 and R1, and $ [N]_{O1}, [N]_{E1} $ and $ [N]_{R1} $ the nutrient The linear correlation between the data recorded at R1 and E1 is high, $r^2 = 0.88$, with a slope of 1.0. The TON values at E2 also show a high linear correlation with respect to those recorded at E1, $r^2 = 0.85$, where the slope is 1.2 (excepting 27 September). At R1, salinities are always less than 2, therefore only continental water exists. At E1, however, the range of salinity was from 8 to 24. Thus, it is very hard to explain why TON follows the same pattern at E1 and R1 when the TON input at R1 is strongly diluted at E1 by sea water. If the same levels and variations exist at the river and on the oceanic side of the rías, it would be possible to find the same global pattern at E1, R1 and R2. However this would imply that the effect on the nitrogen cycle is the same in different water columns. On the other hand, the tide seems to have some effect on the change in time of TON (Fig. 5 a). But, to analyse these processes, a more extensive study is necessary than that reported here. At the same time, ammonium at E1 correlates poorly with salinity ($r^2 = 0.02$), while there is a stronger correlation with &NO$_3$ ($r^2 = 0.48$). Furthermore, it shows a time variation similar to that of TON (Fig. 5 b) and the correlation between the data recorded at R1 vs. those at E1 is also high ($r^2 = 0.67$) with a slope of 1.1. Nitrite behaves similarly to ammonium ($r^2 = 0.76$ at E1), giving poor correlations with salinity. At E1 and E2 it shows a moderate correlation with phosphate ($r^2 = 0.60$). This behaviour of nitrogen compounds in the internal parts of the rías shows again that the distributions of TON, NH$_4^+$ and NO$_2^-$ are strongly influenced by biological activity of the estuarine and benthic biota. Their seasonal growth usually declines in late summer and autumn, and Figure 4 Temporal variations of PO$_4$H$^{2-}$, NO$_3^-$, and TIN anomalies with regard to theoretical mixing at E1. Variations temporelles de PO$_4$H$^{2-}$, NO$_3^-$, et des anomalies du TIN par rapport au mélange théorique en E1. concentrations at stations O1, E1 and R1, respectively. Actually, according to Loder and Reichard (1981), these anomalies also include the deviation from linearity due to the end-member variability. The change in time of these nutrient anomalies at E1 can be seen in Figure 4 (nitrite is included in the &NO$_3$ estimate). All samples at E1 show HPO$_4^{2-}$ and NO$_3^-$ values higher than those estimated by mixing (i.e. &N positive) except for NO$_3^-$ on 19 July and 23 August, when there were remarkable inputs of these nutrients to the water column. An important increase of nutrient concentrations during the late spring and autumn can be observed in this figure. &NO$_3$ and &PO$_4$ show a similar pattern of variation with a significant correlation between themselves ($r^2 = 0.56$). But, if we take into account the variation of the Total Inorganic Nitrogen (TIN) not due to estuarine mixing at E1, i.e. NH$_4^+ +$ NO$_3^- +$ NO$_2^-$, the correlation vs. &PO$_4$ is higher ($r^2 = 0.74$), giving a N:P ratio of 51 ± 8. In this sense, Faganeli et al. (1986) studied the C:N:P ratios of the benthic marine algae Ulva rigida and Fucus virsoides obtaining N:P ratios of 52 ± 22 for these algae in the Gulf of Trieste. Similar species of benthic algae have been described by Niell (1977) on the sheltered shore of the Ría de Vigo: Fucus spiralis, Fucus vesiculosus, Ascophyllum nodorum and Ulva sp. In the annual cycle of benthic algae, maximum biomass occurs during spring and decays during late summer and autumn. According to this - with the Loder and Reichard limitation - in our study the stronger recycling of nutrients seems to come from the mineralization of estuarine and benthic biota, chiefly in September and October. TON and ammonium Measurements of TON were also carried out at stations R1, E1 and E2. The levels and changes in time of TON recorded are very similar at the three stations (Fig. 5 a). Figure 5 Temporal variations of (a) TON and (b) NH$_4^+$ concentrations at stations R1, E1 and E2. Variations temporelles des concentrations en : a) azote organique total ; et b) ammonium dans les stations R1, E1 et E2. this can be produced over all the estuarine side of the rias where they account for an important amount of biomass. Furthermore these biological processes could increase dissolved organic matter as well as other nitrogen compounds in the water column during the biomass decay. However, the covariability found between nitrate and salinity at E2 indicate that the latter is also marked by the estuarine mixing process. CONCLUSIONS The main rivers that flow into the Galician Rías Baixas are characterized by very low alkalinity and calcium levels, both about 350 μmol.kg⁻¹, which behave conservatively during estuarine mixing. The input of calcium by runoff to Arousa from May to October 1989 represents 65% of the total amount uptake by mussel rafts on the oceanic side of the ría. These rivers, due to the mineralogical composition of their basins, have high silicate levels (about 100 μmol.kg⁻¹) which also behave conservatively during the mixing. The silicate input is about 9 Tm-Si.d⁻¹ and play an role on the diatoms dominance in the Rías Baixas (Margalef, 1958). On the other hand, the low nitrate (0.2-0.6 g-N.m⁻³ and 0.6-1.8 T-N.d⁻¹), and phosphate (0.02 g-P.m⁻³ and 0.06 T-P.d⁻¹) concentrations found are an indication of low industrial or agricultural pollution. The levels of these nutrient salts from late spring to autumn are mainly determined by a high biological activity, relatively similar from place to place, that can result in identical concentrations and time variations at stations with different water bodies. Acknowledgements This work was supported by grant number MAR88-245 of the Comisión Interministerial de Ciencia y Tecnología (CICYT). We thank Ramón Peñín for assistance with salinity analyses and in drawing the figures; and Ricardo Casal for his help with the sampling. We are grateful to two anonymous reviewers for their valuable comments. REFERENCES Alvarez-Salgado X.A., F. Fraga and F.F. Pérez (1992). Determination of nutrient salts by automatic methods both in sea and brackish water. The phosphate blank. Mar. Chem., 99, 311-319. Beer T. (1983). Environmental oceanography. Pergamon Press, Oxford, 262 pp. van Bennekom A.J. and W. Salomons (1981). Pathways of nutrients and organic matter from land to ocean through rivers, in: River Inputs to ocean systems. UNESCO, Paris, 33-51. Blanton J.O., K.R. Tenore , F. Castillojo, L.P. Atkinson, F.B. Schwing and A. Lavin (1987). The relation of upwelling to mussel production in the rias on th western coast of Spain. J. mar. Res., 45, 497-511. Catalán J. (1981). Química del agua. Bellisco, Madrid, 423 pp. Denant V. and A. Saliot (1990). Seasonal variations of nutrients (NO₃⁻, NO₂⁻, NH₄⁺, PO₄³⁻, Si(OH)₄) and suspended matter in the Rhone delta, France. Oceanologica Acta, 13, 1, 47-52. Faganell J., A. Vokovic , F.I. Saleh and J. Pezdic (1986). C:N:P ratios and stable carbon and hydrogen isotopes in the benthic marine algae, Ulva rigida C.Ag. and Fucus virsoides J.Ag. J. expl mar. Biol. Ecol., 102, 153-166. Fraga F. (1981). Upwelling of the Galician coast, Northwest Spain, in: Coastal Upwelling, F.A. Richards, editor. American Geophysical Union, Washington, 176-182. González N., JJ. González, C. García and J.M. Cabanas (1979). Dinámica de nutrientes en las Rías de Arosa y Muros (NW España). Boln Inst. esp. Oceanogr., 5, 51-79. Hansen H.P. and K. Grasshoff (1983). Automated chemical analysis in: Methods of seawater analysis, K. Grasshoff, M. Ehrhardt and K. Kremling, editors. Weinheim, 347-379. Liss P.S. (1976). Conservative and non-conservative behaviour of dissolved constituents during estuarine mixing, in: Estuarine Chemistry, J.D. Burton and P.S. Liss, editors. Academic Press, London, 185-218. Loder T.C. and R.P. Reichard (1981). The dynamics of conservative mixing in estuaries. Estuaries, 4, 1, 64-69. Margalef R. (1958). La sedimentación orgánica y la vida en los fondos fangosos de la ría de Vigo. Investigación pesq., Barcelona, 11, 67-100. Meybeck M. (1981). Pathways of major elements from land to ocean through rivers, in: River inputs to ocean systems. UNESCO, 18-32. Meybeck M. (1982). Carbon, nitrogen, and phosphorus transport by world rivers. Am. J. Sci., 282, 401-450. Mouriño C. and F. Fraga (1985). Determinación de nitratos en agua de mar. Investigación pesq., Barcelona, 49, 81-96. Niell F.X. (1977). Distribución y zonación de las algas bentónicas en la facies rocosa del sistema intermareal de las Rías Bajas Gallegas. Investigación pesq., Barcelona, 41, 219-237. Otto L. (1975). Oceanography of the Ría de Arosa (NW. Spain). Koninklijk Nederlands Meteorologisch Instituut, Mededelingen en Verhandelingen, 96, 210 pp. Pérez F.F. and F. Fraga (1987). A precise and rapid analytical procedure for alkalinity determination. Mar. Chem., 21, 169-182. Pérez F.F, Mouriño C. and Fraga F. (1987). Influencia de los efluentes terrestres en los nutrientes de la Ría de Vigo, IIº Seminario de Química Marina. Universidad de Cádiz, 73-82. Prego R. (1990). Las sales nutrientes en la rías gallegas. Infmes téc. Sci. mar., 157, 31 pp. Prego R. and F. Fraga (1992). A simple model to calculate the residual flows in a Spanish ría. Hydrographic consequences in the ría of Vigo. Estuar. coast. Shelf Sci., 34, 603-615. Ríos A.F. (1992). El fitoplancton en la Ría de Vigo y sus condiciones ambientales. Ph. D. Thesis, University of Santiago de Compostela, España, 416 pp. Ríos A.F., M.A. Nombela, F.F. Pérez, G. Rosón and F. Fraga (1992). Calculation of runoff to an estuary. Ría de Vigo. Sci. Mar., 56, 1, 29-33. Rosón G. (1992). Flujos y ciclo del carbonato cálcico en la Ría de Arosa. Ph. D. Thesis, University of Santiago de Compostela, España, 425 pp. Rosón G. and F.F. Pérez (1991). Determinación potenciométrica de calcio en agua de mar. Sem. qui. Mar., 5, 121-128. Rosón G., F.F. Pérez, X.A. Alvarez-Salgado and A.F. Ríos (1991). Flujos de los aportes de agua continental a la ría de Arosa. Sci. Mar., 55, 4, 583-89. Tenore K.L., L.F. Boyer, R.M. Cal, J. Corral, C. Gracía-Fernández, N. González, E. González-Gurriarán, R.B. Hanson, J. Iglesias, M. Krom, E. López-Jamar, J. McLain, M.M. Pamatmat, A. Pérez, D.C. Rhoads, G. de Santiago, J. Tietjen, J. Westrich and H.L. Windom (1982). Coastal upwelling in the Rías Bajas, NW Spain: contrasting the benthic regimes of the Rías de Arosa and Muros. J. mar. Res., 40, 3, 701-772. Tréguer P. and B. Quéguiner (1989). Seasonal variations in conservative and nonconservative mixing of nitrogen compound in a West European macrotidal estuary. Oceanologica Acta, 12, 4, 371-380. UNESCO (1981). Tenth report of the joint panel on oceanographic tables and standard. UNESCO tech. Pap. mar. Sci. 36.	<urn:uuid:8c9deeff-e94d-4972-941e-3e3b19798291>	CC-MAIN-2023-50	https://archimer.ifremer.fr/doc/00101/21184/18801.pdf	2023-12-04T20:33:31+00:00	s3://commoncrawl/cc-index/table/cc-main/warc/crawl=CC-MAIN-2023-50/subset=warc/part-00090-e565b809-b335-4c1d-90fd-54a9a2b7113d.c000.gz.parquet	124,105,299	8,935	eng_Latn	eng_Latn	0.745103	eng_Latn	0.935951	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "spa_Latn" ]	false	docling	[ 2530, 5701, 10100, 16651, 20232, 24447, 30063, 31211 ]
Code of Conduct For the Beverage Container Management Board Beverage Container Management Board CODE OF CONDUCT I. Preamble The Code of Conduct (Code) for the Beverage Container Management Board (BCMB) applies to all employees. The Code reflects a commitment to the BCMB's values and provides a framework to guide ethical conduct in a way that upholds the integrity and reputation of the BCMB. Employees are expected to behave in a way that aligns with this Code. They understand that this Code does not cover every specific scenario. Therefore, they use the spirit and intent behind this Code to guide their conduct, and exercise care and diligence in the course of their work with the BCMB. To demonstrate commitment to transparency and accountability, this Code is available to the public on the BCMB's website. II. Core Values a. Employees act with impartiality and integrity. b. Employees demonstrate respect and accountability. c. Employees strive for excellence in all aspects of their work. d. Confidentiality of information. III. Guiding Principles These principles guide the behaviour and decisions of employees: a. The Code applies to all employees. b. The actions and decisions of employees are made to promote the public interest and to advance the mandate and long-term interests of the BCMB. c. Employees are responsible stewards of public resources. d. To serve the public interest, employees have a responsibility to uphold the BCMB's mandate. e. Employees have a responsibility to act in good faith and to place the interests of the BCMB above their own private interests. f. Employees behave in a way that demonstrates that their behaviour and actions are fair and reasonable in the circumstance. g. Employees enjoy the same rights in their private dealings as any other Albertan, unless it is demonstrated that a restriction is necessary in the public interest. h. When an employee, as an individual, is subject to more than one code of conduct, the employee must consider the expectations in all. Employees understand that this Code is not intended to conflict with other Codes of Conduct, and will discuss any potential conflicts with their supervisor. i. Employees know that when they become aware of a real or apparent conflict of interest, they must at the first opportunity disclose this conflict to their supervisor. j. Employees understand that disclosure itself does not remove a conflict of interest. k. Employees encourage their colleagues to act fairly and ethically and know that they are able to raise concerns about a suspected breach by another to their supervisor without fear of reprisal. l. Employees know that breaches of this Code may result in disciplinary action, up to and including termination of the employee. m. Employees know that if they have any questions about the Code, or are not sure how to apply these principles, they should consult with their supervisor. n. Each employee confirms on an annual basis their understanding of, and commitment to the Code's expectations. IV. Behavioural Standards Behavioural standards help employees make appropriate decisions when the issues they face involve ethical, legal, or moral considerations. Behavioural standards cannot cover all scenarios but provide guidance in support of day-to-day decisions. All employees must adhere to the following standards: a. Employees must not engage in any fraudulent or criminal activity and comply with all relevant laws, regulations, policies and procedures. b. Employees must not use their status or position with the BCMB to influence or gain a benefit or advantage for themselves, their families, their business associates or others with whom they have a significant personal or business relationship. c. Employee conduct contributes to a safe and healthy workplace that is free from discrimination, harassment or violence. d. Employees must not use drugs or alcohol in a way that affects their performance and safety or the performance and safety of their colleagues, or that negatively impacts the reputation or operations of the BCMB. e. Employees must act in a way that is consistent with the BCMB's External Communications Policy. f. Employees must take reasonable steps to avoid situations where they may be placed in a real or apparent conflict between their private interests and the interests of the BCMB. In other words, actions or decisions that employees take on behalf of the BCMB must not provide them with an opportunity to further the private interests of themselves, their families, their business associates or others with whom they have a significant personal or business relationship. 1. Confidential Information Employees must respect and protect confidential information, use it only for the work of the BCMB and do not use it for personal gain. Employees must comply with protocols that guide the collection, storage, use, transmission and disclosure of information. 2. Gifts and Gratuities No gift or benefit of any kind, whether in the form of a payment of money, a loan, rebate, favour or otherwise, shall be given or received by any employee conducting business on behalf of the BCMB, where it might be perceived that an obligation is created or a favour is expected of the recipient. The giving and receiving of gifts or promotional items of modest value is permissible (under $100). Any such gifts or benefits offered or received must be disclosed to their supervisor. Employees must not accept or receive gifts and gratuities other than the normal exchange of gifts between friends or business colleagues, tokens exchanged as part of protocol or the normal presentation of gifts to people participating in public functions. 3. Outside Activities Employees must avoid participating in outside activities that conflict with the interests and work of the BCMB. For example: i. Business Interests: Employees must not hold interests in a business directly or indirectly through a relative or friend that could benefit from, or influence, the decisions of the BCMB. ii. Employment: Employees must not take supplementary employment that affects their performance or impartiality with the BCMB. iii. Political Activity: Employees may participate in political activities including holding membership in a political party, supporting a candidate for elected office or seeking elected office. However, they must not use their position with the BCMB to seek contributions for a political party or activity from current or future clients or entities doing business with the BCMB. In addition, any political activity must be clearly separated from activities related to the work for the BCMB, must not be done while carrying out the work of the BCMB and must not make use of BCMB facilities, equipment or resources in support of these activities. If an employee is planning to seek an elected municipal, provincial or federal office, they must disclose their intention in writing as soon as possible to their supervisor for guidance relating to their duties with the BCMB. iv. Volunteer Activity: If employees are involved in volunteer work, the activity must not influence or conflict with decisions relating to the BCMB. 4. Pre-Separation Employees considering a new offer of employment must be aware of and manage any potential conflicts of interest between their current position and their future circumstance, and must remove themselves from any decisions affecting their new employment. 5. Post-Separation Upon employee termination, the employee must not disclose confidential information, as per the signed confidentiality agreement, that they became aware of during their time with the BCMB and must not use their contacts with their former colleagues to gain an unfair advantage for their current circumstance. The employee must return all BCMB equipment assigned to them during employment upon terminating employment with the BCMB. 6. Social Media We encourage staff to keep their personal and professional life separate with regards to social media. Employees must not disclose confidential information or make any defamatory remarks on any social media site regarding the BCMB or the Alberta beverage container recycling system. This includes but is not exclusive to social media accounts such as Facebook, Twitter, or LinkedIn. 7. Conduct Outside Work The BCMB does not seek to dictate how employees conduct themselves in their personal lives outside work. BCMB staff must take extra care in conveying a professional image when wearing items with BCMB or industry branding. Any unlawful, anti-social or other conduct by employees which may jeopardise the BCMB's reputation or position may be dealt with through disciplinary procedures. 8. Communication Devices Including E-Mail and the Internet BCMB's communication devices, including the phone system, faxes, email, and resources related to the internet: i. are to be used for business purposes, although incidental personal use may be permitted provided such use does not negatively impact productivity, compromise system capacity, complies with applicable law and is in accordance with BCMB's policy relating to communication devices; ii. Are not to be used for improper or illegal activities (including excessive non-business use, downloading or sending defamatory, pornographic or other obscene material, copyright infringement and harassment); 9. Related Persons or Parties Employees must avoid dealing with those in which the relationship between them might bring into question the impartiality of the employee. V. Administrative Processes Administrative processes help employees manage ethical dilemmas, including any real or apparent conflict of interest concerns. a. Administration Management receives and ensures the confidentiality of all disclosures and ensures that any real or apparent conflict of interest is avoided or effectively managed. As well, management is responsible for providing advice and managing concerns and complaints concerning potential breaches of the Code, including conflicts of interest within the BCMB. Even though the BCMB may have a delegated process for responding to and managing concerns, management is responsible for ensuring procedural fairness. The individual responsible for responding to and managing concerns for BCMB employees is the President. The individual responsible for responding to and managing concerns for the President is the BCMB Board Chair. b. Disclosure It is the responsibility of each employee to declare in writing to management those private interests and relationships that they think could be seen to impact the decisions or actions they take on behalf of the BCMB. When there is a change in their responsibilities within the BCMB or in their personal circumstance, employees shall disclose in writing any relevant new or additional information about those interests as soon as possible. Where a real or apparent conflict of interest cannot be avoided, employees must take the appropriate steps to manage the conflict. Employees disclose these real or apparent conflicts of interest so that management is aware of situations that could be seen as influencing the decisions or actions they are making on behalf of the BCMB. This provides employees, following a review by management, an opportunity to take action to minimize or remove the conflict. To actively manage a conflict of interest, options include: * giving up the particular private interest causing the conflict; and, * removing themselves from matters in which the conflict exists or is perceived to exist; * in rare circumstances, resigning their position with the BCMB. c. Reporting a Potential Breach by Another Employees are encouraged to report in writing a potential breach of this Code or any policies or procedures by another to their supervisor. When reporting a potential breach in good faith and with reasonable grounds, employees are protected from retaliation for such reporting. Refer to BCMB's Internal Whistleblowing Procedures for guidance on reporting potential breaches. d. Responding to a Potential Breach Once a potential breach has been reported, the BCMB's procedures for responding to and managing a potential breach will be promptly initiated. Management will review the circumstance and details of the potential breach and will notify the alleged employee. The alleged employee has the right to complete information and the right to respond fully to the potential breach. The identity of the reporter will not be disclosed unless required by law or in a legal proceeding. Management makes a decision and completes a report in a timely manner. The decision may range from finding no potential breach to one that reveals suspected criminal conduct. e. Consequences of a Breach Employees who do not comply with the standards of behaviour identified in this Code, including taking part in a decision or action that furthers their private interests, may be subject to disciplinary action up to and including termination of the employee. f. Review of a Decision An employee can request in writing that the BCMB Board Chair review the decision made by Management that they have breached the BCMB's Code of Conduct. The President can request in writing that the Governance and Compensation Committee review the decision made by the BCMB Board Chair that they have breached the BCMB's Code of Conduct. VI. Other Resources a. Where to Get Advice When employees require advice and guidance in determining whether misconduct or a conflict exists, or need clarification, they may discuss their issue with their supervisor or management. If they do not feel comfortable discussing with their supervisor or management, then the individual should reach out to the Board Chair, Governance and Compensation Committee Chair, or Audit Committee Chair as outlined in the Whistleblowing Policy. b. Questions to Consider When employees are faced with a difficult situation, the following questions may help them decide the right course of action: * Have I considered the issue from a legal perspective? * Have I reflected on or consulted with my supervisor about whether I am compromising the Code's values, principles or behavioural standards? * Have I investigated whether my behaviour aligns with policies and procedures? * Could my decision or action be viewed as resulting in personal gain, financial or otherwise? * Could my private interests or relationships be viewed as impairing my objectivity? * Could my decisions or actions be perceived as granting or receiving preferential treatment? VII. Affirmation The Code of Conduct for the BCMB was introduced on February 29, 2016 and is reaffirmed annually by the BCMB to ensure it remains current and relevant.	<urn:uuid:58d794cb-2e37-4e5a-b1bb-b2ac94d355bb>	CC-MAIN-2017-13	http://www.bcmb.ab.ca/images/uploads/Code%20of%20Conduct/BCMB-Code-of-Conduct%20Effective%20February%2029%202016.pdf	2017-03-27T10:37:49Z	s3://commoncrawl/crawl-data/CC-MAIN-2017-13/segments/1490218189471.55/warc/CC-MAIN-20170322212949-00374-ip-10-233-31-227.ec2.internal.warc.gz	425,826,579	2,732	eng_Latn	eng_Latn	0.919831	eng_Latn	0.99605	[ "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn", "eng_Latn" ]	false	rolmOCR	[ 59, 1604, 3877, 6183, 8336, 10480, 12797, 14807 ]
GUIDING BEST PRACTICE, OR LEGITIMATING CURRENT PRACTICE? AN EXAMINATION OF AGS-1010 ON THE CONSIDERATION OF ENVIRONMENTAL MATTERS IN THE AUDIT OF A FINANCIAL REPORT A paper written for the 20 th Asian-Pacific Conference on International Accounting Issues Paris, France 2008, November 9 – 12 This paper reports PhD work in progress. Please do not quote without permission. Christina Chiang [email protected] Ph +64 9 921 9999; Fax +64 9 921 9990 Accounting Department, Business School AUT University Auckland, New Zealand Private Bag 92006, Auckland 1020, New Zealand GUIDING BEST PRACTICE, OR LEGITIMATING CURRENT PRACTICE? AN EXAMINATION OF AGS-1010 ON THE CONSIDERATION OF ENVIRONMENTAL MATTERS IN THE AUDIT OF A FINANCIAL REPORT ABSTRACT The primary aim of this paper is to report interview evidence on one aspect of a doctoral workin-progress which covers the consideration of environmental in the audit of a financial report. This study particularly considers whether AGS-1010: The consideration of environmental matters in the audit of a financial report is guiding best practice or legitimating current practice. This research study, undertaken in the context of AGS-1010, has not been researched before, thus it contributes to the literature on environmental matters from an audit perspective. It also provides substantial evidence in support of AGS-1010 as a 'symbolic ceremonial conformity' legitimation strategy (Ashforth & Gibbs, 1990). Key words: Financial audits, audit materiality, environmental matters, auditing profession GUIDING BEST PRACTICE, OR LEGITIMATING CURRENT PRACTICE? AN EXAMINATION OF AGS-1010 ON THE CONSIDERATION OF ENVIRONMENTAL MATTERS IN THE AUDIT OF A FINANCIAL REPORT 1. Introduction to This Study The primary aim of this paper is to report interview evidence on one aspect of a doctoral workin-progress which covers the consideration of environmental in the audit of a financial report. This study particularly considers whether AGS-1010: The consideration of environmental matters in the audit of a financial report is guiding best practice or legitimating current practice. This research study, undertaken in the context of AGS-1010, has not been researched before, thus it contributes to the literature on environmental matters from an audit perspective. It also provides substantial evidence in support of AGS-1010 as a 'symbolic ceremonial conformity' legitimation strategy (Ashforth & Gibbs, 1990). The following section review the literature on the auditing profession, AGS-1010 and legitimacy theory and section three outlines the research method. The interview findings are reported in section four and the paper ends with section five on a discussion of the implications of the interview findings, some concluding comments and recommendations for future research. 2. The Auditing Profession, AGS-1010 and Legitimacy Theory The audit profession functions "within a society's framework of legitimate authority" (Pasewark, Shockley, & Wilkerson, 1995, p. 77). For its status and position, it relies on public perception that its members perform an important task with proficiency and with the backing of a legitimate professional body (Weirich & Rouse, 2003). Hence its central focus is the 'social contract' (Deegan, 2006) which requires the audit profession to provide socially valued audited financial statements in exchange for a virtual monopoly of audit practice and self-regulation (Baker, 1977). This enables the audit profession to continue its pursuits and activities for their long-term survival (Ashforth & Gibbs, 1990; Guthrie & Parker, 1989; Savage, Cataldo, & Rowlands, 2000). Therefore, 'legitimacy theory' is an appropriate theoretical frame for this research and maintenance of organisational legitimacy is critical to upholding the status of the audit profession (Weirich & Rouse, 2003). In recent times, media and public scrutiny of a number of high profile corporate failures such as Enron, Parmalat, Health International Holdings (HIH) Insurance (Mak, Deo, & Cooper, 2005) have resulted in significant mounting criticism of the auditing profession (Chandler, 1999). As Savage, Cataldo and Rowlands (2000) observe, the media is a powerful constituent and news media reports are indicators of societal norms and values. The media also seek opportunities to publicise environmental disasters. Commentators observe that highly publicised news coverage on environmental disasters at Exxon Valdez, Chernobyl, Love Canal, and Union Carbide at Bhopal have changed public and political general awareness, attitudes and concerns for environmental issues (Gilkison & KPMG, 1999; Gray & Bebbington, 2000; Rubenstein, 1992; Watson & Mackay, 2003). Hence, there is tremendous turbulence in this aspect of the area in which the auditing profession operates (Baker, 1977). Prevailing environmental crises and audit failures have resulted in the auditing profession facing a crisis of investor confidence in financial reporting and auditing (Weirich & Rouse, 2003). Hence: [The auditing profession as] a professional body could lose its legitimacy if the public expected a change in performance that was not forthcoming. In the present dynamic social environment, continuance of previous practices may not be sufficient to maintain legitimacy, even if the performance related to that practice is maintained or even improved. Legitimacy is a moving target. If society recognises a need for either different or additional information, than accountants [and auditors] are expected to provide the needed information" (Reynolds & Mathews, 1999, p. 89). It is in the midst of high profile corporate failures, environmental disasters and criticisms of the auditing profession in 1998 that International Auditing Practice Statement (IAPS) 1010: The consideration of environmental matters in the audit of financial statements was issued. In 2001, New Zealand's AGS 1010, "consistent in all material respects" with IAPS 1010 (ICANZ, 2001, Appendix 1), was promulgated. The espoused purpose of the promulgation is to guide current practice in the consideration of environmental matters in the audit of ma financial report. Prior research showed that in some cases, the issuance of auditing standards and guidelines resulted in only little or no change in audit practice. Ashforth and Gibbs (1990, p. 181) describes this strategy as a "ceremonial, symbolic strategy", a strategy used by organisations to maintain or enhance their legitimacy. This strategy requires an organisation to adopt practices that are seemingly "consistent with social expectations while leaving the essential machinery of the organisation intact". Its enactment is strictly "for its symbolic quality… to provide the appearance of action without the substance, [with the intention of fostering] a belief among constituents that the organization's activities and ends are congruent with the expectations, values, and norms of constituents" (p. 182). Thus, this research will determine whether AGS1010 issued with the aim of guiding audit practice in considering environmental matters in the audit of a financial report constitutes a legitimation strategy to ensure the accountancy profession maintain their state of legitimacy in current turbulent times. 3. The Research Method This research is qualitative and adopts a naturalistic inquiry approach (Lincoln & Guba, 1985). The research evidence was gathered by interviewing twenty-seven senior financial audit practitioners in New Zealand. Of the participants, ten auditors were from the Big Four firms, eight auditors were from medium sized firms, seven were public sector auditors and two were government auditors. They are all chartered accountants and members of NZICA with access to AGS-1010. Audit partners and managers were selected for interviews because they are usually the ones who plan and manage audit clients. The interviews were conducted over a period of six months (June to December 2005); they were taped and then transcribed for data analysis. Data analysis for this study was informed by a range of literature (Appleton, 1995; Burnard, 1991) but focussed specifically on the work of Miles and Huberman (1994). Data analysis for this study was directed by semi-structured interview questions and the research topic. NVivo 7, a computerised qualitative data analysis software programme was used to manage the data analysis process. The next section reports the interview findings on the research issues. The confidentiality of the auditors was assured, hence when quoting the auditors, they are referred to by a numbering system, for example an audit partner is 'AP' and an audit manager is 'AM' and 1, 2 etc are code numbers for each of the individual interviewees. 4. The Research Findings A discussion of the literature in section two led to the belief that legitimacy theory is the appropriate theoretical frame for this research study. This belief led to the questioning of whether AGS-1010 actually guides audit practice in the consideration of environmental matters in the audit of financial reports or is it merely a legitimation strategy to ensure the accountancy profession maintains its state of legitimacy in current turbulent times. Evidence for the first research issue is reported in two parts. The first part covers interview findings on auditors' perceptions of AGS-1010; and its actual impact on current audit practice. The second part reports an analysis and evaluation AGS-1010 to determine whether it has the potential to provide guidance to improve auditors' practice. The implications of the research findings are reported in section six. The next section covers interview findings on auditors' perception of AGS-1010. 4.1 Auditors' Perception of AGS-1010 The letters of introduction sent to auditors to invite them to participate in this research explicitly referred to AGS-1010 as the basis for the study. However, a majority of the auditors admitted that they had not read AGS-1010 prior to the interviews. Hence, they were unable to comment on it. In fact, some of the auditors were not even aware of its existence: To be perfectly honest I haven't read it [AM 10]. I'd be completely honest and say I'm not aware of its existence [AM 11]. I didn't read it thoroughly. I am not an expert on environmental matters, so I do not know if AGS-1010 gives sufficient guidance on how auditors should recognise environmental issues in the audit process [AP 2]. On the other hand, the auditors who did read AGS-1010 considered it to be an introductory discussion paper; a very long document setting out some principles but not providing any detailed procedural steps: Yes, the introduction of AGS-1010 is an improvement, but really does it go far enough? I'm not sure [AP 2]. As a guideline, AG-1010 did not give direction on methodology. It is very much a discussion paper in my mind [AM 27]. AGS-1010 sets out in principle the general approach to the audit of environmental matters. It is a very long document but it doesn't give enough detail, a bit like the valuation, it doesn't give you enough details on the steps to perform and ticking them off when you get your conclusion [AP 4]. The next section presents interview findings on auditors' perceptions of the actual impact of AGS-1010 on audit practice. 4.2 Auditors' Perceptions of the Actual Impact of AGS-1010 on Audit Practice A number of the auditors felt that AGS-1010 has insignificant impact on audit practice. They commented on it being just an audit guideline, and thus not mandatory like an audit standard. None of the auditors interviewed seemed to pay serious attention to it and most indicated they were likely to ignore it unless they were auditing an entity obviously exposed to environmental risks. One auditor even considered AGS-1010 as a "non-event" and another went further to say that auditors are simply not using AGS-1010 or considering environmental matters in their audits: You know it is an audit guideline as opposed to being an audit standard. As an audit standard, it supposedly becomes compulsory and then you start paying closer attention to it. It is a case of being aware it is there. When your client operates in an industry that specifically has an environmental issue, that's when it is taken out and sits in front of the desk, and you go right through it for the audit [AM 1]. I think it's a good starting point, raising your awareness that you should look beyond the straight numbers. But it is difficult. It's a guideline and you know it can't cover everything. You know it's not as weighty as the standards [AM 14]. AGS-1010 is pretty much something that's a non-event [APR 1]. AGS-1010 is only a guideline and I do not think that auditors are using it or even considering environmental matters in their audit [AP 19]. The auditors who had been auditing environmental matters indicated they had been relying on international standards, which they considered to be of a higher standard and more stringent than AGS-1010: The audit work I do requires me to comply with the Local Government Act 2002 which is more prescriptive than AGS-1010. The calibre of work we already do is at a level higher than that proposed in AGS-1010. We haven't really changed our approach and we tend to get guidance from our international offices which deal with the matter for numerous countries and numerous issues [AM 13]. I think we are already doing a number of those things stated in AGS- 1010 anyway. Our bar is higher [AP 15]. No. I don't think it has really changed the way we do our audits. It's because of the way our files are set up. We refer to international auditing standards and our audits are in line with overseas auditing standards which tend to be more stringent than what we have here in the first place, so I can't think of any thing which has really changed [AM 3]. Some auditors felt that AGS-1010 is subject to different interpretations and although the underlying theory looks easy the practice is not: However, it's all in the interpretation. It's quite interesting, when you read AGS-1010 and when you apply it, they are two different things. The theory looks easy but the practice is not as easy. Often you have feedback that says someone knows the guidance statement, but really they don't have a clue what it involves. At the end of the day, when it comes to application, you know the guidance statement is subject to interpretation [AM 22]. One auditor felt that AGS-1010 in its present form would not facilitate any move forward because it does not provide any assessment criteria: AGS-1010 is very broad. Unless we have something specific to look at in order to give us some kind of assessment criteria, how can we move forward? [AP 26]. Many of the auditors seemed comforted that AGS-1010 is something they can show to their clients to provide assurance that they have appropriate guidance on the audit consideration of environmental matters, regardless of whether AGS-1010 is referred to or not: If anything goes wrong, if you get into a dispute or clients complain and ask "what are you doing?" You have AGS-1010 to pull out to show the client and say "there you go". It helps us in that way [AP 5]. In view of the above interview findings, and particularly the indication that AGS-1010 has insignificant impact on audit practice, AGS-1010 was critically reviewed in order to make sense of the reason(s) behind the interviewed auditors' perceptions. Findings from the review of AGS1010 are discussed next. 4.3 A critical review of AGS-1010 The aim of reviewing AGS-1010 was to analyse its effectiveness and to evaluate its potential impact (based on what AGS-1010 states) on current audit practice. However AGS-1010 was reviewed more critically only after the auditors were interviewed. In so doing, the reasons for the interviewed auditors' perceptions that AGS-1010 is not (actually) impacting current practice and the reasons for auditors not adhering to the requirements of AGS-1010 were capable of being explored. The purpose of AGS-1010 is discussed next, followed by a discussion of each of the identified issues that impact its effectiveness. The purpose of AGS-1010 AGS-1010 was first promulgated in 2001 by ICANZ (renamed NZICA in 2005). ICANZ acknowledged in AGS-1010 that environmental matters were becoming significant, and financial statement users were especially interested in its impact on the financial reports of those entities (AGS-1010, paragraph 1). Hence the stated purpose of AGS-1010 was "to assist auditors in developing best practices in the application of auditing standards" in cases where environmental matters were significant to the financial report of the entity. It did not, however, establish any new basic principles or essential procedures (AGS-1010, paragraph 6). AGS-1010 applied the business risk assessment model in audit planning and elaborated on specific factors and procedures that may be helpful in identifying environmental risk, defined as "the risk of material misstatements in the financial report due to environmental matters" (AGS-1010, paragraph 10d). However, the review of AGS-1010 carried out as part of this study revealed significant concerns on its ability to achieve its espoused purpose. The identified issues impacting the effectiveness of AGS-1010 are (1) the exercise of professional judgement, (2) auditors' greater reliance on client management and other experts (3) the consideration of environmental laws and regulations and (4) the existence of incidences of "doublethink" and "doublespeak" (Orwell, 1949) (which are internal contradictions) in AGS-1010. These issues are being discussed in the following sections. The exercise of professional judgement Professional judgement is emphasised in AGS-1010, as evidenced by the number of references to it and by its relationship with other issues raised in AGS-1010 itself. AGS-1010 expects auditors to rely on professional judgement: (1) when identifying the existence of environmental matters for the entity (AGS-1010, paragraph 3); (2) when assessing its significance to warrant its consideration in the audit of financial reports (AGS-1010, paragraph 2); (3) when assessing its impact on the financial report of the entity (AGS-1010, paragraph 4), and when evaluating environmental risk (which is the risk of material misstatements in the financial report due to environmental matters (AGS-1010, paragraph 10d); all summed up as follows: The extent to which any of the audit procedures described in the statement may be appropriate in a particular case requires the exercise of the auditor's [professional] judgement in the light of the requirements of the auditing standards and the circumstances of the entity (AGS-1010, paragraph 6). In acknowledging that environmental matters may be complex, AGS-1010 again emphasised the importance of exercising professional judgement: The use of professional judgement may become even more important because of the number of difficulties with respect to the recognition and measurement of the consequences of environmental matters in the financial report (AGS-1010, paragraph 44). Professional judgement determines what constitutes 'sufficient appropriate audit evidence' and such judgement is influenced by 'audit materiality' and business risk considerations. However, the relationship is not uni-directional because sufficient appropriate audit evidence significantly influences professional judgement that leads to giving the audit opinion (ICANZ, 1998, AS 500: Audit evidence). Therefore, exercising the professional judgement required by AGS-1010 is challenging because existing audit standards do not provide guidance in exercising judgement or identify the characteristics of good judgement. For all companies, there is a greater potential for omissions and non-disclosures of environmental matters in financial reports (rather than misstatements) because, by their nature, environmental matters are usually negative information which entities would rather omit from public disclosure. However, omissions and non-disclosures are much harder to search for than reported misstatements. Nonetheless, when identifying environmental risk factors, AGS-1010 requires auditors to exercise professional judgement based on 'technical skills' which the profession acknowledges 'the auditor cannot be expected to posses' (AGS-1010, paragraph 14). Auditors are not expected to have a higher 'level of knowledge with regard to environmental matters than that normally possessed by management or by environmental experts' (AGS-1010, paragraph 18). This presents a major challenge for auditors. If AGS-1010 acknowledges that auditors are not technically competent in environmental matters, how then will they exercise professional judgement when dealing with environmental matters? The interviewed auditors who have audited environmental matters commented that the guidelines in AGS-1010 are not prescriptive enough and are rather subjective. They also indicated that even though the theory embodied in AGS-1010 appears easy to understand, its practical application is not. This is confirmed by a review of AGS-1010. Although AGS-1010 contained many examples of environmental matters, it lacked useful guidelines on appropriate audit procedures. The second issue that impacts the effective of AGS-1010 is its suggestion for auditors to place greater reliance on management and other experts, and this is discussed next. Greater reliance on management and other experts AGS-1010 accepted that auditors do not have adequate technical and general knowledge to deal with environmental matters (AGS-1010, paragraph 14), and therefore it suggested that auditors rely more on management (AGS-1010, paragraph 13) and client internal documentation. In particular, AGS-1010 indicates that: To obtain a general understanding of relevant environmental laws and regulations, the auditor normally…enquires of management (including key officers for environmental matters) concerning the entity's policies and procedures regarding compliance with relevant environmental laws and regulations; enquires of management as to the environmental laws and regulations that may be expected to have a fundamental effect on the operations of the entity; discusses with management the policies or procedures adopted for identifying, evaluating and accounting for litigation, claims and assessments (AGS- 1010, paragraph 39). However, such reliance on management and working in close proximity with the client raises potential concerns for auditor independence. The auditor is also directed in AGS-1010 to rely on experts (lawyers, engineers and environmental experts), and in particular to use "the findings of environmental audits as appropriate audit evidence" (paragraph 51). In this matter, AGS-1010 refers to AS-606: Using the Work of Experts. AS-606, paragraph 8 which indicates that the expert may be one engaged either by the entity or auditor, or employed by the entity. If the auditor relied on an expert engaged or employed by the entity the issue of auditor independence arises again. Auditor independence is a significant issue in the Code of Ethics: Independence in Assurance Engagements (ICANZ, 2003) which states that auditors "must not allow prejudice or bias, conflict of interest or influence of others to override objectivity" (p. 460, paragraph 33). However, as indicated by Bazerman, Loewenstein and Moore (2002), auditors are vulnerable to bias and have "a tendency to be influenced by clients' or experts' biases; and that audit judgements are perceived as strongly biased toward the interest of their clients" (p. 101). These authors also argue "that it takes very little ambiguity to produce biased judgement" (p. 101). Therefore, the guidance in AGS-1010 for auditors to significantly rely on management and other experts (engaged or employed by the client) is somewhat problematic as it may lead to a compromise of auditor independence resulting from (1) "'advocacy threat', when the auditor's dependency on the client [or expert] 'subordinates' [his/her] judgement to that of the client, or (2) 'familiarity threat', when the auditor becomes too sympathetic to the client's interests" (ICANZ, 2003, Code of Ethics: Independence in assurance engagements, paragraph 33). Cheney (2005) reported Chuck Landes, the director of auditing and attestation at the American Institute of Certified Public Accountants (AICPA) as saying that audits have become more complicated and auditors are increasingly relying on experts. Landes is concerned that practical guidance given to auditors relying on experts "may be out of date and weak, not recognising what's happening in the work of using experts and specialists today" (Cheney, 2005, p. 14). He also raised several practical questions: (1) To be entrusted with an audit role, what qualifications does an expert need? (2) If an expert is hired by management, do auditors test their work as if it were management's? (3) When relying on the work of expert and specialists, has the auditor exercised sufficient due diligence and applied appropriate scepticism? (4) When an expert is hired by an auditor, is that expert integral to the engagement team and does that expert comply with the audit firm's quality control standards and procedures? (5) Has the audit firm defined the parameters that determine whether an expert is integral to the team? (6) To what extent do auditors as general practitioners take responsibility for the work of experts? (7) Should expert opinions be reported separately in financial reports? (Cheney, 2005, p. 14). When auditors rely on the work of experts when auditing environmental matters, they too should concern themselves with these issues raised by Landes. However, a review of AS-606: Using the work of an expert, confirmed that AS-606 does not provide any standard requirements on the above identified significant issues. Since AGS-1010 expects auditors to refer to AS-606 when they rely on the work of experts, and AS-606 does not provide any guidelines covering the above seven questions, the boundary between the auditor's position and the expert's position may be somewhat blurred, especially when the auditor is ultimately responsible for the overall audit opinion even though the auditor relied on the work of the expert. Auditors are therefore unavoidably exposing themselves to legal liability, especially when the interviewed auditors indicated that 'they do not have the same expertise as experts and therefore cannot always challenge the expert's assumptions, criteria and methods' (emphasis added). The next section discusses the third issue impacting the effectiveness of AGS-1010. The consideration of environmental laws and regulations Often, it is incidences of non-compliance with environmental laws and regulations that lead to environmental matters which materially affect the financial report. Hence, when an auditor is able to detect such non-compliance, the auditor is potentially more able to determine the existence of environmental matters for the entity and assess the corresponding risk of misstatements, omissions or non-disclosures in financial reports. However, guidance given in AGS-1010 on the consideration of environmental laws and regulations as a means of detecting environmental matters is not straightforward. AS-208: Consideration of laws and regulations in an audit established the standard for New Zealand auditors' responsibility to consider laws and regulations when auditing a financial report. 'Laws and regulations' mean statutes, regulations and common law. As with all other audit standards and in terms of Rule 11 (paragraph 97) of the Code of Ethics, auditors are compelled to comply with AS-208 for all audits. AS-208 states that some laws and regulations are relevant to the entity and will therefore determine "the form or content of an entity's financial report or the amounts to be recorded or disclosures to be made in the financial report" (AS-208, paragraph 10). Therefore, there is an expectation that auditors understand those laws and regulations "that may have a fundamental impact on the operations of the entity and thus have financial consequences that are material to the financial report" (AS-208, paragraph 10). Hence, the auditor is required to plan and perform the audit with an attitude of professional scepticism and awareness "that the audit may reveal conditions or events that should lead to questioning whether an entity is complying with laws and regulations" (AS-208, paragraph 15). In so doing, the auditor has to recognise that non-compliance with laws and regulations could result in fines, litigation or material liabilities; could jeopardise the viability of the entity; could affect the ability of the entity to continue to operate as a going concern (AS-208, paragraph 25b) or could cause the entity to cease operations (AS-208, paragraph 26). Non-compliance with legislation governing environmental protection is specifically mentioned in AS-208, paragraph 25c, highlighting its significance in the audit standard. In the context of laws and regulations covering environmental protection, AS-208 also assertes that the auditor "must obtain a general understanding of the legal and regulatory framework applicable to the entity and the industry and how the entity is complying with that framework" (AS-208, paragraph 23) (emphasis added). The legal and regulatory framework relevant to the current New Zealand study is the Resource Management Act 1991 (RMA). Therefore, in accordance with AS208, the auditor is expected to have sufficient understanding of the laws and regulations covered in the RMA when auditing assertions related to the recorded amount and disclosures of environmental matters (AS-208, paragraph 30). In particular, auditors are expected to plan and perform audit procedures to detect instances of non-compliances with the RMA. When noncompliances are detected, auditors then have to consider "whether the act of non-compliance itself is a matter to be reported in the audit report because it is material to the readers of the financial report" (AS-208, paragraph 39) even though the non-compliance does not have a direct potential financial consequence on the financial report. Audit reporting will also be affected by non-compliance which has a material effect on the financial report, but has not been properly accounted for or disclosed in the financial report. Non-compliance with environmental laws and regulations is a significant example of the existence of environmental risk exposure in relation to environmental matters. Yet a review of AGS-1010 pointed to delimitation in auditors' responsibilities as outlined in AS-208, since AGS1010 appeared to guide auditors towards a different level of responsibility when dealing with environmental laws and regulations. Although AGS-1010 asserted that "auditors should recognise that non-compliance by the entity with laws and regulations may materially affect the financial report", it accepted that a breach of environmental laws and regulations is a legal determination, beyond the auditor's professional competence (AGS-1010, paragraph 14). Besides, even though consequences of violating environmental laws and regulations were given as examples of environmental matters with implications for environmental risk (AGS-1010, paragraph 10b (ii)), AGS-1010 did not require auditors to "plan the audit to detect possible breaches of environmental laws and regulations" (AGS-1010, paragraph 12). Therefore, the guideline in AGS-1010 contradicts and delimits the requirements of AS-208 in so far as environmental matters were concerned. This is not the only contradiction found in AGS-1010. Other contradictions point to the fourth and most significant issue that impacts the effectiveness of AGS-1010 - the existence of 'doublethink' and 'doublespeak', examined next. 'Doublethink' and 'doublespeak' in AGS-1010 The notions of 'doublethink' and 'doublespeak' were first drawn from Orwell's (1949) literary classic 'Nineteen Eighty-Four'. 'Doublethink' means the power of holding two contradictory beliefs in one's mind simultaneously and accepting them both (El-Sawad, Arnold, & Cohen, 2004; Robb, 2003a). Lutz (1983) further explains: It is to know and not to know, to be conscious of complete truthfulness while telling carefully constructed lies, to hold simultaneously two opinions which cancelled out, knowing them to be contradictory and believing in both of them (Lutz, 1983, p. 26). 'Doublethink' leads to 'doublespeak'. 'Doublespeak' is the ability to speak or write contradictory ideas without the writer or speaker being aware of the contradiction (El-Sawad et al., 2004; Robb, 2003a, 2003b; Styles, 1984). 'Doublespeak' is language which pretends to communicate but really does not. It is language which makes the bad seems good, something negative appear positive…It is language which avoids or shifts responsibility; language which is at variance with its real and its purported meaning; language which conceals or prevents thought. 'Doublespeak' is language which does not extend thought but limits it (Lutz, 1988/1989, p. 26). Authors like El-Sawad et al. (2004), and Robb (2003a; Robb, 2003b) have already applied the idea of 'double-speak' in accounting contexts, hence the same idea is also being explored here. There is evidence to suggest that 'doublethink' and 'doublespeak' exist in AGS-1010. One example lies in the consideration of environmental laws and regulations. Detecting noncompliances with environmental laws and regulations is fundamental to determining the likelihood of any environmental matters existing for the entity and, consequentially, the potential for environmental risks in misstatements, omissions or non-disclosures in financial reporting. At one point, AGS-1010 noted the need for auditors to be alert to such issues: An audit carried out in accordance with auditing standards is planned and performed with an attitude of professional scepticism recognising that the audit may reveal conditions or events that should lead to questioning whether the entity is complying with relevant environmental laws and regulations in so far as non-compliance could result in a material misstatement of the financial report (AGS-1010, paragraph 37). Yet, in what appeared to be a case of 'doublespeak', AGS-1010 assumed that: … with respect to the entity's compliance with environment laws and regulations, the auditor's purpose is not to plan the audit to detect possible breaches of environmental laws and regulations… (AGS-1010, paragraph 12). The language used has implications for avoiding or shifting responsibility for detecting environmental matters and allowed AGS-1010 to promote two apparently contradictory 'truths'. Regarding auditors' reliance on environmental experts, AGS-1010, paragraph 14 indicated that auditors cannot be expected to possess the technical skills of environmental experts. Thus they are guided to seek technical advice from experts. However, …as the environmental area is an emerging speciality, the expert's professional competence may be more difficult to assess…In this situation it may be necessary for the auditor to give particular consideration to the experience and reputation of the environmental expert (AGS-1010, paragraph 14). The language here seemed to create confusion. If an auditor does not have the technical competence of the expert, how then is s/he expected to assess the expert's professional competence? Besides, what qualifications does an expert need to be entrusted with a role in an audit? And further, But: The use of professional judgement may become even more important because of a number of difficulties with respect to the recognition and measurement of the consequences of environmental matters in the financial report (AGS-1010, paragraph 44). AGS-1010, paragraph 17 stated that existing accounting standards do provide appropriate general guidance on the accounting treatment and disclosures of environmental matters in a financial report, but paragraph 44 indicated that there are special difficulties with environmental matters that require even more professional judgement. Thus, are environmental matters adequately covered by existing accounting standards? Yet another issue was the profession's acknowledgement that the accounting standards do not explicitly refer to environmental matters, hence recognising the difficulties in the reporting of environmental matters. However, instead of providing more explicit guidance on the reporting of environmental matters, AGS-1010 placed an expectation on auditors to use greater professional judgement. As discussed previously, how does one exercise professional judgement in an area where insufficient guidance is given? Does this mean that auditors are allowed a different standard of responsibility because of complexities in the reporting of environmental matters? The examination of AGS-1010 presented here pointed to significant gaps in the guidance it provided. Despite its stated objective to provide guidance on best practices for the consideration of environmental matters in the audit of financial statements, it appeared to delimit auditors' responsibilities for environmental matters. A review AGS-1010 confirmed that generally, AGS- There are few authoritative accounting standards that explicitly address the recognition, measurement and disclosure of the consequences for the financial report arising from environmental matters. However, existing accounting standards generally do provide appropriate general considerations that also apply to the recognition, measurement and disclosure of environmental matters in a financial report (AS-1010, paragraph 17). 1010 is a lengthy document, in parts confusing, complicated and contradictory to the very audit standards it seeks to assist auditors in applying in their attestations on environmental matters and this has been alerted to by the interviewed auditors. A major weakness of this guideline is its failure to specify an auditor's planning responsibility. It also remains unclear whether an auditor is expected to plan an audit that provides reasonable assurance for detecting material misstatements arising from client violations of relevant environmental legislation. The next section summaries the main research findings and discusses their implication for the research question. 5. Discussions and Concluding Remarks The research findings indicate that auditors considered AGS-1010 as a very long introductory discussion document that lacks detailed procedural steps; and auditors generally do not take it seriously. Hence it is not surprising that a majority of the auditors approached for the research interviews admit that they have not read AGS-1010 prior to the interviews or were not even aware of its existence. At least 25% of the interviewed auditors saw AGS-1010 as something which gives the impression that a professional guidance on the audit consideration of environmental matters exist. Hence, the interview evidence supports Humphrey, Moizer and Turley's (1993) observation that the significance of audit standards and guidance statements is in the power of the image they create in asserting auditors' public interest commitments. The text of the guideline seems to also give external visibility to auditors' expertise and rigorous practices and the impression of a solution to the problem (Power, 1999). The interviewed auditors commented that the application of AGS-1010 is subject to different interpretations. Woolf (1994) and Power (1999) also identify similar difficulties in interpreting audit standards, even where they "did look practical enough to look like guidance to outsiders" (Power, 1999, p. 25). Overall, more than 75% of the interviewed auditors perceive that AGS-1010 has very insignificant impact on audit practice; a non-event in practical application; and that auditors are simply not referring to AGS-1010 and not considering environmental matters in their audits. The general perception of the interviewed auditors is that AGS-1010 in its present form would not facilitate any move forward in improving and further developing current practice to better meet the espoused aims of AGS-1010. A review of AGS-1010 confirms the interviewed auditors' general perceptions and provides explanations for the interviewed auditors' perceptions. First, AGS-1010 does not establish any new basic principles or essential procedures (AGS-1010, paragraph 6). Therefore, as Humphrey and Moizer (1990) explain, audit standards and guidance statements are mere articulations of existing audit practice driven by professional self-interest. Power (1999) also made similar observations about the audit guidance on fraud when it was first issued. He criticised the audit guidance as a mere codification of common knowledge which, despite the rhetoric text, meant 'business as usual' for the auditors. Therefore, auditors are effectively directed to treat environmental matters no differently from any other audit issue, and it is business as usual. Second, AGS-1010 emphasises the exercise of professional judgement for every aspect of the audit consideration of environmental matters (AGS-1010, paragraphs 2, 3 and 4). However, professional judgement has many attributes, making the concept of professional judgement complex (Morrill, 1996). AGS-1010 requires auditors to exercise professional judgement based on 'technical skills', which the profession acknowledges 'the auditor cannot be expected to possess' (AGS-1010, paragraph 14). How could auditors exercise professional judgment when dealing with environmental matters, notwithstanding that professional judgement may be influenced by those attributes and factors identified in the literature? Third, AGS-1010 accepts the assessing of business risk in audit planning but highlights that auditors do not have adequate technical and general knowledge to deal with environmental matters (AGS-1010, paragraph 14). Therefore it suggests that auditors rely more on management (AGS-1010, paragraph 13); client internal documentation and experts engaged or employed by the entity. This raises potential concerns for auditor independence and 'managerialistic orientations' (Gray & Bebbington, 2000) which is problematic as it may lead to the auditor subordinating the auditor's judgement to that of management or the expert; or the auditor may be too sympathetic to the client's interests" (ICANZ, 2003, Code of Ethics: Independence in assurance engagements, paragraph 33). Since AS-606: Using the work of an expert, does not guide auditors in how they should manage the experts; this may lead to a blurring of the boundary between the auditor's position and the expert's position. Fourth, AGS-1010 requires auditors to comply with AS-208: Consideration of laws and regulations in an audit which expects auditors to understand those laws and regulations "that may have a fundamental impact on the operations of the entity and thus have financial consequences that are material to the financial report" (AS-208, paragraph 10). Hence, auditors' understanding of environmental laws and regulation should enable them to recognise any noncompliance with environmental laws and regulations. Yet, AGS-1010 seems to delimit auditors' responsibilities required in AS-208, and appears to be guiding auditors towards a different level of responsibility when dealing with environmental laws and regulations. Similarly, when van Peursem, Locke and Harnisch (2005) examined the audit standard on 'Going Concern', they too found that the audit standard do not seem to impose any additional requirement on the auditor. Fifth, discussions which highlight a number of incidences of 'doublethink' (El-Sawad et al., 2004; Robb, 2003a) and 'doublespeak' (El-Sawad et al., 2004; Robb, 2003a, 2003b; Styles, 1984) in AGS-1010 strongly suggests that the language in AGS-1010 was intended to create confusion by promoting two apparently contradictory 'truths' which have implications for avoiding or shifting auditors responsibility for detecting environmental matters. Hence Pong and Whittington's (1994) criticism that audit standard and guidelines do not attempt to re-think or extend the scope and technique of the audit. Rather, they attempt to consolidate the status quo and also to limit the obligations and responsibilities of the auditor. Therefore, the review of AGS-1010 points to significant gaps in the guidance it provides. Despite its espoused purpose in providing guidance on best practices for the consideration of environmental matters in the audit of financial statements, it appears to delimit auditors' responsibilities for this task. In summary, it can be said that AGS-1010 is a lengthy document, in many parts confusing, complicated and contradictory to the very audit standards it seeks to assist auditors to apply to their attestations on environmental matters. This confirms van Peursem et al.'s (2005) observation that although greater volume may give the appearance of improving professional benchmarks, actually volume is not necessarily commensurate with greater quality or a more forceful mandate. Another major weakness of this guideline is its failure to specify an auditor's planning responsibility. It also remains unclear whether an auditor is expected to plan an audit that provides reasonable assurance for detecting material misstatements, omissions or distortions arising from client violations of relevant environmental legislation. Overall it appears that the interviewed auditors are justified in saying that AGS-1010, in its present form, is unlikely to impact on audit practice and does not facilitate the development and improvement of current practice. Nonetheless, as Power (1999) indicated, issuing an audit guidance statement is a strategy for managing new demands in auditing. The next section discusses the implications of the evidence from this study in support of AGS-1010 as a symbolic 'ceremonial conformity' legitimation strategy for managing new demands in the consideration of environmental matters in the audit of a financial report. AGS-1010: A symbolic 'ceremonial conformity' legitimation strategy This strategy requires an organisation to adopt practices that are seemingly "consistent with social expectations while leaving the essential machinery of the organisation intact" (Ashforth & Gibbs, 1990, p. 181). Commentators, authors (Bebbington & Gray, 1992; Gallhofer & Haslam, 1997; Medley, 1997; Rezaee, Szendi, & Aggarwal, 1995; Steadman, Green, & Zimmerer, 1995); and particularly the more 'visible' public criticism did lead to some disquiet in the arena which the accountancy profession operates and in 1998 (amidst the Enron debacle) IFAC released IAPS-1010. In more recent times, criticisms of the audit profession have intensified as a result of media and public scrutiny (Chandler, 1999) of a number of high profile corporate failures such as Enron, Worldcom, Parmalat and Health International Holdings (HIH) Insurance (Mak et al., 2005). Hence, prevailing environmental crises and audit failures have resulted in the auditing profession facing a crisis of investor confidence in financial reporting and auditing (Byrnes, McNamee, Brady, Lavelle, & Palmeri, 2002; Thomas, 2003; Weirich & Rouse, 2003). Self-regulation has also been scrutinised (Kinney Jr, 2005). Therefore, a legitimacy gap is perceived to exist and the audit profession could lose its legitimacy if the continuance of previous practices is not sufficient to maintain legitimacy, even if the performance related to that practice is maintained or even improved (Reynolds & Mathews, 1999). It was in the midst of high profile corporate failures, environmental disasters and criticisms of the audit profession that in 1998 the International Auditing Practice Statement (IAPS) 1010: The consideration of environmental matters in the audit of financial statements was issued and later promulgated in New Zealand in 2001 as AGS-1010. This New Zealand guidance statement was "consistent in all material respects" with IAPS-1010 (ICANZ, 2001, Appendix 1). From the events that took place, the issuing of IAPS-1010 in 1998 could be seen as a legitimating strategy to close the legitimacy gap and to ensure the continued perceived legitimacy of the audit profession (Dowling & Pfeffer, 1975). The issuing of AGS-1010 was also timely in detracting focus from the huge impact the high profile accounting debacles had on auditors and accountants' role in accountability, in protecting the public interest (Pasewark et al., 1995); and the monopoly of self-regulation (Baker, 1977). Lindblom (1993) considers this as a symbolic activity which serves to deflect attention from the main issue of concern (accounting failure) by portraying the audit profession's activities in environmental accountability as compatible with societal norms and values (Ashforth & Gibbs, 1990; Pfeffer, 1981). Findings from the current research indicate that the issuance of AGS-1010 did not result in any significant change in audit practice. Rather, they show that the interviewed auditors see the main value of AGS-1010 in the impression it gives of professional guidance, which gains clients' confidence that auditors are considering environmental matters in their audits of financial reports. This research finding also provides further support for Humphrey and Moizer's (1990) observation that official audit guidance plays little role in everyday audit work, rather it gives the appearance of addressing the issue and providing comfort that it is being attended to, even though the status quo is maintained (Fogarty, Heian, & Knutson, 1991). This has a role in creating an illusion which guide cognition and legitimize acceptance through the business community (Mills & Bettner, 1992; Pentland, 1993). Therefore, the research findings confirm that the issuing of AGS-1010 can be interpreted as a ceremonial, symbolic legitimation strategy used by the audit profession to maintain or enhance their legitimacy, with perhaps the intention of fostering the belief that the auditing profession's activities and ends are congruent with the expectations, values, and norms of constituents (Richardson & Dowling, 1986). However further research is required to investigate auditors' perception of what steps may be taken to improve and further develop current practice in the consideration of environmental matters in the audit of environmental matters in an effort to meet the espoused purpose of AGS-1010. Another research topic arising from this study is: how do or how should auditors manage their relationship with experts and management in view of the questions raised by Cheney (2005). REFERENCE LIST Appleton, J. V. (1995). 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