Land law Essay Example | Topics and Well Written Essays - 1750 words

Land law - Essay Example 15,000 for the purpose of them being a home together and Mr Winston used this sum to purchase the property along with a mortgage in his sole name. There doesn’t appear to be any express valid trust regarding Miss Kaur’s contribution however Miss will most likely have a proprietary right in equity under resulting trust3. Resulting trusts usually involve contribution to the initial cost of the family home, which is registered solely in the name of another person4. Equity does not presume an outright gift, but rather a presumption that the contributing party intended to retain a beneficial interest in the property5 (despite no evidence of actual intention). Whilst this approach has been criticised theoretically as the imposition of an â€Å"artificial presumption6†, it is arguably a necessary approach to protect third party interests7. On this basis, Miss Kaur may be able to claim an equitable interest in the Property under resulting trust and on this basis Mr Winst on will have held the Property as sole trustee with there being two co-owners in equity8. As the Property was held in trust and there is only one trustee of the land and two co-owners, Ms Winston will not be able to rely on the doctrine of overreaching to negate Miss Kaur’s interest9. Moreover, as Miss Kaur has an equitable interest on grounds of resulting trust, Section 3310 of the LRA provides that trusts are not registerable as notices on the register and therefore Miss Kaur’s interest will not have been registered. Furthermore, the effect of Section 26 of the LRA is that purchasers are entitled to proceed, in the absence of such an entry on the register on the basis that there are no limitations on the owner’s powers11. As Miss Kaur has an equitable interest in the Property under the trust, her interest will only be binding on third parties if it constitutes an overriding interest12. Schedule 3, paragraph 2 of the LRA protects overriding interests of those w ith rights to the property that are in actual occupation13. However, in the current scenario, Miss Kaur was away for over a year and did not live in the property. Accordingly, Miss Kaur will not be able to establish an overriding interest by virtue of actual occupation. Therefore, on this basis Ms Winston will hold the Property on trust for Miss Kaur and any proceeds of any potential sale will be held on trust for Miss Kaur in proportion to her contributing share to the purchase price14. 3: Miss Thomas With regard to Miss Thomas, she did not contribute to the purchase price however she undertook significant renovations and modernisation to the kitchen and gave up her local housing authority home to live in the Property on the basis of Mr Winston’s representations. Therefore, Miss Thomas may have an equitable proprietary interest under common intention constructive trust15. The leading case of Lloyds Bank plc v Rosset16 highlighted the essential requirements for the imposition of a constructive trust asserting its foundation in the common intention of the parties to share the properties. Lord Bridge further asserted in this case that intention could be express or inferred from conduct17. Furthermore, Lord Bridge in highlighting the reasoning in Gissing v Gissing18 asserted the concept of

Internationa human rights law Essay Example | Topics and Well Written Essays - 1500 words

Internationa human rights law - Essay Example In most cases, the application of extraterritorial jurisdiction statutes often becomes necessary to regulate the conduct of the state agents in another territory if their conducts have an impact on the national interests of their country of origin (Ovey and Robin, 2006, p.25). With regard to international laws, there are cases where extraterritorial jurisdiction has been exercised beyond international boundaries particularly under agreement between the concerned parties or nations. These legal agreements allow the US government to exercise authority and jurisdiction over the members of the US military in these countries. Many other countries have also enacted laws and signed agreements with other countries to allow them prosecute their citizens in other countries for crimes such as genocide, frauds and war crimes among others. This is often practiced regardless of whether the crimes were committed extraterritorially or in their mother countries. For example, the UK government has incorporated the Rome statute act into their domestic laws. This legislation allows criminal cases to be filed against UK nationals who commit crimes in other countries. In this regard, such criminals can be prosecuted according to the standards of the UK laws even if their count ries of residences do not have such laws. Al-Skeini v. U.K was a case involving the investigation of a complaint in which the British troops had allegedly mistreated and killed five Iraqi civilians and maimed the sixth one. Consequently, the families of the victims sought justice from the European Commission on human rights. One of the major controversies surrounding the case was the question of whether the case was within the jurisdiction of the ECHR since crimes were committed outside the United Kingdom. Although the previous jurisprudence had always sought to limit the extraterritorial jurisdiction of the European countries in the other areas they control, the ECtHR Grand Chamber courts ruled that since the

Needs for a Domestic Vacuum Cleaner Essay Example | Topics and Well Written Essays - 3000 words

Needs for a Domestic Vacuum Cleaner - Essay Example The Dyson DC08T is a hypoallergenic cylinder vacuum cleaner, and comes with a "lose no suction power" claims from the manufacturer. It Employs a Bagless Dust Collector, and is free-standing. In appearance, it’s cute, compact and small. The bright colorful exteriors are attractive, and the cleaner has easily maneuverable buttons. The hose pipe can be wrapped around the cleaner and hence facilitates easy storage. With a maximum volume of the dust collector of 2 Litres, it is capable of working for an extended period of time without the need to clean and restart. The cleaner however is not capable of working on a remote control mode, and also does not have the capacity to multi-function. It comes with a Telescopic wand and a turbo head for deep cleaning or using on pet hair. Before proceeding to report the actual exercise, it is appropriate to elaborate upon the layout of the cleaning area. The cleaning will be undertaken in my two-bedrooms, that have hard floors and furniture like, bed, dresser and an armchair. It will also include the living room, that too has hard floor, a Belgium carpet, and an assortment of rugs. The furniture in this room includes a fabric-furnished sofa set, a glass-topped center table, two wooden side tables, and an array of artifacts that include small sized statutes, terracotta vases, and several other similar displays. The hall houses dining table and chairs, and a couple of lounge chairs.

How Police Conduct Themselves in the Public Eye Essay

How Police Conduct Themselves in the Public Eye - Essay Example The concept of â€Å"effectiveness† plays a key role in the analysis offered by Skogan and Frydl (2004), who likewise take a historical approach to evaluating the success of various police reform efforts. As Kelling and Moore (1988) write, â€Å"interpretation is necessary† (p. 1). In other words, a historical approach is defined by interpretations of the facts that emerge from certain cases. Although an interpretative approach is empirically weak, such an approach provides both a descriptive and evaluative view of what problems exist and how the public should fix them. Police have evolved a secondary function in America to serve as a symbol of authority, which they have with the implicit power to deprive individual citizens of their liberty. A normal person knows that if he commits a crime in front of a police officer, that police officer has the authority to take action to lock him in jail or to give him a fine. Even in the threat of depriving people of liberty withou t actually expressing that power, police have a definite authority (Skogan & Frydl, 2004, p. 65). This authority comes from their symbolic place as a representative of authority, which members of the public automatically respond to. ... In the last 50 years in American policing, some of these conflicts have been exacerbated by nationwide media coverage. One of the most remembered incidents involved the beating of Rodney King at the hands of the Los Angeles Police Department. In 1991, an African-American was assaulted by four white police officers. These police officers were later acquitted in 1992, which precipitated the 1992 riots that reflected deep racial mistrust between urban populations and the police in charge of maintaining social order. Of course, the interaction between police and civil rights was nothing new, following major riots in 1964 and 1968. However, Rodney King did represent an opportunity for a more contemporary analysis of how police interact with the public as symbols of authority. In that case, police interacted with the public as authority figures, but the authority figures served no other purpose but to detract from due process and fairness. To some degree, this may have been due to the emer ging category of services that police provide: preventing crime (Skogan & Frydl, 2004, p. 72). By employing nearly deadly force on a suspect, the police seem to be sending a message to the public they deal with; however, in the Rodney King case, the message was extended to the wrong audience. Another new direction in American law enforcement is the widespread use of Taser technology by police officers. Taser technology is a supposedly non-lethal alternative to firearms that subdues suspects before they can pose a bodily threat. A study in 2008 revealed that approximately 90 percent of Taser discharges by police were done in response to unarmed or non-threatening suspects (The Washington Post, 2010). This problem with Tasers reflects a more fundamental problem

Report on The Correlation of physical strength to perfomance on Essay

Report on The Correlation of physical strength to perfomance on physically demanding jobs - Essay Example Physically demanding jobs like those that can be obtained in the armed forces, emergency rescue, construction, heavy-equipment industries and the like require a high level of physical capabilities. Occupations that involve long and cyclical duties such as lifting, carrying, pulling and pushing can potentially cause cumulative trauma disorders such as â€Å"back pain, sprains, strains, carpal tunnel syndrome, and neck pain† (Nindl & Sharp, 2011). Understandably, when workers are blighted by physical traumas and injuries, they become less effective in carrying out their duties and responsibilities; hence, it could have a potentially negative effect on the job performance on the whole, and eventually on the entire organization. So, this paper shall elaborate on the correlation between physical strength of workers and job performance on physically demanding jobs. In order to clearly and accurately demonstrate a decisive inference on whether a correlation exists or not, this paper shall focus on two measures: arm strength and grip strength. Data Set No. 18 S. No. GRIP x ARM y RATINGS z SIMS Mean Score (x,y, z) Mean Score (x, y) 1 100.5 51 30.2 0.77 60.57 75.75 2 95 64.5 36 -1.97 65.17 79.75 3 75.5 57.5 42.1 0.35 58.37 66.50 6 54.5 35 39.8 -1.68 43.10 44.75 7 131 86 37 1.03 84.67 108.50 8 147 71 57.2 0.53 91.73 109.00 9 104 47.5 31.2 1 60.90 76.00 10 104.5 69 38 -1.43 70.50 86.75 11 120 100 52.4 1.24 90.8 110.00 12 128.5 93.5 46.4 3.16 89.47 111.00 13 29 19 28 -4.17 25.33 24.00 14 128.5 88 57 0.91 91.17 108.25 15 98.5 65.5 29.6 -1.29 64.53 82.00 Solution By simply taking the arm and grip endurance at a particular length of time, arm and grip strength have been measured and tallied for analysis. For the first calculation of the mean score, that is, (x, y, z), ratings have been included in order to identify the significance of ratings in determining the correlation between arm and grip strength and job performance. Nevertheless, to find if ratings do have a subs tantial effect on the overall job performance, a second mean score has been measured. Interpretation Scatter plots could have been utilized in order to graphically display the relationships between the strength scores and ratings, and how the two measures relate with ratings and work simulation scores. But, the table itself can already tell enough that participants with lower strength scores have lower ratings from their employers, which could mean that they performed less effectively that their counterparts. By simply analysing the data, one can automatically conclude that, indeed, there is a correlation between physical strength on performance on physically demanding jobs. Take for instance the comparison of the mean scores and sims between participant 1 and participant 13, participant has got a better simulation and mean score as compared to participant 13 despite the fact that participant 1 got a considerably low ratings. Furthermore, there is not much relationship between ratin gs and physical strengths. Some participants who have higher physical strength do necessarily have higher performance ratings from their employers. Such is the case of participant 12 and 15; nonetheless, it

Global Warming Poses Threat to Ski Resorts in USA Essay Example for Free

Global Warming Poses Threat to Ski Resorts in USA Essay The American west is marvellous, it is large with grand landscapes and mountains reaching to the sky . The plains unfold to the horizon and the vistas present an unimaginable panorama. Just like any where else in the world, water is an essential element to life here but it is scarce hence creating the wests vulnerability. Precipitation is generally low and cannot support agriculture it is for this reason that agriculture is only possible through irrigation. This precipitation is not only scarce but scarcest in the summers when it is mostly needed but falls disproportionately and mostly in the mountains in the winter. The only saving grace is that in winter it precipitates as snow and stays as snow packs throughout the winter. It is on the basis of these weather patterns that the winter sports tourism is established. This industry has served as the main economic driving machine of the west and other other areas for decades. However, changing climatic patterns and global warming has emerged as a serious threat to the existence of the winter sports industry. Projected increases in average global temperatures due to increases in green house gases in the atmosphere has been incriminated in widespread glacial and white cap decreases, ocean level rise and warming but most importantly in the reduction of snow cover and the decrease in the duration of winter tourism. The unpredictability of the future and the climate sensitive nature of winter sports tourism has led to many initiative aimed curbing the increase in green house gases and consequently making snow available. Introduction Compelling evidence suggests that global climate has been on a progressive change since the industrial era and is projected to continue over the 21st century and beyond. Global warming and climate change is an unequivocal phenomenon. Global mean temperature has been on the increase with an approximate increase of 0. 760 C between 1850-1899. the same increase has been found between 2001 and 2005. This means that global predictions of temperature bear a 90% probability (IPPC. Climate Change and Tourism, 2007). These increases in average temperatures are a direct result of human activities that increase the concentrations of green house gases in the atmosphere. The extent of these discernible human influences have also extended to other climate change aspects such as temperature extremes, changes in wind patterns, continental average temperatures and ocean warming. The same is applicable to the widespread glacial and white cap decreases coupled with warming of the ocean surface temperatures, the result is a sea level rise of approximately 1. 8mm yearly from 1961-2003 and approximately 3. 1mm yearly from 1993-2003. The resultant effect of biological response in ecosystems and species diversity presents an unpleasant scenario and these statistics are recorded in virtually every continent. It is projected that the probability of increase in global temperatures will further accelerate green house gas emissions at the present or above the present rates. The prediction pushes overall global temperature rise by 1. 80C -4. 00C. Assuming that the atmospheric concentrations of green house gases are stabilized, the warming effect would still continue due to the levels of green house gases from past emissions and the consequent thermal inertia of oceans. The biological response would also be extrapolated to future centuries even if the levels are stabilized at the present concentrations today. The discernible manifestations worldwide will be hot temperature extremes, extreme heat waves, heavy precipitation, peak wind speeds and precipitation in tropical cyclone events and an additional heavy precipitation associated with increases in tropical sea and surface temperatures. Together with these climatic changes extra tropical storm tracks are projected to shift towards the poles. All these changes together with the decreases in show cover will continue into the future. The economic and environmental risks are unfathomable and would effectively impede nations strides towards the achievements of sustainable developments. However, there is hope that if precautions and measures are taken to reduce green house gases today the high costs of environmental and economic destruction and disruption can fairly be mitigated. This calls for lifestyle changes, economic policies and regulations and international efforts that not only help reduce the causative agents of climate change and global warming but also foster adaptation and mitigation measures to meet the challenges of climate change. Climate change and Tourism Climate change, especially global warming has grown to be a pivotal issue in the development and management of tourism. The relationship between the environment, climate and tourism sector is currently a highly sensitive economic matter. Climate change is increasingly driving tourism development and decision making, changing tourism destinations and even tourist tastes. Tourism sector remains a non negligible contributor to climatic changes. GHG emissions from transport and accommodation must be reduced in accordance with international standards. Tourism sector cannot address the challenges of climatic changes themselves and in isolation but they can only do this in the context of sustainable development and the broader international development agenda. Tourism and the sustainability of tourism destinations is dependent on climate variability. The length and the quality of seasons as well as destination choice and the level of tourist spending are all determined by climate change. Climate change and winter sports Winter sports constitute a very source of income and the reliability of snow is a key element in the touristic offer. Skiing and snowboarding are the most common forms of writer sports but others such as snow hiking and cross-country skiing also depends on the reliability and the availability of enough snow. Mountainous areas are always very sensitive to climate change hence less snow, melting permafrost, receding glaciers and extreme events such as landslides. Additionally climate change shift mountain fauna and flora. These effects pose a direct threat to ski resorts in the United States. Lower earnings in winter tourism will only serve to exacerbate economic disparities that exist between the alpine regions and the more developed urban areas. These changes will also increase the risk of only skiing at high altitude up the mountain. If this was to happen there would be an intense concentration of sports activities in certain regions as well as further putting pressure on the environmentally sensitive high mountains. The extrapolation of the effects of global warming on winter tourism extends to the viability of the mountain cable way companies that use the availability of snow as a prerequisite for their financial stability. Without snow or enough snow the profitability of the ski industry is impossible. The absence of snow in the mountains will be like having a summer without a sea. The variability of the winter season with response to climate change will deny the winter sports industry the right levels of snow at the right time. These forecasts are a necessity in planning for trips at shorter notices especially the weekends (Rolf Burki et al, 2003) Studies undertaken in Canada, Australia, New Zealand, Australia, Switzerland and the United States to establish the impact of climate change on the tourism sector show severe implications especially to the winter sports industry. While some regions with high technological advances like adaptation strategies (artificial snow making) will maintain their tourism, others unable to adapt the expensive technologies will lose out. These transitions in business volumes will not only be driven by limiting snow levels but also the fact that skiers respond flexibility to snow conditions. During a snow poor season, 49% of skies are most likely to change to a resort that is fairly more snow reliable, 32% would reduce the frequency of skiing and only 4% would give up the sport. Coupled together with the fact that climate change has a direct effect on the number of ski days, those unable to adapt to expensive technologies will be disadvantaged and pushed out of business. (Rolf Burki et al, 2003). Snow resorts not concentrated in snow reliable high altitude areas will be forced to withdraw from the market because of decreasing levels of snow. For transport industries that will offer access to high altitude areas (sometimes higher than 200m) business prospects will be good due an expected increase in skiing at the high altitudes. The effect of this will be quantitative expansion of the high altitude skiing resorts hence eliciting a negative environmentally feedback effect caused by disruption of the ecologically sensitive high altitude mountain regions. Presently, this expected expansion to high altitude areas has been the theme of many concept studies that influence the opening up of High Mountain (Breiling and Charamza, 1999) It is for these effects of climate change that during a recent campaign in Portsmouth, N. H, Barrack Obama the Democratic Party presidential candidate reiterated that there is need to address the urgency of global warming on the ski industry. He said that global warming is not a future problem but a present one. This problem has made New Hampshire to have shorter sporting seasons and people are losing jobs. He further reiterated that residents of North America ski areas together with their customers should work hand in hand to change their energy spending. habits and resort to green technology if they were to prevent climate caused melt-downs (Laura Bly, 2007) Resorts have started investing in sustainable seafood practices, local food supplies, biodiesel powered snow cats and embracing the use of more energy efficient snow making equipment. To achieve this, campaigns on global warming and discounts are being offered to guests who come in hybrid cans. What is even more impressing is that resorts have taken the challenge of campaigning for these changes as well as acting as advocates for intergovernmental change. Effects of global warming have also been reported in Burlington Vt. The city is usually carpeted in December but unfortunately changing climatic conditions has created a mild situation where snowfall is meager just an inch thick. The temperatures are becoming warmer and fewer trails open. However, these fears have been allayed by the optimism of the meteorological department prediction that the season will progress as Christmas approaches. According to Michael Berry; president of the National ski Areas Association, the potential impacts winter recreation, the mountain ecosystem and the way of life of residents in these areas cannot be ignored. Global warming has a direct and profound effect on the ski business as it depends solely on the variability of weather. To drive this process of change, the association has adapted a policy to regulate and control climate change. The reduce, educate and advocate approach was adopted to help in the fight against global warming. Key in the policy is a call to ski resorts to work towards the reduction of green house gas emissions individually and collectively, educate the public and guests on the potential impacts of climate change to writer sports industry and be the advocate in pushing for institutional and regulatory changes aimed at curbing greenhouse gas emissions (Michael Berry, 2007). To this end almost half of the 59 ski resorts, who have purchased renewable energy credits or utilized green energy for their lifts and other facilities are 100% green powered hence reducing carbon dioxide emission by 427,596,000 pounds an equivalent of planting almost 17 million trees. Customers are encouraged to offset their emission and work towards increasing green energy use in their home. Generation of renewable energy through on site solar projects or micro hydro power projects and wind energy has greatly increased with Jimmy Peak Mountain Resort in Massachusetts installing the first wind turbine powered ski area in August 2007. Resort vehicle fleets are now using alternative fuels like biodiesel, they also provide or promote car pooling or mass transit use. Ski resorts are being built using green building techniques and retrofitting existing facilities all with the aim of saving energy. Though an outreach program called â€Å"Keep Winter cool† millions of people have been educated on global warming and encouraged to institute lifestyle changes to help curb global warming. Specific Impacts of Global Warming on Winter Tourism . Snow The financial viability and stability of the winter sports tourism industry solely depends on the availability of sufficient snow. Less snow pack is caused by higher average temperatures, on the other hand if there are extremely low temperatures at night then it follows that there is likely to be an average increase in daytime temperatures. In both cases the resultant effect is less mountain snow cover and a reduction in the duration of cover. (Stephen Saunders et al, 2005). This means that recreation will be shortened and the snow will be slushier. The big difference to earlier situation where snow cover was considerably reduced is that, the capital intensity of the winter sports tourism will be considerably high. When this is analyzed in the context of profits from ski dependent businesses, taxes from local and state governments, the financial prospects of industries in the winter tourism sector look bleak. However, the most important link between climate change and mountain tourism is less snow and, as a consequence, less earnings in ski tourism. Glaciers Statistics all over the world point to the fact that there is a general retreat of glacial cover all over the world. Taking Switzerland as an example, since 1850, the Swiss glaciers have lost slightly more than 25% of their surface. If this was to continue in the future, by 2030, approximately 20% to 70% of the total Swiss glacial cover will disappear. This is a real problem for the ski industry not only in Switzerland but across the world as ski tourists will resort to other countries with snow availability. The effect of this trend will be putting more pressure on the existing ski facilities as well as acting as an incentive for investment in high altitude areas. Permafrost Melting of permafrost due to global warming makes mountain areas vulnerable to landslides. Transport facilities such as the mountain cable way stations, the lift masts and buildings become instable. Them costs incurred in bracing and anchoring such buildings when permafrost melts are extremely high. Hiking and climbing in these areas is also made more dangerous hence the loss of revenue due to potential risk of injury like rockfall or other health outcomes. Despite of cries over decreases in snow levels in the future, there is a possibility of winters with heavy snow like that of 1998/1999 that brought a great deal of losses in the winter tourism industry. The avalanche winter destroyed mountain cable ways, ski-lifts and chair lifts. The expenses incurred on sow clearing and the overall loss incurred was in excess of US $ 130 million. Adaptations for the future ski industry should therefore inculcate these historical weather unpredictability patterns in improving the industrys financial viability. Adaptations and Strategies Used by the Tourism Industry to Mitigate Against the Impacts of Global Warming All tourism representatives at political,organizational, entrepreneurial or operational level have been in the forefront in pushing for adaptation strategies to curb climate change and help mitigate the potential effects of global warming. The experiences that project what is going to come in the future are prevalent today and is widely accepted that snow deficient conditions will determine whether winter tourism will remain a viable economic activity. To achieve this a multi sectoral framework that consists of the National Ski Areas Association(NSAA), Natural Resource Defense Council (NRDC), the federal government through the Senate Environment and Public Works, state stakeholders and other non governmental civil society organizations have developed a Climate Change policy aimed at reducing the concentrations of green house emissions. Ski resorts have been encouraged to adopt safe and efficient energy usage through the exploitation of renewable energy resources. It is this concerted effort in mitigating climate change challenges that also saw the support and endorsement of McCain/Lieberman Climate Stewardship Act to spearhead the fight against global warming. Specifically these attempts will help stabilize the US$ 5 billion mountain resort industry that currently offers employment to 165,000 people. Despite the existence of facts that predict radical effects in the industry, some argue that climate change issues are very exaggerated and politicized by science and the media. They argue that even though the effects could intensify problems in the industry, the majority of resorts in medium and high altitudes will be barely affected. Discussions should yield strategies that take into account the accuracy of statistical data disseminated on climate change and critically analyze the potential consequences. These issues should further be analyzed with reference to the global competition in the winter tourism sector. The facts that accrue from these forums should then be integrated in the construction of artificial snow flaking facilities, extend existing ski runs. Opening of high altitude ski resorts (2000-3000m)should be guided by the potential ecological effect. Climate change should not only be viewed as a negative challenge to winter tourism but also as a catalyst to drive radical structural adjustment and change. These developments should take into account the present risks and opportunities as well as foster development that is in line with the strive for environmental and socio economic sustainability. This will create a highly competitive market where customer preference is not only driven by snow availability but by the efficiency of service in some very high end but smaller less extensive resorts. Such top resorts will offer attractive offers for skiing tourists and hence reduce attention on expansive developments with less attractive offers. Artificial Snow making This is an ubiquitous strategy that is widely employed to mitigate the risk of climate change. Since its inception in 1953 at the Grossingers Resort in New York, it has grown to become the principle in the ski industry with an approximate 95% of the resorts engaged in the strategy. Its success has mainly been driven by its invaluable superior nature that offers a complete substitute to natural snow fall as well as making it possible to extend skiing durations(Daniel D. D. McGill, 2007). However, this technology is heavily dependent on temperature and is only effective in cases at low temperatures. Technological advances has seen the reduction of labor costs through the use of snow guns operated by computers. Snow making utilizes vast volumes of water and therefore the availability of water must be guaranteed for efficient blanketing of a large resort. Weather Derivatives. These are weather risk management tools structured to enable ski resorts make appropriate and informed decisions. They can be structured on snow fall temperature according to the customers specifications. Other factors that can be utilized to mitigate the effects of global warming include r4evenue diversification, cloud seeding and marketing to insulate the resorts against variability of weather by enabling them to maximumly capitalize when the weather is excellent. Conclusions Climate change and global warming remains will continue to remain key challenges in the winter tourism industry especially the ski resorts. Less snow, less glaciers and extreme weather events such as landslides are the key determinants of the future viability of ski resorts. Strategies instituted to meet the challenges of climatic change and mitigate the impacts of global warming can never be successful if implemented in isolation. It is commendable fact that the skiing industry has adopted sustainable building techniques,inculcated green principles and technology in their operations among others. These precedents are admirable but we have to admit that when taken in the global context, these measures do very little in stemming the worrying tide of global warming whose effects are felt indiscriminately. Global warming is a worldwide problem and therefore all the measures undertaken by the tourism industry must be in line with national and international guidelines that aim at reducing greenhouse gas emissions. In the future, tourist developments will not only be evaluated and judged with respect to their environmental or socio-economic compatibility and viability but they will also be assessed with respect to the climate-compatibility angle.

Eccentric and Concentric Bench Press Comparison

Eccentric and Concentric Bench Press Comparison Introduction Resistance training is an exercise modality that can be defined as a movement working against an external load resulting in physical adaptations (McArdle, Katch Katch, 2014). It is utilised by many as a means of increasing muscular strength, improving athletic performance, reducing the risk of injury and to maintain a healthy lifestyle. An average resistance training programme would incorporate a variety of static and dynamic movements whilst under an external load (Jones, 2009). Whilst the muscles are static, the fibres are in a fixed state and no change in length occurs. However, in a dynamic movement muscles go through a shortening and lengthening process. The concentric phase involving the shortening of muscle fibres, and the eccentric phase involving the lengthening of the fibres. Current literature proposes that eccentric and concentric training illicit different training responses and therefore could produce different muscular adaptations (Rosete et al. 2015). Although there are a variety of methods to provide resistance in a training sense, traditional exercises involve moving a load in opposite directions (i.e. push/pull) where there is a shortening (Concentric) and subsequent lengthening of the muscles (Eccentric). Proske (2001) describes the concentric phase as the actions that initiate movement, whereas the eccentric phase slows movement or brings it to a halt. Some research indicates that muscles acting in an eccentric fashion produce more force than when working concentrically. Other research shows eccentric movements have different fatigue patterns to concentric movements which could explain their apparent superiority. The intended purpose of this proposal is to quantify if concentric bench press yields less strength than eccentric bench press, measured via a 1 rep max max test. Literature Review As previously defined, resistance training is movement working against an external load resulting in physical adaptations. The health benefits of resistance training are widely documented with most of the literature reporting on musculoskeletal adaptations. Recently there has been an emergence of literature detailing other outcomes of resistance exercise such as benefits for metabolic disease (Jurca, 2005), bone density health (Lohman et al, 2003), all-cause mortality (Metter et al, 2002), mobility (Janssen et al, 2002) and quality of life (Levinger et al, 2007). Furthermore, resistance training provides a means of exercise for people whose current cardio vascular based regimes such as jogging or swimming have become too difficult. Based on these findings, resistance exercise is now considered an imperative component of a regular training program. The eccentric phase of a muscle action is when the force generate by a muscle is inferior to the external load. This is characterised by a lengthening of the muscle even though an actin-myosin cross bridge is formed. In this instance when actin separates from myosin it is regarded as a mechanical separating rather than chemical (Flint Hurst, 1978). In contrast, a concentric muscle action involves the actin filaments being pulled over the myosin filaments as the muscle shortens. This is commonly known as the Sliding Filament Theory (SFT).ÂÂ   SFT refers to the movement of actin and myosin sliding over one and other. (Baechle Earle, 2000). Cross bridges are separated through the splitting of an Adenosine Tri Phosphate molecule, thus making it a chemical reaction rather than mechanical. This is a more energy dependant process and should result in less trauma to the muscles. Eccentric muscle action, when used in a resistance training setting has been shown to improve neural activation (Enoka, 1996), muscular strength (Hortobagyi, 1996) and increase muscle size (Vikne et al, 2006). Enoka (1996) goes on to suggest that muscles become more resistant to fatigue when working eccentrically. Placing emphasis on the eccentric phase of an exercise has been proven in some studies to be effective at improving strength than an even split of eccentric/concentric (Brandenburg Docherty, 2002). Research has been conducted to examine the physiological and metabolic effects of concentric actions versus eccentric muscle actions. A study by Hollander et al, (2008) examined if contraction type (Eccentric/Concentric) or load (Absolute/Relative) has a greater metabolic impact on resistance exercise. Seven resistance trained men were included in the study. Their concentric 1 rep max determined for several exercises then their 1 rep max for eccentric was estimated at 20% greater. On completion of the initial 1 rep max testing, participants completed a further 2 bouts of maximum lifts in a random order: concentric only lift and an eccentric only lift. They were then assessed on rating of perceived exertion, pain rating and heart rate. Tests were conducted to take samples of blood PRE/POST exercise, and 15 minutes after exercise had finished to identify lactate and cortisol levels. To analyse the data, a repeated-measure ANOVA was used. No differences were noted between concentric and eccentric trials for pain rating and perceived exertion. Heart rate was significantly higher in every exercise except lat pulldown. Levels of lactate were significantly higher directly post exercise and 15 minutes after following concentric training compared to eccentric training. The study shows that at a relatively lower intensity, concentric and eccentric training show similar rate of perceived exertion pain perception under a relative load (%eccentric1RM= %concentric1RM +20%).ÂÂ   This suggests that you can overload the eccentric phase of an exercise with 20% more than the concentric phase and the body is not negatively affected. Heart rate was maintained at a lower threshold throughout training apart from in one instance despite the eccentric phase holding a 20% greater load. This potentially indicates that eccentric exercise could be deemed as a safer modality of exercise than concentric Enoka (1996) conducted a study highlighting the differences in concentric and eccentric muscle actions in regards to neural activity. Previous studies suggest that neuralogical factors can augment strength gains in trained (Edgerton et al, 1986) and untrained individuals (Komi, 1986) whilst also increase the efficiency in which they can lift sub-maximal loads (Ploutz et al, 1994). It is also noted that neural factors increase the synchronization of motor units (Milner-Brown et al, 1975). A motor unit is defined as motoneuron and all its associated fibres (Bachle Earle 2002). An action potential is passed through the motor neuron, this releases a hormone which passes across a neural junction resulting muscle fibre activation (Baechle Earle, 2000). To increase the force generated by a muscle, motor unit activation must increase frequency, or recruit more motor units at once. Usually motor units activate in a uniform sequence, inferior unitsÂÂ   activate first with superior units coming in to play when the external load becomes too great, commonly termed as the size principal (Baechle Earle, 2000). In order to generate maximum force, it is necessary for all of the motor units within a muscle to activate. In most people the size principle applies, lower threshold units being activated then the higher threshold as the load increases. Some research suggests that resistance exercise increases the efficiency that a person can recruit the higher threshold motor units (Sale, 1987). Enoka (1996) goes on to suggest that this differs for muscles working eccentrically. Research has identified that it is not likely to recruit all motor units during maximum eccentric contraction despite that fact that eccentric strength is usually 20% greater than concentric (Tesch et al, 1990). Aims Previous literature suggests that the strength of the eccentric portion of an exercise can be anything up to 120% greater than that of concentric (Hortobagyi, 1990). Current literature also proposes that eccentric and concentric training illicit different training responses and therefore could produce different muscular adaptations (Baechle Earle, 2000). From the previously mentioned literature, the following was hypothesised: Eccentric 1 Rep Max bench press will yield greater strength than concentric. Objectives The main objective of this proposal is to quantify the differences in eccentric and concentric bench press scores. Methodology Participants Twenty six males between the ages of 18 and 31 who have been taking part in resistance training for over 1 year volunteered for the study. For the purposes of this study resistance training experience is defined as having regularly trained bench press( 1p/w) over the year leading up to the study. Volunteers for the study where students recruited from sport and exercise science classes at The University of the West of Scotland, Hamilton Campus. It was required of the students involved in the study to firstly complete a Physical Activity Readiness Questionnaire to ensure that they were physically fit enough to engage in the study. It was also required of the students to complete an Informed Consent document outlining how the study would be carried out, how it affects them and highlighting that they have the right to withdraw themselves at any time. Exclusion criteria from the study included: orthopaedic injuries, hypertension, cardiovascular issues and abuse of anabolic agents. Current dietary intake will not be monitored throughout the study, but it will have to remain consistent throughout its entirety. Once the study begins, participants may not take part in any resistance training out with study. The assumption is made that all participants will follow all testing protocols relayed to them for completion out with the laboratory. The participant is also required to abstain from exercise that is greater than the needs for daily living during the testing period. They must also refrain from taking any ergogenic supplements or making dietary changes throughout the testing period. Protocol The study will consist of 3 testing sessions over an 8-week period. Testing will be conducted in the strength and conditioning laboratory in the University of the West of Scotland, Hamilton Campus. Participants will be split into 2 even groups for testing, concentric and eccentric. Participants will be prompted to complete an informed consent document providing their approval to take part in the study. Once the document is completed and reviewed, anthropometric measurements will be taken: weight, height and body composition. Following anthropometric measurements, participants will perform a cardiovascular warm up on a cycle ergometer for (90RPM 5 minutes). This will be followed by an incremental warm up protocol for bench pressing (10,5 and 3 repetitions). The weight used here will be self-selective and should increase with every set (Baechle Earle, 2000). All three testing sessions will include the cardio vascular warm up, bench press warm up followed by 1 Rep Max testing in eithe r eccentric/concentric bench press, depending on what group the individual has been placed in. Participants will be allowed to have a few practice attempts with an unloaded barbell to familiarise themselves with how the testing will operate. The concentric group will perform their lifts by lying supine on a bench from the chest until they can fully straighten their arm, extending the elbow. The bar will be lowered down to their chest prior to each rep to ensure that only a concentric muscle action is being measured. This will be done via a pulley system and two additional spotters positioned at either end of the barbell. When the participant is unable to completely straighten the arms to complete the concentric bench press, the repetition will be deemed a failed rep. The eccentric bench press will involve the slow and controlled lowering of a barbell from full extension down to the chest. It should take the participant three seconds to perform this movement and tempo will be kept with a metronome to help to identify successful reps. On completion of a rep the barbell will be returned to the original position via pulley system and assistance from spotters. If the participant is unable to control the descent of the bar, allowing it to touch their chest before the 3 seconds ends the repetition n will be classed as a failure. To ensure that all the participants are safe, stringent measure will be taken. Spotters will be used during all exercise sets, warm up and testing. The pulley system will be lowered to the appropriate height for each user, this will be marked to ensure consistency with the operator. Chalk will be made available on request to reduce the likelihood of the barbell slipping from the hands. Statistics All data collected in the study will be analysed using an SPSS software. The data will be initially inspected to make sure it is acceptable. The mean and standard deviation will be calculated using a paired T test which will help to identify if there is a significant difference between concentric one repetition maximums and eccentric. References Baechle, T.R., Earle, R.W. (eds.). (2000). Essentials of Strength Training and Conditioning, 2nd Edition. Human Kinetics, Champaign, IL. Brandenburg, J.P., and Docherty, D. (2002). The effects of accentuated eccentric loading on strength, muscle hypertrophy, and neural adaptations in trained individuals. Journal of Strength and Conditioning Research, 16(1), 25-32. Lohman, E.C., Cussler, T.G., Going, S.B., Houtkooper, L.B., Metcalfe, L.L., Teixeira, P.J. (2003). 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