Nicotine Addiction :: Research Analysis

Nicotine addiction Cigarette addiction is responsible for over four million deaths every year. The question most people ask is why don’t people just put down their cigarettes? Well, the answer to that often asked question is nicotine. Nicotine is a neurotransmitter that targets certain receptors in the brain. It is a chemical messenger that induces feelings of pleasure. When someone takes a hit off of a cigarette, they ingest the harmful chemicals that can cause cancer and other serious health threats. They only inhale these chemicals to get one thing and one thing only, nicotine. Curing addiction becomes harder and harder with each puff of a cigarette one takes. When nicotine is consumed, it communicates with the brain and is absorbed into receptor molecules, Doctors for years have undergone hundreds of experimental studies on the human brain to help understand just how these chemicals neurologically affect the brain, and which sectors of the brain are affected. This goal has not yet been accomplished due to the large amounts of receptor cells in the brain. In a study performed at the California Institute of Technology performed by Andrew Tapper, Professor Allan Collins from the University of Colorado, Several colleagues, and Henry A. Lester, the Caltech University Bren Professor of Biology revealed that nicotine affects a small subunit of the brain called alpha four. This subunit of the brain increases levels of pleasure, response, sensitization, and increases tolerance of multiple doses of the drug nicotine. Many people do not know what nicotine does inside the brain. Here’s how it works when the nicotine reacts with the cells in the brain. It creates nerve impulse that jump chemically across a gap between two different nerve cells. This action is called a synapse. The neurotransmitter acetylcholine is used in this process and is used to affect specified receptors in the brain targeting post-synaptic nerve cells. After this process, the feel good brain messenger, dopamine, is released. This chemical is released into the brain creating an extreme high. The acetylcholine is then supposed to diminish the dopamine after completing its task. The drug disguises itself as acetylcholine causing the process of dopamine release to last for minutes rather than milliseconds. In several lab studies performed on mice in the 1990’s, results concluded that nicotine also affects the subunits of the brain labeled beta two. Knowing how this drug affects many different subunits shows just how complicated it is to find a cure for addiction to this drug.

A Game of Thrones Chapter Forty-four

Sansa He wouldn't send Ser Loras,† Sansa told Jeyne Poole that night as they shared a cold supper by lamplight. â€Å"I think it was because of his leg.† Lord Eddard had taken his supper in his bedchamber with Alyn, Harwin, and Vayon Poole, the better to rest his broken leg, and Septa Mordane had complained of sore feet after standing in the gallery all day. Arya was supposed to join them, but she was late coming back from her dancing lesson. â€Å"His leg?† Jeyne said uncertainly. She was a pretty, dark-haired girl of Sansa's own age. â€Å"Did Ser Loras hurt his leg?† â€Å"Not his leg,† Sansa said, nibbling delicately at a chicken leg. â€Å"Father's leg, silly. It hurts him ever so much, it makes him cross. Otherwise I'm certain he would have sent Ser Loras.† Her father's decision still bewildered her. When the Knight of Flowers had spoken up, she'd been sure she was about to see one of Old Nan's stories come to life. Ser Gregor was the monster and Ser Loras the true hero who would slay him. He even looked a true hero, so slim and beautiful, with golden roses around his slender waist and his rich brown hair tumbling down into his eyes. And then Father had refused him! It had upset her more than she could tell. She had said as much to Septa Mordane as they descended the stairs from the gallery, but the septa had only told her it was not her place to question her lord father's decisions. That was when Lord Baelish had said, â€Å"Oh, I don't know, Septa. Some of her lord father's decisions could do with a bit of questioning. The young lady is as wise as she is lovely.† He made a sweeping bow to Sansa, so deep she was not quite sure if she was being complimented or mocked. Septa Mordane had been very upset to realize that Lord Baelish had overheard them. â€Å"The girl was just talking, my lord,† she'd said. â€Å"Foolish chatter. She meant nothing by the comment.† Lord Baelish stroked his little pointed beard and said, â€Å"Nothing? Tell me, child, why would you have sent Ser Loras?† Sansa had no choice but to explain about heroes and monsters. The king's councillor smiled. â€Å"Well, those are not the reasons I'd have given, but . . . † He had touched her cheek, his thumb lightly tracing the line of a cheekbone. â€Å"Life is not a song, sweetling. You may learn that one day to your sorrow.† Sansa did not feel like telling all that to Jeyne, however; it made her uneasy just to think back on it. â€Å"Ser Ilyn's the King's Justice, not Ser Loras,† Jcyne said. â€Å"Lord Eddard should have sent him.† Sansa shuddered. Every time she looked at Ser Ilyn Payne, she shivered. He made her feel as though something dead were slithering over her naked skin. â€Å"Ser Ilyn's almost like a second monster. I'm glad Father didn't pick him.† â€Å"Lord Beric is as much a hero as Ser Loras. He's ever so brave and gallant.† â€Å"I suppose,† Sansa said doubtfully. Beric Dondarrion was handsome enough, but he was awfully old, almost twenty-two; the Knight of Flowers would have been much better. Of course, Jeyne had been in love with Lord Beric ever since she had first glimpsed him in the lists. Sansa thought she was being silly; Jeyne was only a steward's daughter, after all, and no matter how much she mooned after him, Lord Beric would never look at someone so far beneath him, even if she hadn't been half his age. It would have been unkind to say so, however, so Sansa took a sip of milk and changed the subject. â€Å"I had a dream that Joffrey would be the one to take the white hart,† she said. It had been more of a wish, actually, but it sounded better to call it a dream. Everyone knew that dreams were prophetic. White harts were supposed to be very rare and magical, and in her heart she knew her gallant prince was worthier than his drunken father. â€Å"A dream? Truly? Did Prince Joffrey just go up to it and touch it with his bare hand and do it no harm?† â€Å"No,† Sansa said. â€Å"He shot it with a golden arrow and brought it back for me.† In the songs, the knights never killed magical beasts, they just went up to them and touched them and did them no harm, but she knew Joffrey liked hunting, especially the killing part. Only animals, though. Sansa was certain her prince had no part in murdering Jory and those other poor men; that had been his wicked uncle, the Kingslayer. She knew her father was still angry about that, but it wasn't fair to blame Joff. That would be like blaming her for something that Arya had done. â€Å"I saw your sister this afternoon,† Jeyne blurted out, as if she'd been reading Sansa's thoughts. â€Å"She was walking through the stables on her hands. Why would she do a thing like that?† â€Å"I'm sure I don't know why Arya does anything.† Sansa hated stables, smelly places full of manure and flies. Even when she went riding, she liked the boy to saddle the horse and bring it to her in the yard. â€Å"Do you want to hear about the court or not?† â€Å"I do,† Jeyne said. â€Å"There was a black brother,† Sansa said, â€Å"begging men for the Wall, only he was kind of old and smelly.† She hadn't liked that at all. She had always imagined the Night's Watch to be men like Uncle Benjen. In the songs, they were called the black knights of the Wall. But this man had been crookbacked and hideous, and he looked as though he might have lice. If this was what the Night's Watch was truly like, she felt sorry for her bastard half brother, Jon. â€Å"Father asked if there were any knights in the hall who would do honor to their houses by taking the black, but no one came forward, so he gave this Yoren his pick of the king's dungeons and sent him on his way. And later these two brothers came before him, freeriders from the Dornish Marches, and pledged their swords to the service of the king. Father accepted their oaths . . . â€Å" Jeyne yawned. â€Å"Are there any lemon cakes?† Sansa did not like being interrupted, but she had to admit, lemon cakes sounded more interesting than most of what had gone on in the throne room. â€Å"Let's see,† she said. The kitchen yielded no lemon cakes, but they did find half of a cold strawberry pie, and that was almost as good. They ate it on the tower steps, giggling and gossiping and sharing secrets, and Sansa went to bed that night feeling almost as wicked as Arya. The next morning she woke before first light and crept sleepily to her window to watch Lord Beric form up his men. They rode out as dawn was breaking over the city, with three banners going before them; the crowned stag of the king flew from the high staff, the direwolf of Stark and Lord Beric's own forked lightning standard from shorter poles. It was all so exciting, a song come to life; the clatter of swords, the flicker of torchlight, banners dancing in the wind, horses snorting and whinnying, the golden glow of sunrise slanting through the bars of the portcullis as it jerked upward. The Winterfell men looked especially fine in their silvery mail and long grey cloaks. Alyn carried the Stark banner. When she saw him rein in beside Lord Beric to exchange words, it made Sansa feel ever so proud. Alyn was handsomer than Jory had been; he was going to be a knight one day. The Tower of the Hand seemed so empty after they left that Sansa was even pleased to see Arya when she went down to break her fast. â€Å"Where is everyone?† her sister wanted to know as she ripped the skin from a blood orange. â€Å"Did Father send them to hunt down Jaime Lannister?† Sansa sighed. â€Å"They rode with Lord Beric, to behead Ser Gregor Clegane.† She turned to Septa Mordane, who was eating porridge with a wooden spoon. â€Å"Septa, will Lord Beric spike Ser Gregor's head on his own gate or bring it back here for the king?† She and Jeyne Poole had been arguing over that last night. The septa was horror-struck. â€Å"A lady does not discuss such things over her porridge. Where are your courtesies, Sansa? I swear, of late you've been near as bad as your sister.† â€Å"What did Gregor do?† Arya asked. â€Å"He burned down a holdfast and murdered a lot of people, women and children too.† Arya screwed up her face in a scowl. â€Å"Jaime Lannister murdered Jory and Heward and Wyl, and the Hound murdered Mycah. Somebody should have beheaded them.† â€Å"It's not the same,† Sansa said. â€Å"The Hound is Joffrey's sworn shield. Your butcher's boy attacked the prince.† â€Å"Liar,† Arya said. Her hand clenched the blood orange so hard that red juice oozed between her fingers. â€Å"Go ahead, call me all the names you want,† Sansa said airily. â€Å"You won't dare when I'm married to Joffrey. You'll have to bow to me and call me Your Grace.† She shrieked as Arya flung the orange across the table. It caught her in the middle of the forehead with a wet squish and plopped down into her lap. â€Å"You have juice on your face, Your Grace,† Arya said. It was running down her nose and stinging her eyes. Sansa wiped it away with a napkin. When she saw what the fruit in her lap had done to her beautiful ivory silk dress, she shrieked again. â€Å"You're horrible,† she screamed at her sister. â€Å"They should have killed you instead of Lady!† Septa Mordane came lurching to her feet. â€Å"Your lord father will hear of this! Go to your chambers, at once. At once!† â€Å"Me too?† Tears welled in Sansa's eyes. â€Å"That's not fair.† â€Å"The matter is not subject to discussion. Go!† Sansa stalked away with her head up. She was to be a queen, and queens did not cry. At least not where people could see. When she reached her bedchamber, she barred the door and took off her dress. The blood orange had left a blotchy red stain on the silk. â€Å"I hate her!† she screamed. She balled up the dress and flung it into the cold hearth, on top of the ashes of last night's fire. When she saw that the stain had bled through onto her underskirt, she began to sob despite herself. She ripped off the rest of her clothes wildly, threw herself into bed, and cried herself back to sleep. It was midday when Septa Mordane knocked upon her door. â€Å"Sansa. Your lord father will see you now.† Sansa sat up. â€Å"Lady,† she whispered. For a moment it was as if the direwolf was there in the room, looking at her with those golden eyes, sad and knowing. She had been dreaming, she realized. Lady was with her, and they were running together, and . . . and . . . trying to remember was like trying to catch the rain with her fingers. The dream faded, and Lady was dead again. â€Å"Sansa.† The rap came again, sharply. â€Å"Do you hear me?† â€Å"Yes, Septa,† she called out. â€Å"Might I have a moment to dress, please?† Her eyes were red from crying, but she did her best to make herself beautiful. Lord Eddard was bent over a huge leather-bound book when Septa Mordane marched her into the solar, his plaster-wrapped leg stiff beneath the table. â€Å"Come here, Sansa,† he said, not unkindly, when the septa had gone for her sister. â€Å"Sit beside me.† He closed the book. Septa Mordane returned with Arya squirming in her grasp. Sansa had put on a lovely pale green damask gown and a look of remorse, but her sister was still wearing the ratty leathers and roughspun she'd worn at breakfast. â€Å"Here is the other one,† the septa announced. â€Å"My thanks, Septa Mordane. I would talk to my daughters alone, if you would be so kind.† The septa bowed and left. â€Å"Arya started it,† Sansa said quickly, anxious to have the first word. â€Å"She called me a liar and threw an orange at me and spoiled my dress, the ivory silk, the one Queen Cersei gave me when I was betrothed to Prince Joffrey. She hates that I'm going to marry the prince. She tries to spoil everything, Father, she can't stand for anything to be beautiful or nice or splendid.† â€Å"Enough, Sansa.† Lord Eddard's voice was sharp with impatience. Arya raised her eyes. â€Å"I'm sorry, Father. I was wrong and I beg my sweet sister's forgiveness.† Sansa was so startled that for a moment she was speechless. Finally she found her voice. â€Å"What about my dress?† â€Å"Maybe . . . I could wash it,† Arya said doubtfully. â€Å"Washing won't do any good,† Sansa said. â€Å"Not if you scrubbed all day and all night. The silk is ruined.† â€Å"Then I'll . . . make you a new one,† Arya said. Sansa threw back her head in disdain. â€Å"You? You couldn't sew a dress fit to clean the pigsties.† Their father sighed. â€Å"I did not call you here to talk of dresses. I'm sending you both back to Winterfell.† For the second time Sansa found herself too stunned for words. She felt her eyes grow moist again. â€Å"You can't,† Arya said. â€Å"Please, Father,† Sansa managed at last. â€Å"Please don't.† Eddard Stark favored his daughters with a tired smile. â€Å"At last we've found something you agree on.† â€Å"I didn't do anything wrong,† Sansa pleaded with him. â€Å"I don't want to go back.† She loved Mng's Landing; the pagaentry of the court, the high lords and ladies in their velvets and silks and gemstones, the great city with all its people. The tournament had been the most magical time of her whole life, and there was so much she had not seen yet, harvest feasts and masked balls and mummer shows. She could not bear the thought of losing it all. â€Å"Send Arya away, she started it, Father, I swear it. I'll be good, you'll see, just let me stay and I promise to be as fine and noble and courteous as the queen.† Father's mouth twitched strangely. â€Å"Sansa, I'm not sending you away for fighting, though the gods know I'm sick of you two squabbling. I want you back in Winterfell for your own safety. Three of my men were cut down like dogs not a league from where we sit, and what does Robert do? He goes hunting.† Arya was chewing at her lip in that disgusting way she had. â€Å"Can we take Syrio back with us?† â€Å"Who cares about your stupid dancing master?† Sansa flared. â€Å"Father, I only just now remembered, I can't go away, I'm to marry Prince Joffrey.† She tried to smile bravely for him. â€Å"I love him, Father, I truly truly do, I love him as much as Queen Naerys loved Prince Aemon the Dragonknight, as much as Jonquil loved Ser Florian. I want to be his queen and have his babies.† â€Å"Sweet one,† her father said gently, â€Å"listen to me. When you're old enough, I will make you a match with a high lord who's worthy of you, someone brave and gentle and strong. This match with Joffrey was a terrible mistake. That boy is no Prince Aemon, you must believe me.† â€Å"He is!† Sansa insisted. â€Å"I don't want someone brave and gentle, I want him. We'll be ever so happy, just like in the songs, you'll see. I'll give him a son with golden hair, and one day he'll be the king of all the realm, the greatest king that ever was, as brave as the wolf and as proud as the lion.† Arya made a face. â€Å"Not if Joffrey's his father,† she said. â€Å"He's a liar and a craven and anyhow he's a stag, not a lion.† Sansa felt tears in her eyes. â€Å"He is not! He's not the least bit like that old drunken king,† she screamed at her sister, forgetting herself in her grief. Father looked at her strangely. â€Å"Gods,† he swore softly, â€Å"out of the mouth of babes . . . † He shouted for Septa Mordane. To the girls he said, â€Å"I am looking for a fast trading galley to take you home. These days, the sea is safer than the kingsroad. You will sail as soon as I can find a proper ship, with Septa Mordane and a complement of guards . . . and yes, with Syrio Forel, if he agrees to enter my service. But say nothing of this. It's better if no one knows of our plans. We'll talk again tomorrow.† Sansa cried as Septa Mordane marched them down the steps. They were going to take it all away; the tournaments and the court and her prince, everything, they were going to send her back to the bleak grey walls of Winterfell and lock her up forever. Her life was over before it had begun. â€Å"Stop that weeping, child,† Septa Mordane said sternly. â€Å"I am certain your lord father knows what is best for you.† â€Å"It won't be so bad, Sansa,† Arya said. â€Å"We're going to sail on a galley. It will be an adventure, and then we'll be with Bran and Robb again, and Old Nan and Hodor and the rest.† She touched her on the arm. â€Å"Hodor!† Sansa yelled. â€Å"You ought to marry Hodor, you're just like him, stupid and hairy and ugly!† She wrenched away from her sister's hand, stormed into her bedchamber, and barred the door behind her.

Economics Outline Essay - 951 Words

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Approaches Of Psychology And Psychology - 1465 Words

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Freud combined the then current cognitive notions of consciousness, perception and memory with ideas of biologically based instincts, to make a bold new theory of psychodynamics. Freuds theory, which forms the basis of the psychodynamic approach, represented a challenge

Fast Food Is Responsible For The Biggest Legacy Of Food...

Golden Arches Fast food is the term given to food that is prepared and served very quickly, first popularized in the 1950s in the United States. The â€Å"fast food† term refers to food sold in a restaurant or store with preheated or precooked ingredients, and served to the customer in a packaged form for take-out/take-away. Once you take your first bite you only find yourself coming back for more. Fast food is responsible for the biggest legacy in food industry, plays the biggest role in our economy and has taken part in our society’s pop culture. â€Å"As automobiles became popular and more affordable following World War lI, drive-in restaurants were introduced.† (Graczyk, Mark. Drive-in Restaurants of the ’50s and ’60s. The Daily News†¦show more content†¦People are not going out to buy these products they prefer to go out to consume food already made. Since McDonald’s is the biggest purchaser of the main food consumed in America, they are controlling what the animals are being fed. To keep everything on fast food menus at a low price companies have to find new ways to make more with less money. â€Å"Fast food serves 50 million Americans daily.† (â€Å"How Fast Food Has Changed Our Nation. One Green Planet. N.p., n.d.) Millions of people in America depend on fast food for breakfast, lunch and dinner. With 160,000 fast food restaurants there is one on every street corner making it easier than it ever has been before to buy fast food. McDonalds alone opens 2000 new restaurants annually. â€Å"Fast food industry is the highest employer of minimum wage workers in the country† (Langfield, Amy. In Tough Economy, Fast Food Workers Grow Old. NBC News. N.p., Apr.-May 2013). You would think that most of their employers would be teenagers wanting to earn extra pocket change; actually the average worker is from twenty-five to twenty-nine years old. However these people don’t want the job for extra cash, they’re trying to make an honest living. Car payments, phone bill, electric, water, gas, rent, living from pay check to pay check. â€Å"In the United States, consumers spent $160 billion on fast food in 2012 (up from$6 billion in 1970). In total the US restaurant industry had projected sales of $660.5 billion in 2013.†

Case Study about Dominant Market Segment of Adidas’ Target Market

Question: Young people are a dominant market segment of Adidas target market. Justify whether you feel that this restricts the market for their products, or do you feel that they are doing the correct thing? Answer: Its very difficult for a company to connect to all the customers in large, broad or diverse markets. Adidas has done the right thing by targeting the young people. It knows very well that it has always been associated with sports of all kind and it is something that they can serve best. Obviously as each and every individual is different so each consumer has a different set of needs and a single brand alone is not sufficient to cater each and every segment. (Perner) Adidas brand is based on the passion for distinction in sports and creative for athletes perform to as best to their ability. Youngsters are the one who follow sports more actively and are as such a brand face for them. (Wilson, 2010) As an example when the name Adidas is recalled the only thing that comes in your mind are sports, youth and a lot of energy this happens because it has positioned itself in the market as a brand that has supported many iconic athletes to achieve great things. It is very important from the point of a view of a marketer to know the target market. It is very easy and simple to explain say that you cant cover the entire market with one blanket. If Adidas as an example tries targeting everyone the message that it delivers would be undefined and wont be able to satisfy any of its customers. As for Adidas targeting is the very correct step as the customers who purchase Adidas are in accordance with anything and everything that it is offering. In this way it is a segment that would be the loyal cutomers for the Adidas whatsoever happens to it they would stick to it entirely. (Hamaleinko, 2010) As everyone knows that time and resources are the most important things wasting them on things that seem disinteresting to your business would not be suitable. Adidas has taken a smart move by targeting most of its efforts on one direction as it knows that it is better to focus your entire money and resources on pleasing and offering those customers who expect innovative and creativity from it rather than diversifying into different segments. (Belzer, 2015) For Adidas targeting has been a very profitable decision from the very start it was because of this that Adidas came to know that their demographic is the young innovative and energetic people who tried to experiment with the new stuff that was available and was being offered by Adidas. Adidas knew very well that if it fails to perform a target market analysis before launching its products, the target audience would have never known about their business because as of then they wont have know the ways to target their ,meassage to their intended audience. By learning about the needs and expectations of its target audience it has tailored its offerings before the launch so in short they dont to worry about working backward. This also helps them ensure that their each every minute and cent has been spent in a nice manner. (Hainer) In the world of globalisation it is necessary that the products are tailored to a specific customer who makes up revenue for the company.The market segmentation allowed Adidas to reach a consumer having specific needs and wants and who ssociated with it. In the long run, this has benefittes Adidas as through it is able to use its corporate resources in an effective manner and has taken batter strategic decisions. (Bose, 2012) The need for segmenting arised for Adidas as it felt that market is not homogeneous. For each and every product the market is divided into different customer groups. And it is easier for them when they know their target market. (Teece, 2010) Adidas has always believed that targeting should be done for a segment that you are after and this has helped them reach their target audience pretty easily. The major realization has been the fact that major investments in marketing are not essential to achieve the desired outcomes. The companys greater focus and high effectiveness embedded in their marketing plan has helped them in their vision and helped in attaining better returns on the capital invested. It knows that each customer has different wants, needs and tastes. Customers often want to be the fashion leads. To achieve this, they focus on purchasing certain and specific styles and are willing to pay a premium for it. Most are also shoppers who desire value for money and bargain for best value. The Adidas as an organization faces a dilemma to target the both markets simultaneously with a single product. There are cases where a high priced product may not be so valued by a bargaining customer. One of the major challenges remains the correct identification of the brands target population. The company knows that survival of the business in the competitive times is mainly based on the target populations choice and behaviour assessment and understanding what they want. They have known for a fact that brands like them who can feel the choices and bring the right products to the market have a better probability of convincing the investors. Distinguishing between audiences has made it easier for them to determine that youth is the segment that truly does help them in supporting their business and them and has made them understand that for them they are more than one time purchase customers. (Goyat, 2012) Works Cited Belzer, J. (2015)Adidas Launches Adigirl Clothing Line Targeting Female Athletes. Available at: https://www.forbes.com/sites/jasonbelzer/2015/08/06/adidas-launches-adigirl-clothing-line-targeting-female-athletes/ (Accessed: 22 August 2015). Bose, T. K. (2012) Market Segmentation and Customer Focus Strategies and Their Contribution towards Effective Value Chain Management,International Journal of Marketing Studies, . Goyat, S. (2011) The basis of market segmentation: a critical review of literature,European Journal of Business and Management, 3. Hainer, H. (2015)Strategy Overview. Available at: https://www.adidas-group.com/en/group/strategy-overview/ (Accessed: 22 August 2015). Hamaleinko, S. (no date)Adidas Target Audience. Available at: https://www.mindmeister.com/34165392/adidas-target-audience (Accessed: 22 August 2015). Perner, L. (no date)Introduction to Marketing. Available at: https://www.consumerpsychologist.com/marketing_introduction.html (Accessed: 22 August 2015).Teece, D. J. (2010) Business Models, Business Strategy and Innovation,Long Range Planning, 43(2-3), pp. 172194. doi: 10.1016/j.lrp.2009.07.003. Wilson, J. (2010)Adidas targets US youngsters for sales. Available at: https://www.ft.com/intl/cms/s/0/c13f7b72-eb3a-11df-811d-00144feab49a.html (Accessed: 22 August 2015).

V. Nascent Jurisprudence on Intergenerational Equity Essay Example

V. Nascent Jurisprudence on Intergenerational Equity Paper Introduction Over the last forty years, environmental law (both internationally and in domestic jurisdictions across the world) has increasingly been required to address the special issues created by geographically and temporally disparate damage and causes. Environmental harm can be long lasting or irreversible, or can remain undiscovered for many years, even after the practices causing it have ceased. In other words, some environmental harm is not only spatially but also temporally disconnected from its causes. Climate change presents a clear example: the harm likely to be caused by climate change in the future will be far removed in time from its causes (which include greenhouse gas emissions dating from the time of the Industrial Revolution). Environmental law has come a long way since its early focus on assigning liability for point source pollution. Nonetheless, a better capacity to deal with the temporally disparate nature of the causes and effects of environmental damage is long overdue. The principle of intergenerational equity, which provides a particular focus on temporal relations, has great potential as means of resolving environmental problems in which current interests conflict with the reasonably identifiable interests of future generations. This Chapter’s analysis of the jurisprudence relating to the principle, hitherto underexamined, provides a new focus on the practical implications of the principle of intergenerational equity when enforced by courts. Before going further, it is necessary to define the concept of intergenerational equity, both in its general sense and in the legal context in which it occurs in this Chapter. At its most basic level, a principle of intergenerational equity is a principle that promotes equitable relationships between generations. We will write a custom essay sample on V. Nascent Jurisprudence on Intergenerational Equity specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on V. Nascent Jurisprudence on Intergenerational Equity specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on V. Nascent Jurisprudence on Intergenerational Equity specifically for you FOR ONLY $16.38 $13.9/page Hire Writer It is based on the notion that justice between generations requires equity between generations. As with any application of equity, what constitutes an equitable relationship in an intergenerational context is essentially a normative question. That is to say, a principle of intergenerational equity should address such issues as whether all people have equal moral status (or, practically speaking, whether and to what extent future generations’ interests should be discounted), and what distributive principles should apply between generations. What a principle of intergenerational equity would require in any one case is likely to vary; this is why an examination on real case law on the principle is so useful. While a general definition of intergenerational equity is therefore in essence a framework (an idea discussed further below), several observations can be made about the principle in the abstract. First, in distinction to most principles of equity, a principle of intergenerational equity does not seek to address imbalances within society, but rather to preserve opportunity universally for future generations; it is focused on temporal rather than geographic distributional issues. Second, the timeframe over which a principle of intergenerational equity can be said to operate must, for practical purposes, be limited. The classical economics approach of applying a discount rate to future values is useful for comparing options or impacts over the near future, but becomes problematic over long timeframes, when future lives at any meaningful discount rate become nearly worthless. If the principle of intergenerational equity is to serve a useful purpose, the timeframe over which it is considered must have some inherent relevance to decision-makers (whether legislators or jurors); it must be able to form part of a narrative about what justice requires. Relevant timeframes over which a principle operates therefore could be, for example, sixty years (the rough time lapse between a grandparent’s birth that of her grandchild), or ninety years (the length of a long human life). The exact timeframe relevant to the principle may vary as long as it has some underlying meaning for decision-makers. In a legal context, the definition of intergenerational equity becomes more solid. The most cited definition of intergenerational equity in a legal context is that of Edith Brown Weiss, who presented a theory of intergenerational equity in 1989, writing from an international environmental law perspective. Her premise is that ‘[e]very generation needs to pass the Earth and our natural and cultural resources on in at least as good condition as we received them.’ According to Brown Weiss, three principles of intergenerational equity can be derived from this premise. These principles require that the current generation: ‘Conserv[e] the diversity of the natural resource base so that future generations can use it to satisfy their on values’; ‘Ensur[e] the quality of the environment is on balance comparable between generations’; and Pro vide ‘non-discriminatory access among generations to the Earth and its resources.’ While providing some substance to the concept, Brown Weiss’s definition nonetheless leaves much open to interpretation. Similarly, international law provides a sense of what a principle of intergenerational equity might require, but references to the principle remain vague. For example, Principle 3 of the Rio Declaration on Environment and Development (1992) states that ‘the right to development must be fulfilled so as to equitably meet developmental and environmental needs of present and future generations.’ Refining the definition further, at a domestic level, Australian law provides the strongest exemplar of the principle; in Australia a single statement of the principle of intergenerational equity exists throughout the state and territory legislation: the present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations. This particular formulation makes no explicit statement about the moral status of future generations or the way in which resources should be distributed over time: these esse ntial concerns have been left to the judiciary to determine through case law. At all levels therefore – general and legal, international and domestic – definitions or statements of intergenerational equity provide little more than a framework upon which enforceable requirements might be built. For this reason, it is jurisprudence, the practical application of the principle of intergenerational equity, that provides the strongest insight into its practical implications. Scholarship on intergenerational equity over the years has been largely normative in character – it seeks to explain why a principle of intergenerational equity is desirable. Much less work has been done to understand the practical implications of judges’ application of the principle to factual situations. This Chapter seeks to fill that gap. A review of relevant literature and case law internationally shows that very few cases have addressed the concept of intergenerational equity. Only in Australia does a nascent jurisprudence on the principle of intergenerational equity appear to have formed. This Chapter therefore presents an analysis of the existing jurisprudence on intergenerational equity. The principle is striking in its ambition. As the examination of its definition indicates, it has received attention on the world stage, most notably as a concept informing a number of international conventions, including, most obviously, the Rio Declaration on Environment and Development (1992). It is somewhat surprising, then, that it has thus far had limited application in practice. Nonetheless, the ramifications of its application, however infrequent, must not be underestimated. The most significant case law in the field internationally has been generated in Australia; three decisions from the New South Wales Land and Environment Court are examined here: Gray v Minister for Planning, Taralga Landscape Guardians Inc v Minister for Planning, and Walker v Minister for Planning. The use of Australian cases to elucidate the nature and requirements of the principle should not be construed as limiting the arguments and implications of this work to the Australian context. On the contrary, the issues raised in this Chapter are relevant to all common law jurisdictions and go to the heart of humanity’s prospects for addressing long-term environmental problems. The Australian case law on intergenerational equity raises several salient issues. First, Australia’s legislative provision with respect to intergenerational equity leaves much of the responsibility for determining the content or practical consequences of the principle to judges. Given the difficult y inherent in legislating for long-term goals, these cases highlight the potential for the judiciary, as an independent and tenured political branch, to develop systematic protection for the interests of future generations. Second, the Australian example suggests that legislative temptation might be overcome by judicial foresight and prudence in this area. If this is true, its implications for democracy should be assessed. Third, the case law indicates that the principle of intergenerational equity requires decision-makers to consider cumulative environmental impact, hinting at a radical change in the way that environmental harm is assessed: it represents a clear departure from earlier interpretations of environmental harm, which were largely concerned with point source pollution (pollution originating an identifiable and discrete time and place). It also underscores a judicial willingness to recognise the long time-horizon of many environmental problems. Fourth, cases on the princi ple of intergenerational equity may require judges to prioritise the interests of future generations over those of current generations to some extent. As such, an examination of the early case law on intergenerational equity must bring us to question whether intergenerational equity and intra-generational equity are mutually reinforcing, as is often claimed. These points are significant. Finally, a set of implications can be drawn from the fact that all of these cases are all based in administrative law. While the use of administrative law as a form of environmental redress has advantages in the context of the principle of intergenerational equity (in particular, it provides a preventative rather than reactive remedy), it also has several limitations. In particular, the broader applicability of decisions made under the New South Wales Land and Environment Court’s special merits review jurisdiction is somewhat uncertain. Moreover, there appears to be a trend toward viewing the principle of intergenerational equity as an element environmental impact assessment, rather than a broad principle of environmental law; this risks limiting its scope. The Chapter proceeds as follows. The first section outlines where the principle of intergenerational equity is situated within both international law and domestic jurisdictions. The second section looks at how courts have given effect to the principle in practice, focusing on the Australian context, where the most relevant cases appear. Three cases from the Land and Environment Court in New South Wales are analysed: Gray v Minister for Planning, Taralga Landscape Guardians Inc v Minister for Planning, and Walker v Minister for Planning, all of which have contributed to the nascent practical formulation of the principle of intergenerational equity. The final section discusses the implications of these decisions for environmental law both in Australia and beyond. What is intergenerational equity? The concept of interge nerational equity (which is sometimes described as a principle, and other times merely a concept or theory) presents a potential legal solution to environmental problems whose effects are likely to be spread unevenly over time, or across generations, because of its explicit reference (in the legislation relevant to this Chapter) to needs or benefit of future generations. Before wading into the legal potential of the concept, however, it is worth briefly tracing its relevance in philosophy and economics, as these have direct bearing on its use in law. Part of the failure of law to facilitate justice effectively over extended time periods within the context of the environment is a product of the difficulty more generally of constructing a satisfactory regime for determining justice between individuals who are not contemporaries. Only relatively recently have Western philosophers included the question of justice between generations in more detailed and sophisticated theories of justice . In doing so, they have addressed questions arising from the wider notion of justice between generations: how do we know what future generations will want or need? How do we determine what is just for people who do not yet exist? And how do we prioritise justice for future generations when there is an abundance of injustice within the current generation? Many philosophers, including John Rawls, see justice between generations as reliant on a sort of intergenerational social contract. Brown Weiss relies on a similar notion of intergenerational obligation to justify her ‘Planetary Trust’ argument, which states that each generation holds the planet on trust for the next. By contrast, others have argued that a comprehensive understanding of intergenerational justice must find foundations outside of the notion of social contract. For example, some have situated a basis for cultivating intergenerational justice within individuals’ self-interest, or within the vulnerab ility of future generations vis-Ã  -vis current generations. It is beyond the scope of this Chapter to evaluate these competing theoretical bases for determining justice between generations. However, it is worth stressing that for some, the questions raised above suggest that justice between generations can be achieved by the attainment of equity between generations. It is this approach, largely through the influence of Brown Weiss and the Rio Conference, that has influenced the cases examined in this Chapter, and the development of much legal thinking on the topic more generally. Economists have also addressed the concept of intergenerational equity, focussing largely on how discount rates should be set in order compare policies whose effects will be felt over long timeframes, by many generations. The setting of a discount rate has deep ethical implications. As Derek Parfit and Tyler Cowen note, with a discount rate of 10 percent, one life today is worth the equivalent of one mill ion lives in 145 years. Moreover, the setting of a discount rate relies on a series of uncertain assumptions about the future. It does, however, have practical value for policy evaluation. For example, according to the Organisation of Economic Cooperation and Development, the Netherlands and Norway use ‘generational accounts’ in order to help determine the fiscal sustainability of current government projects. The United Kingdom and the United States have the ability to produce generational accounts, but have recently stopped doing so. In generational accounting, the ethical implications of discount rates become practical. Not surprisingly, as Paul Portney and John Weyant note, ‘even the best minds in the [economic] profession’ feel a sense of ‘unease’ about discounting. The difficulty that economists face in selecting an appropriate discount rate is a testament to the complex ethical and practical issues surrounding the concept of intergenerati onal equity. In law, the concept of intergenerational equity remains largely in the realm of theory; we are unsure, often, of what it signifies in practice. This is partially due to the definitional vagueness of the concept. For example, the terms of the concept, as they appear in Principle 3 of the Rio Declaration (‘the right to development must be fulfilled so as to equitably meet developmental and environmental needs of present and future generations’), are so wide that they give little insight into how they might be applied in a particular factual situation. This formulation of the concept immediately raises a number of questions, including what ought to happen if members of different generations prefer different outcomes to the same problem; the Rio Declaration’s notion of intergenerational equity disregards the potential for conflict within a generation. The question of how effect might be given to such terms, and whether they indicate something more than m ere aspiration, is addressed below. As Birnie et al. note: ‘the essential point of the theory [of intergenerational equity], that mankind has a responsibility for the future, and that this is an inherent component of sustainable development, is incontrovertible, however expressed. The question then becomes one of implementation.’ More than anything the ambiguity surrounding the real implications of the concept have to do with its infrequent application to factual situations. This section examines the legal sources of the concept of intergenerational equity, drawing upon international law material and domestic legislation. While the term ‘intergenerational equity’ per se does not appear in any international agreement, references to concern for future generations in some international agreements suggest that a concept (and perhaps even a principle) of intergenerational equity exists. The term intergenerational equity also appears infrequently within domestic legislation in several jurisdictions around the globe. Australia is one country in which the term has found its way into a number of domestic legislative instruments. In Australian legislation, the concept is referred to as ‘the principle of intergenerational equity’, and that terminology is adopted when referring to the Australian context. Next Page – International Legal Sources of Intergenerational Equity Previous Page – Legal Context