Smog has been a serious problem in many cities worldwide today. High air pollution and the low eco-awareness make the situation even worse. However, what is smog actually? Why is it harmful? Check how polluted air influences our everyday life.
What is smog? Smog is a phenomenon created when fog gets mixed with air pollutants, including e.g. exhaust fumes of vehicles or smoke from manufacturing plants. Unfortunately, this is an omnipresent though unwelcome phenomenon these days. Smog presence can be noticed in most cities in different countries in the world. The more developed a city is, the higher air pollution can be observed. Such factors as the presence of large industrial plants and factories generating high amounts of pollutants contribute to the deteriorated air condition. Exhaust fumes, particularly the ones produced by older vehicles, contribute to poor air quality significantly. Why is smog harmful? Polluted air contains many toxic compounds, including nitrogen and sulphur oxide, and polycyclic aromatic hydrocarbons (PAH). Specialist research confirms that the compounds present in smog are dangerous for health. All results of measurements related to that are disclosed and available on the website of the Chief Inspectorate Of Environmental Protection. The measurements usually consider the concentrations of the following pollutants: ● Benzene (C6H6) ● Sulphur dioxide (SO2) ● Nitrogen dioxide (NO2) ● Ozone (O3) ● PM10 dust ● PM2.5 dust ● Carbon oxide (CO) This is the grounds for determining the air quality index using PM 2.5 scale and its value can range from 0 to 300+. 0–50 GOOD The air quality is considered satisfactory and the pollution constitutes low risk or its absence. 51-100 MEDIUM The air quality is acceptable but some pollutants may be moderately harmful for a very low number of people highly sensitive to air pollutants. 101-150 UNHEALTHY FOR SENSITIVE PEOPLE In sensitive people, adverse health effects may occur. Most population may not experience any adverse symptoms. 151-200 UNHEALTHY Adverse health effects may occur in anyone. The sensitive people may experience more serious health effects. 201-300 HIGHLY UNHEALTHY Health alert, alarm level. Highly probable adverse impact on the whole population. 300+ LIFE HAZARD Health alarm: anyone can experience more serious health effects How to read the smog measurement? When measuring air quality, particular attention is attached to the presence of atmospheric aerosols in smog. Those are any particles and dusts entering the atmosphere. The higher their concentration is, the worse the quality of air we inhale. There are two basic smog measurement scales based on the particle size: · PM 2.5 — the particles sized 2.5 micrometers and smaller. Those are mainly reactive organic and inorganic compounds, including ammonium nitrate. · PM10 — larger particles, sized 10 micrometers or smaller. Those are primarily the relatively inert chemical compounds including silica or metal oxides. Globally, the 5-step scale from 0 to 300 and more mg of PM 2.5 particles is usually used. Where is the pollution the highest and where it is the lowest? The most polluted cities are the Asian metropolises, including those in China, India, Bangladesh and Pakistan (more than 300 of PM2.5 particles). The cleanest air can be found in the cities in North America and Australia. The cities with clean air include, however, also two Asian ones, i.e. Kuching in Malaysia and Krasnoyarsk in Siberia. When it comes to European cities, the ones with the highest smog level include: ● Belgrade ● Sarajevo ● Zagreb ● Wrocław ● Kiev The cleanest air can be found in West European cities: ● Berlin ● Milan ● Bern ● Lyon ● Skopje ● Kraków Practical effects of smog in cities Although the most obvious and significant effect of smog is health problems and their complications, high air pollution has other practical adverse effects. One of them is the real property price decrease. The mean price of one square meter is conditional on many factors. One of the most important ones is the exact location. The real properties situated in industrial areas with higher air pollution are cheaper than the ones in places with lower smog burden, including green areas or larger water reservoirs. Nonetheless, one of the most expensive options has been living in the city center where pollution can be much higher than on the outskirts. However, flat prices are determined primarily by demand. The prices do not decrease until the interest in real properties in polluted city areas does not fall. However, the attitude changes in line with the changing eco-awareness which offers hope for the future. You must not forget also that the argument concerning unhealthy air can be used when negotiating the price of your future flat! Flat insurance is what matters most Irrespective of what flat and location we choose ultimately, we must not forget about the appropriate insurance. We can find offers by many insurance companies on the market now. To check the best one for you, check various flat insurance offers and compare them in terms of the policy price and scope. The basic one should include the following: ● Insurance of the walls of your flat or house ● Insurance of the real property fit-out ● Third party liability insurance (different options) ● Third party liability insurance of the tenant ● Assistance insurance If you want to choose a policy adapted to your individual needs, use the calculator which will not only compare the offers by different home insurance companies but will also enable to buy a policy in several steps without leaving your home. Source: insurance comparison site rankomat
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Running an offline business nowadays is like a cup without tea because today we are living in a digital era with everything dependent on appliances and online sources. During covid times we have realized that today to make your business survive you have to walk along with the trend and bring required changes to your business. During these times many businesses have joined the digital community and excelled in their businesses. They have shifted to making applications and e-commerce websites to convert and increase their sales. This shift provides them with better assistance and customer support as customer feedbacks and inputs increase the overall productivity of the business. There are many app developers who can easily assist you in this shift at affordable prices as this is a one-time investment with a few maintenance charges. You can easily get the best and affordable mobile app developers in the United Kingdom. Who can help you develop your business and support your growth?
There are many reasons why you should invest in mobile app development for your business. A few of them are listed below:
Conclusion- Seeing the above benefits we can conclude how important mobile app development has become in today's era. It helps you to connect you with your target audience in a timely, location based and context specific manner which is unique to any customer. It is very difficult for anyone to survive without mobile phones in today's world and thus mobile has become a very important part of our lives and it's all because of the new applications which are coming in the market. These apps are changing our lives rapidly and in order to get things done we need these applications. Appellants, the city and its officers (collectively the city), challenged judgments of the Superior Court of Monterey County (California) and orders granting a preliminary injunction and denying their motion to set aside a default in an action by respondent corporation to have an ordinance declared unconstitutional and its enforcement enjoined.
The corporation, which occasionally delivered fish within the city, brought an action against the city to have an ordinance imposing a business license tax deemed unconstitutional and to have its enforcement enjoined. The lower court granted the order and the city appealed. It also appealed from the order denying its motion to set aside a default judgment against it. The court was of the opinion that the trial court's refusal to set aside the city's default was to be affirmed. The court rejected the city's honest mistake of law argument and noted that the trial Mileage rate 2021 California was justified in believing that the city's failure to look up the law indicated at least indifference. With respect to the constitutionality of the ordinance, the court also affirmed. The court noted that the ordinance made no exception for occasional or incidental deliveries, and such deliveries could not be taxed. The court also noted that although the city's power to tax was clear, the method provided for in the measurement of the tax was invalid because it measured the tax by factors not entirely based on the taxable event occurring in the city. The tax was therefore discriminatory and void. The judgments in favor of the corporation and against the city in the corporation's action to have the ordinance declared unconstitutional and its enforcement enjoined was affirmed. Additionally, the order denying the city's motion to set aside a default was affirmed. Appellant corporation challenged a judgment of the Superior Court of Los Angeles County (California), which sustained a demurrer filed by respondent State in the corporation filed suit to recover money paid for franchise taxes for the year 1935. The corporation maintained that the additional franchise taxes were improperly assessed and levied against it and were void due to the retroactive nature of the legislation on which they were based. The corporation contended that the application of the amendment of § 14 to the Bank and Corporation Franchise Tax Act of California, 1929 Cal. Stat. p. 19 (amend. 1937), Cal. Gen. Laws p. 3851(1937), deprived it of vested rights which it acquired by previously paying its taxes for the year in question according to the provisions of the Act as it had existed before the amendment became effective. Under the amended statute, the corporation could not offset the losses of affiliated corporations. In affirming the trial court's judgment, the court found that the tax under consideration was in the nature of a license or franchise tax and concluded that the mere fact that the amendment was deemed retrospective with respect to its application to that portion of the year 1935 which had already elapsed when the amendment was passed did not necessarily render it void. The court determined that the legislature "left no doubt" that it intended the amendment to operate retrospectively and to apply to the levying of franchise taxes for the calendar year beginning January 1, 1935. A legislative department of government had the right to change an excise tax during the term for which it was imposed. The trial court's judgment was affirmed. Plaintiffs, the buyers of an apartment complex, appealed an order from the Superior Court of Sacramento County (California), which, in a suit asserting breach of contract and other causes of action related to a mold problem in the complex, quashed service and dismissed the complaint against defendants, two Delaware entities that were limited partners of the seller.
The seller, an Oregon limited partnership, owned and operated an apartment complex in California. The limited partners had no other property interests in California, conducted no business in California, and did not actively participate in the operations of the partnership. The court held that the limited partners' passive investment in the PAGA statute of limitations partnership did not subject them to personal jurisdiction under Code Civ. Proc., § 410.10. Although the limited partners were subject to taxation in California on partnership income earned there, merely being subject to taxation did not provide a basis for personal jurisdiction over a nonresident limited partner. The court noted that limited partnerships were treated as associations of individuals for income tax purposes but as discrete entities for other purposes, including proceedings by or against the firm, as indicated in Corp. Code, former § 15526. Moreover, even if the investment activities of a limited partner could constitute minimum contacts with respect to claims arising from those activities, the claims at issue did not arise from the limited partners' activities because they did not participate in managing the apartment complex. The court affirmed the order quashing service and dismissing the complaint against the limited partners. Petitioner insurers filed a writ of mandate seeking review of the decision from the Insurance Commissioner (California) that found that petitioners had violated the mandatory renewal provision of Proposition 103 because the provision applied to all policies in force on the effective date, regardless of the steps the insurers took to withdraw from the California insurance market. Petitioner insurers sent the Department of Insurance (Department) their applications to withdraw as insurers, along with their certificates of authority, surrendered for cancellation. The next day Proposition 103 (103) was enacted and included a mandatory renewal provision. The very next day, applicants issued notices of nonrenewal to their California automobile insurance policyholders on a blanket basis. The Department served petitioners with notices of noncompliance and alleged that the nonrenewal notices they issued after the effective date of 103 violated the mandatory renewal provision. After a hearing, the commissioner concluded that the mandatory renewal provision applied to all policies in force on the effective date of 103, regardless of steps taken by the insurer to withdraw from the insurance market. Accordingly, the commissioner found that petitioners had violated the mandatory renewal provision. Petitioners filed a writ of mandate. After review, the court concluded that the mandatory renewal provision did not apply to an insurer who had commenced the withdrawal process. Accordingly, the writ was granted and the commissioner was ordered to set aside her decision. The petition for peremptory writ of mandate was granted and respondent insurance commissioner was commanded to set aside her decision and order because the mandatory renewal provision of Proposition 103 did not apply to an insurer who had commenced the withdrawal process. Appellant sought review of judgments from the Superior Court of Fresno County (California), dismissing respondent health care providers after sustaining without leave to amend demurrers to causes of action for negligent and intentional infliction of emotional distress, concealment, interference with a physician-patient relationship, wrongful disclosure of confidential medical information, and violation of the constitutional right to privacy.
Appellant was a patient treated by respondent physician at a facility owned and operated by respondent health care providers. Appellant brought an action against respondent physician alleging negligence, and against respondent physician, respondent health care providers, and respondents' insurer, alleging negligent and intentional infliction of emotional distress, interference with the physician-patient relationship, concealment, wrongful disclosure of confidential medical information, and violation of the constitutional right to privacy. The trial Bereavement leave California sustained demurrers without leave to amend to all causes of action , except the negligence claim. Appellant sought review by writ of mandate concerning respondent physician and appellate review of the judgment dismissing the remaining respondents. The court granted a writ of mandate and reversed the judgment sustaining the demurrers to the wrongful disclosure and privacy claims, holding they were not barred by the litigation privilege of Cal. Civ. Code § 47(2 ). The court affirmed the judgment sustaining the demurrers to the other causes of action, holding they were barred by the litigation privilege. The court affirmed the judgments as to respondents alleged to have been liable for negligent and intentional infliction of emotional distress, concealment, interference with a physician-patient relationship, holding the claims were barred by the litigation privilege. The court reversed the judgment as to the claims for wrongfully disclosing confidential medical information and violating the right to privacy because these claims were not barred. Plaintiff employee filed a proposed class action against defendant employer for unpaid wages and unfair business practices. The Superior Court of Los Angeles County, California, granted the employer's motion to compel arbitration under the employment agreement and dismissed the class action claims. The employee appealed. The trial court ruled that a class action waiver did not render the arbitration agreement unconscionable because the employee did not prove that there were predictably small amounts of damages. The reviewing court assumed for the purposes of argument that the test developed in the consumer context applied and that the class action waivers would be substantively unconscionable if the dispute involved a predictably small amount of damages per class member. The court agreed with the trial court that the employee did not establish the required predictably small amounts. The complaint alleged that the employer had engaged in a scheme to defraud its employees out of overtime compensation and sought damages under Lab. Code, § 558, and Bus. & Prof. Code, § 17200. The employee presented no evidence in the trial court that the potential damages and penalties payable to class members would be predictably small. The employee could not rely for the first time on appeal on statistics from the United States Department of Labor. Moreover, there was no apparent correlation between the cited federal back wage figures and the allegations in the complaint. The court affirmed the order compelling arbitration and dismissing the class action claims. Appellant hotel owner sought relief from the judgment entered by the Superior Court of Alameda County (California), awarding relief to respondent city on appellant's cross-complaint that alleged that a business license tax ordinance passed by respondent violated the equal protection clause of the constitution. Respondent had filed suit to collect the taxes under the contested ordinance.
Respondent city enacted a business license tax ordinance, which required that certain businesses pay annual taxes. Respondent filed a complaint to collect unpaid business license taxes, and appellant hotel owner filed a cross-complaint for declaratory relief, alleging that the ordinance violated the equal protection clause of the constitution. The trial Defense lawyerentered judgment for respondent. Appellant sought relief. The court held that appellant was subject to a business license tax irrespective of the nature of the legal relationship between the provider and the guest. Appellant next argued that even if the disputed section of the ordinance applied to the hotel operation, it was invalid because it contravened the equal protection clause of the Constitution. The court held that the ordinance was enacted for rational reasons, and a mere disparity in the tax rate did not provide a legitimate reason to overturn the ordinance on equal protection grounds. The court concluded that the ordinance was constitutionally justified and that appellant's contention that the tax classification in the ordinance automatically failed was wrong; thus, the court affirmed the judgment. The court affirmed the judgment of the trial court upholding the business license tax ordinance because the business tax was enacted upon a rational basis, and a disparity in tax rates did not violate the equal protection clause of the constitution. Therefore, the ordinance was not contrary to equal protection standards. Appellants, two excursion providers, sought review of a summary judgment from the Superior Court of Los Angeles County (California) entered against them and in favor of respondent, a trade association for the sight-seeing and tour service industry, on their cross-complaint seeking equitable indemnity in a personal injury action. The court affirmed a summary judgment in favor of respondent, a trade association for the sight-seeing and tour service industry, on a cross-complaint for equitable indemnity filed by appellants, two excursion providers. Appellants had filed the cross-complaint in connection with an underlying personal injury action brought by two tourists. The court adopted the American Motorcycle modification to the equitable indemnity rule to permit a concurrent tort-feasor to obtain partial indemnity from other concurrent tort-feasors on a comparative fault basis. Accordingly, respondent's obligation to indemnify appellant provider depended on its having been at least partially responsible for plaintiffs' injuries. The motion for summary judgment on the complaint disposed of the issue in respondent's favor. Appellants were bound, therefore, by the judgment. Although respondent and appellants were co-defendants in the main action, they were, nevertheless, adversaries as to the issues raised by respondent's motion for summary judgment on the complaint. Appellants could not litigate its cross-complaint, which raised only issues already determined by the prior judgment. The summary judgment in favor of respondent, a trade association for the sight-seeing and tour service industry, on the cross-complaint was affirmed because appellants, two excursion providers, were bound by a summary judgment on the complaint. Plaintiff franchisees sought damages from defendant franchisor based upon claims that the franchisor's agent and subagent fraudulently induced them into signing distribution contracts. The Superior Court of Santa Clara County found that the franchisor was liable for the false representations because of the ostensible authority vested in the subagent, through his relationship with the agent of the franchisor. The franchisor appealed.
Franchisor knew that its agent had hired a subagent, and that the subagent was working for the agent. The agent authorized the subagent to use the franchisor's marketing materials and logo in selling distributorships to the franchisees. A principal was bound by the acts of its agent and subagent, whom were vested with ostensible authority as defined by Cal. Civ. Code §§ 2317 and 2300, when the franchisees in good faith, and without want of ordinary care, paid for the distributorships based upon the subagent's misrepresentations. Cal. Civ. Code § 2334. The court reasoned that the evidence supported the judgment against theCorporate attorney Los Angeles franchisor because the agent had the authority to hire the subagent, the franchisor knew its name and materials were used, and even when the franchisor knew of the subagent's activities it failed to take immediate action. None of the franchisees had any experience or familiarity with franchising, while the franchisor held itself out as an expert. Furthermore, none of the subagent's statements were preposterous, some were borne out by the franchisor's materials, and the initial successful transactions justified the franchisees' reliance on the subagent's authority. The court affirmed the judgment in favor of the franchisees because the franchisor's agent and subagent had ostensible authority when the false representations were made, and the franchisees' reliance was reasonable, in good faith, and their recovery was not barred by such independent investigations as they made. Finally, the damages were fairly calculated. By an application for writ of habeas corpus, petitioner prisoner challenged the validity of the ordinance under which he was convicted of carrying on within the City of Los Angeles a business where spirituous and vinous liquors were sold in quantities less than one gallon without first procuring a license. The prisoner also claimed that the trial court had been abolished by Cal. Const. art. 6, § 1 and art. 22, § 1 (1879), or lacked jurisdiction. The prisoner urged that the mayor should have been disqualified from serving as the judge. The ordinance imposed a license fee of $ 50 per month, provided that a license could not be issued without a permit, delegated to the clerk of the city council the power to issue licenses and to the board of police commissioners the power to issue and revoke permits, and declared that violations were punishable as misdemeanors. The court rejected all the prisoner's arguments and dismissed the writ. The court held that the city had the power to impose licenses for regulation, revenue, or both under Cal. Const. art. 11, §§ 11 and 12 (1879) and Los Angeles, Cal., Charter art. 1, § 5; that the ordinance was properly authenticated under Los Angeles, Cal., Charter art. 12, § 2 and Cal. Pol. Code § 1031; and that inclusion of the order for publication in the ordinance did not affect the validity of the order or the ordinance. The court could not say as a matter of law that the fee was oppressive, unreasonable, or prohibitory of trade and found that the city's power to regulate under Cal. Const. art. 11, § 11 included the power to prescribe punishments for the violation of its regulations. The court dismissed the writ of habeas corpus and remanded the prisoner. Defendant appealed a judgment from the Superior Court of Shasta County (California), which, in a jury trial, convicted defendant of multiple counts of forgery, identity theft, and other offenses.
Defendant used blank checks, credit cards, and identifying information unlawfully taken from a victim to obtain cash and to purchase items. She also used another victim's credit cards and used the other victim's driver's license as identification during some transactions. The court held that defendant was properly convicted of two violations of Pen. Code, § 530.5, subd. (a), for two uses of the driver's license on separate occasions because each separate use constituted a new crime. Defendant also was properly convicted of violating both Pen. Code, § 470, subd. (d), and Pen. Code, § 484f, subd. (b), for one act of forging a signature to a charge card receipt because § 484f, subd. (b), was not a necessarily included offense of § 470, subd. (d). Because the California false claims act evidence showed that defendant possessed both the checks of one victim and a credit card of the other victim at about the same time, this amounted to only one offense of receiving stolen property under Pen. Code, § 496, subd. (a). Defendant's failure to object to asserted instructional errors waived the issue on appeal, and the court declined to consider an ineffective assistance claim because defendant's argument was inadequate. The court reversed the judgment as to one count of receiving stolen property and one count of possession of a forged item, affirmed as to all other counts, stayed the sentences on four counts resulting in a reduction of defendant's aggregate sentence, and directed the trial court to correct the abstract of judgment accordingly. Petitioner, an international corporation, sought review of an order of respondent Superior Court of the City and County of San Francisco (California), which denied its motion to quash the service of summons effected by a copy of the summons and complaint being mailed to petitioner's head office in Japan. Petitioner international corporation was mailed a copy of a summons and complaint to its head office in Japan in an action alleging the negligence in a helmet of a corporation which had merged into petitioner. The trial court denied petitioner's motion to quash the service, and the court denied a petition for peremptory writ. The court held that petitioner had sufficient contacts with the state for in personam jurisdiction because the helmet was found in channels of retail trade, the merged corporation had a representative in the state, and the representative promoted the sales of petitioner. The court held that service was perfected because Japanese law permitted transmission by mail, a multilateral international convention did not prevent the state's exercise of jurisdiction where the trial court had jurisdiction, and notice had been given by mail with a receipt for delivery. The court held that due process was not violated by the service being written in English because testimony declared that Japanese companies involved in trade with other countries corresponded in English, petitioner executed a postal receipt written in English and French, and petitioner had English brochures. The court denied a petition for a peremptory writ, holding that the service of process to petitioner international corporation was perfected because petitioner had sufficient contacts with the state for in personam jurisdiction, international law permitted transmission by mail, and there was evidence to support the conclusion that petitioner had actual notice although service was written in English. Appellant, an injured passenger, sought review of a judgment from the Superior Court of the City and County of San Francisco (California), which entered judgment in favor of respondents, a city and county, thereby denying the passenger damages for an injury sustained while a passenger on respondents' trolley car.
The passenger challenged the trial court judgment in favor of respondents and argued that the trial court judgment was not supported by sufficient evidence and that there was no evidence on which contributory negligence could be predicated. The passenger contended that respondents failed to meet the inference of negligence based upon res ipsa loquitur, which arose when the passenger was injured as a result of the trolley car's movement. The Top class action attorneys determined that the jury was allowed to find that the passenger was guilty of contributory negligence because she stood in the moving trolley prior to its stop, failed to use the hand support bars that were provided, and her failure to hold the bars proximately caused her injury. The jury finding that the passenger was contributory negligent was sufficient to support the verdict in favor of respondents and did not require the court to determine whether the res ipsa loquitur inference was sufficiently met. The court affirmed the trial court judgment. Plaintiff developer brought an action against defendants, city water department and county water district, to determine whether the city or county controlled water service to the development. The Superior Court of Orange County (California) ruled for the city. The county appealed. The city advised the developer that it had to perform certain conditions to comply with its ordinance, Brea, Cal., Mun. Code § 21.74, which stated that a subdivision's domestic water supply within the city limits was to be provided by the city. The county, however, already had rights to provide the water service due to its general obligation bonded indebtedness. The trial court found for the city in the developer's action to determine whether the city or county controlled water service to the development. The court reversed the decision and held that the county was to provide water to the subdivision. The court held that the city was a "publicly owned utility" as defined in Cal. Water Code § 31053 because it served the public. Also, the county was a municipal corporation. The court held that § 31053 was constitutionally valid under Cal. Const. art. XI, § 19. As a result, the county, and not the city, had the legal obligation to supply water. Therefore, the city's conditions were invalid, and it was not permitted to provide water to the subdivision where that obligation was held by the county unless the city complied with § 31053. The court reversed the decision for the city and ruled for the county in the determination of which entity was to provide water to the developer's subdivision. |
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