the 1990s onwards indicates an intense burst of interest in the environmental skeptical program and is consistent with a conservative countermovement against global environmental concern". Fathers' rights movement Fathers’ Rights Groups have become a growing issue in American society. In response to the perceived high number of violent crimes committed against women by their male partners, the battered women’s movement (BWM) has been campaigning for greater awareness of domestic violence. (p. 723) With the widespread understanding that domestic violence is a serious problem in the United States and elsewhere, the BWM has found public support to create “tougher penalties against offenders and public vigilance against potential batterers, including fathers from dissolving families” (p. 723). At least partly in response to this, there has been a counter-movement of activists from the fathers’ rights movement (FRM) who argue that the battered women’s movements have created laws that targets men unfairly. Fathers’ rights groups have grown in numbers since the 1980s in Canada, the United Kingdom, Sweden, Australia, and the United States (p. 727). The fathers’ rights movement has argued that the legal system is making it difficult for them to be 'good fathers.' The FRM employs the argument that being a biological father is different from being a social father because a biological father is simply the individual who makes a genetic contribution, while a social father is one who engages in all of their children’s activities (p. 727) The FRMs "have tapped into the emerging cultural notion that in the healthiest families fathers are involved in all aspects of their children's daily lives.(p. 727). Abortion The most controversial of countermovements are about whether abortion should be legal or not, which is fought by anti-abortion and pro-abortion groups. The anti-abortion group is opposed to abortion under most grounds, notably those "on request". Some anti-abortion proponents believe abortion to be justifiable when serious health issues are present for the mother, while other proponents believe that abortion is unjustifiable under any circumstance. The pro-abortion group believes that a woman has a right to abortion under all circumstances, often citing human rights do not encompass fetuses before fetal viability. Both of these groups tend to be adamant towards their views and neither sides' arguments seem to convince towards otherwise. “Although the issue of abortion is very controversial, most surveys indicate liberalization of public attitudes towards pregnancy termination between 1965 and the years immediately following Roe