text:
You are here
Letter dated - 2/21/12 Environmental Protection Agency
February 21, 2012
The Honorable Lisa Jackson
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
Re: Non-Hazardous Secondary Materials that are Solid Waste, Docket ID No. EPA-HQ-RCRA-2008-0329, 76 Fed. Reg. 80452 (December 23, 2011)
Dear Administrator Jackson:
The U.S. Small Business Administration Office of Advocacy (Advocacy) submits the following comments regarding the Environmental Protection Agency's (EPA) proposal to revise the final rule, regarding non-hazardous materials that are solid waste when used as fuels, that was promulgated on March 21, 2011.1
EPA promulgated the 2011 Non-hazardous Secondary Material (NHSM) final rule under the Resource Conservation and Recovery Act (RCRA) to identify which secondary materials are solid wastes when combusted as fuel. These solid wastes are subject to more costly and stringent air pollution requirements when combusted for energy recovery, as opposed to non-wastes. Although EPA's proposed changes are helpful, they do not fully address the serious economic and environmental consequences of the current rule. Small businesses have told Advocacy that EPA's approach disrupts the large economic activity associated with the recycling of secondary materials for energy recovery, with significant detriment to the environment.
Advocacy recommends that EPA should revise the legitimacy criteria for NHSM and allow facilities to self-certify those secondary materials as non-waste. In addition, EPA should use its rulemaking petition process to designate various NHSM as non-wastes, and avoid disruption of the large existing recycling infrastructure for the designated materials. This approach will facilitate the safe and beneficial recycling of secondary material, while maintaining protection of human health and the environment.
Office of Advocacy
Advocacy was established by Congress under Pub. L. 94-305 to represent the views of small entities before federal agencies and Congress. Advocacy is an independent office within SBA, so the views expressed by Advocacy do not necessarily reflect the views of SBA or the Administration. Section 612 of the Regulatory Flexibility Act (RFA) also requires Advocacy to monitor agency compliance with the RFA, as amended by the Small Business Regulatory Enforcement Fairness Act.2 Moreover, Executive Order (E.O.) 13272 requires federal agencies to notify Advocacy of any proposed rules that are expected to have a significant economic impact on a substantial number of small entities and to give every appropriate consideration to any comments on a proposed or final rule submitted by Advocacy.3 Further, the agency must include, in any explanation or discussion accompanying publication in the Federal Register of a final rule, the agency's response to any written comments submitted by Advocacy on the proposed rule.
Under the RFA and E.O. 13272, Advocacy submits the following comments on the proposed revisions to the 2011 final rule.
In the promulgated NHSM rule,4 EPA describes the standards and procedures for identifying whether NHSM are solid wastes under the Resource Conservation and Recovery Act (RCRA) when used as fuels or ingredients in combustion units. EPA recently proposed amendments to the promulgated NHSM rule.5 When viewed in the context of analogous requirements applied to hazardous wastes under RCRA Subtitle C, these rules deviate from EPA's long-standing policy approach to determining the legitimacy of recycling activities.
EPA's new approach will place unnecessarily burdensome requirements on facilities to demonstrate the legitimacy of long-standing NHSM combustion activities for energy recovery. Such requirements are unwarranted given that EPA has not produced any evidence that these facilities are performing ―sham‖ recycling (i.e., activity undertaken to avoid the requirements of managing a secondary material as a waste). The new amendments would more likely result in many millions of tons (and in the case of waste oil, millions of gallons) of NHSM being classified as solid wastes, making those materials subject to Clean Air Act (CAA) section 129 emission standards for
Commercial/Industrial Solid Waste Incinerators (CISWI) rather than CAA section 112 emission standards for Industrial, Commercial, and Institutional boilers and process heaters. Because the CISWI standards are much more stringent and costly, NHSM recycling activity will likely decrease substantially, resulting in net negative environmental impacts relative to the status quo. EPA indirectly acknowledges this in describing the environmental benefits of NHSM when used as fuel:
"The use of secondary materials as alternative fuels and/or ingredients in manufacturing processes using combustion not only recovers valuable resources, it is known to contribute to emission reductions. For example, both greenhouse gas (GHG) and particulate matter (PM) emissions have been reduced as a co-benefit of the use of secondary materials. The use of secondary materials, such as use as a fuel in industrial processes may also result in other benefits, including reduced fuel imports, reduced negative environmental impacts caused by previous dumping (e.g., tires), and reduced methane gas generation from landfills" 6
EPA also describes the interplay between economic and environmental benefits from use of NHSM as fuel:
"Economic efficiencies can be improved with the use of secondary materials, when substituted for increasingly scarce virgin materials, because the use of such secondary materials often results in an equivalent level of outputs at lower overall resource use, or in turn, greater outputs could be generated using the same amount of resource inputs. When this occurs, monetary savings resulting from reduced resources and expenditures would, theoretically, be applied to a higher and better use in the economy. This helps advance economic growth as a result of improved industrial efficiency, which, in turn, helps move the country toward material sustainability and energy self sufficiency, while protecting human health and the environment."
We propose that EPA return to the legitimacy determination principles stated in the 2008 final DSW rule (see Advocacy's October 20, 2011 comments on proposed DSW revisions).7 These principles reflect the reality that, when combusted for energy recovery, the use of NHSM with meaningful heating value is a legitimate recycling activity.
EPA's long-standing formal policy with respect to determining the legitimacy of recycling activities originates with the preamble to the 1985 hazardous waste regulations that first established the definition of solid waste under RCRA Subtitle C.8 A 1989 memorandum issued by then Office of Solid Waste Director Sylvia Lowrance set forth a set of evaluation criteria for determining whether an activity was true or "sham" recycling.9 EPA considered sham recycling to be, in fact, discard and materials being sham recycled to be solid wastes.10
In the 2008 final DSW rule pertaining to hazardous wastes, EPA finalized a set of four criteria for determining the legitimacy of hazardous waste recycling activities.11 EPA recognized that the same criteria for legitimate hazardous waste recycling could be equally applied to nonhazardous secondary materials.12 In keeping with the precedent set by the Lowrance memorandum, EPA did not make all of these criteria mandatory. Instead, only two of the four legitimacy criteria were identified as mandatory: (1) the hazardous secondary material provides a useful contribution to the recycling process or to a product of the recycling process (Useful Contribution); and (2) the recycling process must produce a valuable product or intermediate (Valuable Product or Intermediate). As stated in the Advance Notice of Proposed Rulemaking (ANPRM) for NHSM, "These two legitimacy factors make up the core of legitimacy, and, therefore, a process that does not conform to them cannot be a legitimate recycling process, but would be considered sham recycling." 13
Under the final 2008 DSW rule, the two non-mandatory criteria were that: (3) the generator and recycler manage the hazardous secondary material as a valuable commodity14 (Manage as a Valuable Commodity); and (4) the product of the recycling process does not contain significant concentrations of hazardous constituents that are not in analogous products (Comparison of Toxics in the Product). Although these criteria must be evaluated, they did not have to be met, "…because the Agency is aware that a legitimate recycling process may not conform to one or both of these two factors." 15
The 2008 DSW final rule preamble provides a detailed discussion of the rationale for the specific criteria and why two of the four factors were not mandatory. EPA used several examples in the October 2008 final rule notice that showed that materials can be legitimately recycled even though not all the criteria are met.16
In March 2011, EPA promulgated an NHSM rule that deviated from this long-standing approach.17 As outlined in more detail below, EPA described a process that properly legitimizes the burning of "traditional" and "alternative traditional fuels" as non-wastes, as well as allowing NHSM generators to self-certify that NHSM is a non-waste when combusted for energy recovery under the control of the generator.
Advocacy agrees that these activities represent legitimate recycling. However, we do not agree with EPA's approach to classify off site transfers of NHSM combustion for energy recovery as a waste disposal activity. In sections I and II below, we summarize EPA's regulatory approach, and provide comments on where we agree and disagree with that approach. In sections III-V below, we describe procedures to redefine how secondary materials can be reprocessed into a non-waste fuels or ingredients (section III), and how secondary materials can be designated as categorical non-wastes (sections IV and V).
EPA should consider modifying the legitimacy criteria for NHSM and allow facilities to self-certify. In addition, we endorse EPA's new rulemaking petition process for categorizing NHSM as non-wastes as providing regulatory certainty for industry. Furthermore, Advocacy recommends that EPA specifically designate several secondary materials as non-wastes in the final rule, which we identify later in this letter. This approach will avoid the unnecessary and burdensome Regional EPA Administrator petition process in cases where EPA has sufficient information to make these designations, and avoid substantial disruption of the existing recycling infrastructure, while enhancing environmental protections.
I. Legitimacy Determination for Combustion of NHSM for Energy Recovery
General Concepts
EPA considers all NHSM burned in combustion units as solid wastes except in the following circumstances:
- NHSM used as a fuel that remains within the control of the generator (whether at the site of generation or another site within the generator's control) that meets the legitimacy criteria;
- NHSM used as an ingredient in a manufacturing process (whether by the generator or a third party) that meets the legitimacy criteria;
- Legitimate fuel or ingredient products produced from the processing of discarded NHSM;
- NHSM that have received a categorical non-waste fuels designation from EPA;18 and
- NHSM handled outside the control of the generator, but has been determined through a case-by-case non-waste determination petition process to not have been discarded and to be indistinguishable in all relevant aspects from a fuel product.
As noted above, EPA policy under the NHSM rule allows self-certification of non-waste status (legitimate recycling) for NHSM generators that burn self-generated materials for energy recovery. However, a burdensome and unnecessary petition process is required to receive EPA non-waste determinations when NHSM is transferred for energy recovery via combustion by a third party.
The following two sections describe small business concerns with EPA's approach to legitimacy—how EPA defines discard (first test used in determining waste status), and the specific criteria for evaluating the legitimacy of combustion of NHSM for energy recovery. This is followed by Advocacy comments on the design of EPA's current non-waste exemptions.
Definition of Discard
In its NHSM ANPRM, EPA correctly asserts that it has discretion to determine that transferred NHSM is not a solid waste:
The court also considered whether material is discarded in Safe Food and Fertilizer v. EPA, 350 F.3d 1263 (D.C. Cir. 2003) (''Safe Food''). In that case, among other things, the court rejected the argument that, as a matter of plain meaning, recycled material destined for immediate reuse within an ongoing industrial process is never considered ''discarded,'' whereas material that is transferred to another firm or industry for subsequent recycling must always be solid wastes. 350 F.3d at 1268. Instead, the court evaluated ''whether the agency's interpretation of…'discarded'… is, reasonable and consistent with the statutory purpose.'' Id. Thus, EPA has the discretion to determine if material is not a solid waste, even if it is transferred between industries.19
However, in the final NHSM rule, EPA reverses course and assumes that NHSMs sent offsite to third parties are assumed to be wastes, unless EPA makes a non-waste determination.20 In support of this new policy approach, EPA stated that:
when non-hazardous secondary material fuels are transferred to another party, the Agency generally believed that the material is discarded, since the generator has relinquished control of the secondary material and the entity receiving such materials may not have the same incentives to manage them as a useful product, which results in the materials being discarded. The Agency noted that this lack of incentive to manage as a useful product has been well-documented in the context of hazardous secondary material recycling as evidenced by the results of the environmental problems study performed in support of the 2008 DSW Final Rule and believed that this finding also held true for non-hazardous secondary materials that are used as fuel.21
Advocacy finds no justification in the record that this is true for NHSM (except tires).
In the final NHSM rule, EPA states: "It is clear that EPA's jurisdiction under RCRA applies unambiguously to materials that are discarded and the definition is unambiguous in that it means thrown away, disposed of or abandoned. It is the application of the definition to particular instances that gives rise to ambiguity." 22 It is not clear how EPA concludes that NHSM that are a part of long-established energy recovery markets where generators contractually transfer these materials for use as fuels for the purpose of energy recovery can ever be considered to have been "…thrown away, disposed of, or abandoned." Scrap tires are the only specific example that EPA provides of a NHSM that is transferred to a third party being considered to be in the "waste stream" by some states. 23 However, the EPA's NHSM rule specifically categorizes the vast majority of scrap tires as non-wastes. 24 This treatment contradicts EPA's explanation for choosing to break from decades of RCRA policy by assuming in the NHSM rule that third-party transfers indicate non-legitimate recycling by defining such transfers as discards.
It appears to Advocacy that, given the long history of combustion of secondary materials, the primary motivation of combustion is for energy recovery, not discard. EPA has presented no evidence of discard of NHSM, with the exception of discarded tires, over which there is no dispute. There was no reliable evidence of discard for any other secondary material, despite the fact that thousands of firms have been involved in the combustion of dozens of different secondary materials over many decades. The only other damage cases cited by EPA involved a few sites where wooden pallets unfortunately caught fire. The occurrence of fires at pallet storage locations is no more evidence of an intent to discard than a fire caused by smoking in bed provides evidence that the homeowner intended to destroy his home. Furthermore, unlike DSW, where financial difficulty played a major role in the cause of discard, EPA found no cases of financial distress in the NHSM cases.
Instead, the Agency appears to be extrapolating a concern reached from the hazardous waste recycling marketplace, for which the incentives to avoid cradle-to-grave waste management are much greater, and the adverse effect on the environment is much greater. Without any evidence to the contrary, EPA's presumption of discard for transfer of NHSM for combustion for energy recovery purposes is unfounded. The EPA should instead focus on the design and application of appropriate NHSM legitimacy criteria. 25
Although the NHSM rule carves out an exception from non-waste status for use of resinated wood for fuel (where resinated wood has slightly higher formaldehyde levels than virgin wood), such exceptions are unnecessary given that the legitimacy criteria (e.g., NHSM has meaningful heating value) are sufficient for determining whether combustion of NHSM for energy recovery represents legitimate recycling. Indeed, in Advocacy's view, EPA is on much stronger legal grounds by asserting that combustion for energy recovery is not discard rather than the opposite conclusion often reached in the final rule.
Legitimacy Criteria
The promulgated NHSM rule included three self-implementing legitimacy criteria that any NHSM must meet in order to be considered a non-waste fuel when burned in a combustion unit (40 CFR 241.3(d)(1)(i)–(iii)). These criteria, which mirror the criteria in the 2008 DSW rule are:
- Have a meaningful heating value and be used as a fuel in a combustion unit that recovers energy (EPA cites 5,000 BTU/lb as a general guideline threshold for meaningful, but also allows for lower BTU ratings);
- Be managed as a valuable commodity, including being stored for a reasonable time frame. Where there is an analogous fuel, the non-hazardous secondary material used as a fuel must be managed in a manner consistent with the management of the analogous fuel or otherwise be adequately contained so as to prevent releases to the environment;
- Have contaminants at levels comparable to or lower than those in traditional fuels which the combustion unit is designed to burn.
The proposed NHSM rule revised the third criterion to clarify that: (1) the contaminant comparison can be performed not only on an individual contaminant basis, but also on groups of contaminants; (2) the traditional fuel does not have to be actually burned in the boiler, simply being able to be burned is sufficient (does not require that unit is permitted to burn that fuel); and (3) the contaminant comparisons can be made using ranges of traditional fuel contaminant levels compiled from national surveys, as well as data from the specific traditional fuel being replaced.
While Advocacy appreciates the additional flexibility that these changes provide, we believe that EPA should return to the approach advocated in the ANPRM, which stated that NHSM used as fuel could not contain contaminants that were "significantly higher'' than traditional fuel products. This is also consistent with the current DSW language. In keeping with long-standing EPA policy, we don't view the third criterion as mandatory for establishing the legitimacy of NHSM combustion for energy recovery. Assuming that EPA does not adopt this well-established approach, we recommend that it revise the third criterion to provide the flexibility that EPA currently allows in making categorical non-waste fuels designations, and in evaluating case-by-case non-waste determination petitions.
II. Fuels and Alternative Traditional Fuels
Under the NHSM rule, traditional and alternative traditional fuels are non-wastes when burned in combustion units for energy recovery, and therefore, are not required to meet the NHSM legitimacy criteria. Under the proposed NHSM rule, EPA is identifying additional materials that are "clean cellulosic biomass,'' and therefore, traditional fuels. The proposed rule also clarifies that clean construction and demolition wood can be combusted as a traditional fuel if it does not contain contaminants at concentrations not normally associated with virgin wood. Advocacy fully supports each of these changes.
III. Secondary Materials that have been Discarded and Processed into a Fuel or Ingredient that Meet the Legitimacy Criteria Can Be Designated as Non-Wastes
Under the final NHSM rule, EPA considers discarded NHSM that have been sufficiently processed into fuel or ingredient products and used in a combustion unit as a non-waste, provided these materials satisfy the specified legitimacy criteria (as codified in § 241.3(d)(1) for fuels and (d)(2) for ingredients). The Agency defines processing as:
"any operations that transform the discarded non-hazardous secondary material into a legitimate fuel or ingredient product, and includes, but is not limited to, operations that remove or destroy contaminants; operations that significantly improve the fuel characteristics of the material, e.g., sizing or drying the material in combination with other operations;
operations that chemically improve the as-fired energy content; and operations that improve the ingredient characteristics. Minimal operations that result only in modifying the size of the material by shredding do not constitute processing for the purposes of this definition. Prior to any processing, the discarded non-hazardous secondary material would be considered a solid waste and would be subject to the appropriate federal, state, and local laws and regulations". 26
Advocacy believes that this definition is unnecessarily restrictive, disallowing beneficial reuse of a previously classified waste into a fuel product. Below we summarize EPA's rationale for its approach to processing. We then analyze the issues, and propose revisions to address EPA's concerns while increasing overall environmental benefits relative to EPA's proposed approach.
EPA's Explanation for its Approach to Processing in the NHSM Final Rule
In the preamble to the final NHSM rule, EPA correctly concluded that it has discretion to identify the types of processing activities that NHSM can undergo to have its discard status removed. If this occurs and if the material meets the required legitimacy criteria, the NHSM would be considered a non-waste when combusted for energy recovery. However, EPA rejected industry arguments that there should be no specific processing requirement because the legitimacy criteria alone are sufficient for ensuring that no sham recycling occurs.
As noted by EPA, "…the degree of processing necessarily will vary depending on the specific material, but the objective is the same—that is, the product from processing must be a legitimate fuel (i.e., a material with a meaningful heating value, with contaminants that are not present at significantly higher concentrations than those of traditional fuel products, and managed as a valuable commodity)." 27 We agree with this statement, which correctly focuses on the fact that processing should depend on the specific material, and reflect what is necessary to fully combust the materials. However, EPA veered from this approach in the final NHSM rule by concluding that the same processing into fuels that occurs in the context of non-discarded materials is insufficient for discarded materials.
In making its arguments, industry asserted that normal processing of coal refuse (mining rejects) and whole tires retrieved from tire piles should be sufficient to constitute the processing needed to convert previously discarded materials to legitimate fuels/ingredients. In each case, this level of processing (or in some cases, less processing) is used in preparing the material for use as fuel when these same materials are recycled in other contexts where discard has not occurred. For example, whole tires collected by used tire collection programs can be burned in cement kilns without any physical processing, while EPA requires that whole tires recycled from stockpiles for use in these kilns be physically shredded and undergo metals removal processing. EPA does not provide any explanation as to why this level of processing is not required when for scrap tires obtained from state collection programs, nor does EPA present a reason why cement kilns that currently combust whole tires are discarding tires, rather than recovering energy. Because EPA did not provide adequate justification why such processing is required for such tires to be a legitimate fuel, EPA's approach to defining processing requirements seems arbitrary and capricious.
Contrary to the stockpiled tire example, EPA now agrees with industry in the final rule preamble where it notes that ―sufficiently processed‖ in the context of reclamation of coal refuse from legacy piles only requires the same level of processing as the same material that is currently mined. "[T]he Agency has changed its view regarding coal refuse that was previously abandoned, such that if the discarded coal refuse is processed in the same way as coal is today, the Agency would not consider the processed coal refuse a solid waste." 28 In making this change, EPA attempts to distinguish coal refuse from tires by noting that coal refuse "…has never been used for anything else and is mined as fuel in the first place, while tires are originally produced for a use that is fundamentally different from its current use as a fuel." 29 We do not understand why this distinction has any bearing on the level of processing that is required in each case to produce a legitimate fuel.
Therefore, Advocacy proposes that EPA revise its current definition of processing to clarify that the same level of processing that is used to produce a fuel product from an NHSM in the non-discard context is acceptable to remove the discard status from NHSM that has been abandoned, disposed of, or thrown away (see changes to current EPA definition in underlined text):
"Processing means any operations that transform discarded nonhazardous secondary material into a non-waste fuel or non-waste ingredient product. Processing includes, but is not limited to, removal of extraneous debris, sizing for safe and efficient handling, shredding, sorting, segregating, cleaning, culling, racking, drying or other systematic procedures for making a material ready for use as a fuel. For materials that have been discarded, processing also includes the procedures used to process the same non-discarded material into fuel."
IV. Rulemaking Petition Process for EPA National Categorical Non-Waste Determination [241.4(b)]
Comments on Overall Petition Process
EPA is proposing to create a rulemaking petition process that would provide an opportunity for entities to submit a rulemaking petition that requests EPA to make categorical determinations that additional NHSM are non-waste fuels. This proposal will allow for petitioners to demonstrate that a NHSM is a non-waste fuel when the legitimacy criteria are balanced with "other relevant factors." Given the final NHSM rule's application that all legitimacy criteria are mandatory, this balancing would be necessary to continue a number of long-standing, environmentally protective practices of treating specific NHSM as a non-waste fuel when combusted for energy recovery. We fully support this proposal because it will streamline the promulgated regional-level non-waste petition process [Section 241.3(c)], resulting in national consistency that could not be ensured under the promulgated process. Advocacy welcomes this major improvement over the final rule since it potentially provides certainty for a large number of secondary materials, which can help ensure the timely preservation of the large existing recycling infrastructure, while enhancing environmental protection.
Additional Fuels Warranting Non-Waste Designations
In the proposed NHSM rule, EPA states its intention "…to identify several NHSMs as not being solid waste when burned as a fuel in a combustion unit where the Agency has sufficient information to determine that discard is not occurring when these materials are
being used as fuels. Specifically, the Agency recognizes that certain NHSMs
may not meet the legitimacy criteria, especially the "contaminant legitimacy criterion," in all instances, but the material would still generally be considered a non-waste fuel." 30
EPA has proposed the designation of scrap tires (excluding stockpiled tires) and resinated wood as non-wastes. We support those designations. We recommend that EPA promulgate a non-waste designation in the final rule for the following NHSM when combusted for energy recovery because all represent legitimate recycling (e.g., all demonstrate meaningful heating values):
- Coal refuse in legacy piles – The proposed NHSM indicates that EPA already believes that this material meets all of EPA's current legitimacy requirements, and that these materials are sufficiently processed to remove their discard status;
- Off-specification used oil – (1) Off-specification used oil should instead be compared to coal/coke for the comparison fuel rather than the virgin fuel oil and (2) the Subtitle C regulations actually indicate that such oil is a fuel with significant energy recovery benefits, and should be treated the same as on-specification used oil with respect to combustion in industrial boilers/furnaces;
- Scrap tires in stockpiles (when used in cement kilns) – EPA wrongly concluded that removal from discard status when these tires are combusted for energy recovery requires shredding and removal of metals—sufficient processing does not require more processing than that used for this same material in the non-discard context;
- Treated wood – This material has higher heating value than virgin wood. This material has been used in cement kilns and other boilers for decades nationwide;
- Animal manure – There is growing industry combusting manure for energy recovery; furthermore, there is no reliable evidence of contamination and EPA's concept of ―sufficient processing‖ is not supported by the record;
- Pulp and paper sludges – Sludges from pulp and paper mills, which are handled as valuable materials, have a long history of use as fuels, and their use has been increasing as technical advances make recovering their heating value more cost-effective; and
- Pulp and paper processing residuals – There has been a long-standing industry practice of using these materials as a fuel, which have meaningful heating value, are handled as a valuable commodity, and have emissions comparable to those from burning traditional biomass.
Advocacy also believes EPA will avoid the unnecessarily burdensome petition process by making these categorical determinations in the final NHSM. This will avoid substantial disruption of the existing recycling infrastructure, while enhancing environmental protections.
Even if EPA does not agree with our assertion that all of the above NHSM meet the necessary legitimacy criteria, EPA should categorize these alternative fuels as non-wastes "based on a balancing of the legitimacy criteria and other such relevant factors that the Administrator may identify." 31 The Appendix to this document presents the supporting details regarding the legitimacy of the recycling of these materials when combusted for energy recovery.
V. Petition Process for EPA Regional Administrator Non-Waste Determinations [241.3(c)]
The 2011 NHSM final rule established a non-waste determination process that provides entities with a petition process for receiving a determination from an EPA Regional Administrator that a NHSM that is used as a fuel, and which is not managed within the control of the generator, can be considered a non-waste fuel. To obtain such a determination, entities must demonstrate that the NHSM has not been discarded and is indistinguishable in all relevant aspects from a fuel product.
Because the non-waste determinations under this petition process are limited in scope to combustion units that are within the geographic area of each EPA Region, Advocacy supports the new national non-waste categorical non-waste determination petition process [under section 241.3(b)] that EPA included in the December 2011 proposed NHSM rule. We suggest, further, that EPA clarify that the region-specific petition process can be used for previously discarded NHSM that has been processed into a fuel as it appears that this is not discussed in the proposed rule.
EPA should re-adopt the legitimacy factors used in the 2008 final DSW rule to allow self-certification of legitimate combustion of non-hazardous secondary materials. In addition, EPA should use its newly proposed national categorization authority to designate several additional non-waste categories beyond the two categories already proposed, based on a balancing of the legitimacy criteria and other such relevant factors that the Administrator may identify. These additional revisions will achieve the Agency's regulatory goals, and protect human health and the environment.
Advocacy appreciates the opportunity to submit comments on the proposed NHSM revisions. We also applaud the substantial work that EPA has done in the short period of time since March 2011 to ameliorate the substantial negative effects of the final rule in this proposal. We look forward to working further with the Agency on developing the final rule. If you have any questions or comments on this letter, please contact me or Kevin Bromberg of my staff at 202-205-6964 or firstname.lastname@example.com.
Winslow Sargeant, Ph.D.
Chief Counsel for Advocacy
Kevin Bromberg
Assistant Chief Counsel
Office of Advocacy
The Honorable Cass R. Sunstein, Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
The Honorable Mathy Stanislaus, Assistant Administrator for
Solid Waste and Emergency Response, EPA
Docket - EPA-HQ-RCRA-2008-0329
- 76 Fed. Reg. 80452 (December 23, 2011).
- Pub. L. No. 96-354, 94 Stat. 1164 (1981) (codified at 5 U.S.C. §§601-612) amended by Subtitle II of the Contract with America Advancement Act, Pub. L. No. 104-121, 110 Stat. 857 (1996). 5 U.S.C. § 612(a).
- Executive Order No. 13,272, 67 Fed. Reg. 53,461 (Aug. 13, 2002).
- 76 Fed. Reg. 15456 (March 21, 2011).
- 76 Fed. Reg. 80452 (December 23, 2011).
- 76 Fed. Reg. 15456, 15467 (March 21, 2011).
- Comments were submitted by Advocacy on October 20, 2011 regarding the DSW revisions proposed on July 22, 2011. Letter found at http://www.sba.gov/advocacy/816/29631.
- 50 Fed. Reg. 638 (January 4, 1985).
- OSWER directive 9441.1989(19).
- 74 Fed. Reg. 41, 52 (January 2, 2009).
- 73 Fed. Reg. 64668, 64701-710 (Oct. 30, 2008).
- While the criteria may be equally applicable, this does not mean however, that hazardous wastes and nonhazardous secondary materials are handled or mishandled the same way. See further discussion in this letter.
- 74 Fed. Reg. 41, 52 (January 2, 2009).
- As part of this criterion, you must demonstrate that ―[w]here there is an analogous raw material, the hazardous secondary material should be managed, at a minimum, in a manner consistent with the management of the raw material.‖ Some secondary materials are handled differently from the analogous materials.
- 74 Fed. Reg. 41, 52 (January 2, 2009).
- 73 Fed. Reg. 64668, 64703-710 (Oct. 30, 2008).
- 76 Fed. Reg. 1546 (March 21, 2011).
- EPA has so far provided these designations for only (a) scrap tires that have not been discarded and are managed under the oversight of established tire collection programs, including tires removed from vehicles; and (b) resinated wood.
- 74 Fed. Reg. 41, 51 (January 2, 2009).
- 76 Fed. Reg. 15456, 15466 (March 21, 2011).
- Id.
- 76 Fed. Reg. 15456, 15468 (March 21, 2011).
- 76 Fed. Reg. 15456, 15460 (March 21, 2011).
- In comments provided later in this document, SBA provides reasons why all scrap tires combusted for energy recovery should be classified as non-wastes.
- EPA has complete discretion as to how to regulate "solid waste" under RCRA. The Natural Resources Defense Council case that concerns EPA does not restrain EPA's ability to properly define "solid waste." The case simply establishes that EPA needs to identify what "solid waste" means. EPA can clearly identify that material burned for energy recovery with a minimum BTU value, and some requirements for managing as a valuable fuel excludes materials from the "solid waste" designation. As the Portland Cement Association stated in its August 18, 2011 NHSM petition to EPA, the fact that "a court has rejected a result an agency reached through improper legal avenues does not mean the agency is precluded from reaching the same result through proper legal avenues."
- 76 Fed. Reg. 15456, 15550 (March 21, 2011).
- 76 Fed. Reg. 15456, 15465 (March 21, 2011).
- 76 Fed. Reg. 15456, 15476 (March 21, 2011).
- 76 Fed. Reg. 15456, 15507 (March 21, 2011).
- 76 Fed. Reg. 80452, 80471 (December 23, 2011).
- 76 Fed. Reg. 80452, 80482 (December 23, 2011).


text:
Archer Daniels Midland Company
Archer Daniels Midland Company (ADM) connects the harvest to the home and transforms crops into products that serve our customers' vital needs for food and energy. Today, we are one of the leading agricultural processors in the world, and we supply many of the largest food companies with the high performance ingredients they demand for their products.
At ADM, we pride ourselves on sourcing the highest-quality commodity goods available. Our global workforce of 29,000 employees and more than 240 processing plants worldwide convert corn, oilseeds, cocoa, wheat and other crops into food, fuel and industrial materials that are used by consumers and businesses around the world every day. In addition, our customers benefit from ADM's unrivaled logistical network. Our premier crop origination and transportation network connects crops and markets in more than 60 countries. This logistical infrastructure allows us to serve thousands of customers efficiently and profitably.
ADM does more than supply quality ingredients; we are also an industry leader in product innovation. Our dedicated team of food scientists and food technicians continually work to create new and innovative products. Food companies come to us when they need to develop a new product or to reformulate an existing product because they know we have the expertise to find the solution.
ADM's work is inextricably tied to its social responsibility, so we work to ensure our capital investments, social investments and investments in people to help fulfill the company's purpose of serving our customers' vital needs.
To learn more about the full range of ADM products and application expertise that ADM has to offer, visit adm.com.

subset: commoncrawl


text:
Joan Sutherland Theatre, Sydney Opera House
From the opening notes of Verdi's most famous overture, you are swept up in The Force of Destiny, an action-packed melodrama of passion, honour, vendetta and death. Leonora and Alvaro love one another but her family is set against the match. They prepare to elope but are instead caught up in war.
This thrilling new production uses the powerful iconography of Spain in richly detailed sets and costumes. An all-star international cast is led by Svetla Vassileva.
"...this is a chance to hear one of this season's most impressive voices, Svetla Vassileva as the doomed Leonora..." - Daily Telegraph
"Making his role debut as Don Alvaro, tenor Riccardo Massi was outstanding." - The Australian
An Opera Conference co-production.
|Andrea Licata
|Tama Matheson
|Assistant Director
|Netta Yashchin
|Set & Costume Designer
|Mark Thompson
|Lighting Designer
|Nigel Levings
|Svetla Vassileva
|Don Alvaro
|Riccardo Massi
|Don Carlos di Vargas
|Jonathan Summers
|Padre Guardiano
|Giacomo Prestia
|Rinat Shaham
|Fra Melitone
|Warwick Fyfe (until
17 Jul)
Andrew Moran
|Marchese di Calatrava
|Richard Anderson
|Mastro Trabuco
|Kanen Breen
|Sian Pendry
|An Army Surgeon
|Richard Mitchell
Australian Opera and Ballet Orchestra
Running time: Approximately three hours and 45 minutes including two 20-minute intervals.


text: Recently there has been some robust progress in AI (Artificial Intelligence), with some scientists even successfully uploading the mind of a roundworm into a Lego robot. Although this seems to be a rather small step, it is significant since the software was in place without any prior programming and the robot started to behave like a worm, including in its response to food. "I think big leaps have been made in the last few years," said Geoffrey Hinton, a distinguished researcher at Google and a professor at the University of Toronto. "A.I. is undergoing a growth spurt. We're beginning to solve problems that a few years ago we couldn't solve, like recognising images." Continue reading


text:
Latest News
Win more with RedWolf Rewards Program (2010-11-25)Since launching in 2000, our RedWolf Rewards Program (RRP) has awarded free prizes to thousands of customers. Free gifts have ranged from a simple bag of BBs to an Inokatsu M60. As we enter the next decade, we have added more exciting prizes to our list of bonus products for you to redeem. And best of all, there is no expiration date on your points which means you can really save up for that big prize.
For every dollar spent on buying product, you earn one Wolf Bonus Point. Sign into your RedWolf account and go to the MEMBERS section to see the list of BONUS PRODUCTS you can redeem. You can conveniently see your Wolf Points balance on top of that page.
Wolves take care of their own, and we take care of you.


text:
HARVARD — Police are asking for the public's help in identifying a female on Sheep Island wanted for questioning, as they continue to investigate break-ins that happened there this winter.
Police received a call about the multiple break-ins in February, when Officer Timothy Schaeffer noticed five cottages were broken into, with damages.
Schaeffer also noticed old campfires on the ice and the island, The Harvard Hillside reported at the time, and it did not look like anything was taken from the houses.
The image, taken from a video still shot on the island, appears to depict a female in a pink sweatshirt with another person near a house.
Police advise that the female's sweatshirt may be helpful for identification purposes.


text:
Charlotte teammate Freddy Garcia is also close to joining the White Sox' starting rotation, and the 32-year-old righty could pitch against the Kansas City Royals Tuesday at U.S Cellular Field. … Sox manager Ozzie Guillen told reporters in Seattle Wednesday night Garcia is "real excited," but isn't sure when he'll join the Sox.
August 14, 2009
Freddy Garcia update
Leave a Comment »
No comments yet.
RSS feed for comments on this post. TrackBack URI


text:
Tagged: Hunger Games
The Return of the Empire…
Why? Because the Yankees McCann!…
I have to admit that the Yankees' free agent signing of former Atlanta Braves catcher Brian McCann caught me by surprise. Like so many people did last Saturday, I went to see The Hunger Games: Catching Fire. No sooner than I walked out the theater after the movie, I immediately saw the alerts the Yankees had signed McCann.
I had heard the Yankees were interested in McCann, but so were other teams like the Boston Red Sox, Texas Rangers, and Colorado Rockies. I thought the Rangers were the most likely landing spot. It's a winning organization in a city that puts more pressure on the local football team. The cost of living is reasonable, and the area is spacious. There's not too much to dislike about Texas…well, outside of those hot humid summers, the long drives to get anywhere, and the infrequency of trees (at least in North Texas). I also thought the Boston Red Sox might have an advantage with former McCann backup David Ross on the roster. Either Texas or Boston offers the chance for World Series participation.
But in the end, it was the Yankees' offer (number of years) in combination with the short porch in right field which is very attractive for the left-handed slugger.
I had Brian McCann as my catcher on my fantasy baseball team this year and his health caused me to seek other options. While he was on the DL, I leaned on his Braves replacement (Evan Gattis) among others. So, McCann's health is an obvious concern. But if healthy, he is a tremendous addition to the team. He gives the Yankees their best offensive threat from the position since Jorge Posada retired. Russell Martin would occasionally get hot, but he is not close to the hitter that McCann is. Plus, McCann's leadership abilities are well documented. When Chipper Jones retired, he gave a strong recommendation for McCann as a team leader.
Nothing against Francisco Cervelli, but I think he is better suited to backup someone like McCann than to start. He had his moments last year before getting hurt and then the subsequent suspension, but he'll get his opportunities when McCann rests or moves to DH. I am fine with the number of years on the contract because I think McCann is an excellent bridge to super prospect Gary Sanchez. When Sanchez is ready for the majors, it will be time to slide McCann to first or DH anyway. It also frees GM Brian Cashman to potentially include other catching prospects like Austin Romine or J.R. Murphy is potential trades.
Signing McCann was a great start to the off-season but there is obviously still much work ahead for Cashman and the Yanks.
Where are we?…
As we turn the page to Thanksgiving, the Yankees have their manager, backup shortstop and catcher in the fold. They are rumored to be the leaders for the services of free agent outfielder Carlos Beltran of the St Louis Cardinals, although I have heard he has a preference for staying in the NL (I don't know if that's true or not, and I personally believe he'd have even greater success in the American League). I like the idea of Beltran in right.
As it sounds, Robinson Cano's camp is still asking for something in the neighborhood of $300 million. They've dropped "slightly" from the initial figure of $310 million, but anything in the Alex Rodriguez area of contracts is too much…even for arguably the team's best player. I would rather see the Yankees use the money on multiple key players, shift the offense to other positions and then backfill second base with someone like Omar Infante. I still hope there are compromises made on both sides to bring Cano back to the Bronx, but if it is not meant to be, I don't want to see the Yankees overspend.
So far, no help for the starting rotation. Several notable free agent pitchers in a market void of any aces have already signed. Dan Haren with the Los Angeles Dodgers, Tim Hudson with the San Francisco Giants, and Ricky Nolasco with the Minnesota Twins. I don't think the Yankees were linked to any of those guys, but the smaller the free agent pool, the more intense the competition becomes at least for the guys who can win 12-14 games for you. I know the Yankees are rumored to be heavily counting on the posting of Japanese pitcher Masahiro Tanaka if MLB and the Japanese are able to come to an agreement for a new posting system. But you have to wonder what Plan B will be. So far, I have not heard much about Hiroki Kuroda but I would like to see the team try to bring him back for one more year.
The next few weeks will go a long way toward determining how strong and competitive the 2014 Yankees will be.
Coaching staff intact…well, almost…
Several weeks ago, I heard that Joe Girardi's entire coaching staff would be returning. However, today, I saw that the Arizona Diamondbacks have named Yankees bullpen coach Mike Harkey as their new pitching coach. Congratulations to Mike! Larry Rothschild is not going anywhere so it is good to see Harkey get his opportunity elsewhere. Now, the Yankees will be in the market for a new bullpen coach. Say, I wonder what Mariano Rivera is doing… 😉
Well, that's all for now. Have a very Happy Thanksgiving and Holiday Season!


text:
Bride-to-Be Wants Jon Bon Jovi to Walk Her Down the Aisle
Over the past couple of years, plenty of fans have launched online campaigns to have their favorite celebrity escort them to their prom, or their military ball, or to a similar event. But one woman in Australia wants something truly unique from her favorite singer, Jon Bon Jovi: she wants him to walk her down the aisle at her wedding next month.
Australia's Daily Telegraph reports that the bride, Branka Delic, is due to marry her boyfriend Gonzalo "Gonzo" Cladera on October 12 in the same Las Vegas wedding chapel where Jon married his wife Dorothea. It just so happens that Bon Jovi is playing in Las Vegas that same night. The band will take the stage at 8 p.m., but Delic's wedding is at 2 p.m., so Branka figures that Jon could make it if he really wanted to.
In addition to tweeting Jon with her request, and setting up a Facebook page, Branka has created a website called BonJoviWalkMeDowntheAisle.com to plead her case. "Bon Jovi…we're begging you….make this wedding happen," states a note on the site. "There is plenty of time in the afternoon for you to come and walk [Branka] down the aisle before the show. We're living on a prayer and we want you to come lay your hands on me and walk me down the aisle!"
As for how her groom feels about this, Branka says, "Gonzo thinks it is all quite funny. He's given me a [hall] pass if I meet [Jon]. I'm allowed one kiss. He's just hoping to bump into Jessica Alba so he can do the same.''


text:
Introduction To Forex By Mark McRae SureFire Forex Trading 1. SureFire Forex Trading.
Basic Forex Trading Guide Open free Practice eToro account! BASIC FOREX TRADING GUIDE 3 Intro.
12 Free Forex Ebooks Introduction. and includes trading between large banks, Download your free introductory Forex ebooks below.
All the books are available for free in. pdf Forex Library Free Forex Books Trading in pdf will help you achieve your goal! Download this book.
Business Forex Trading Gives A Fresh Life To DOWNLOAD. Forex Trading New Revolution Forex Trading PDF Forex Trading Manual Audio Book Free Gift. Free Forex books read the best Forex ebooks, download free Forex trading books, read about Forex in PDF, Forex technical and Forex fundamental Forex Books. Here is a list of free trading eBooks to aid you in your trading. New free trading eBooks Here is a list of free trading eBooks and free download page for a. The 10 keys to Successful Forex Trading PDF shows you how to become a habit of downloading Forex PDF eBooks, Forex Trading PDF Version Free Download.
Free Trading Courses; Forex eBooks If you want to share your own free forex Learn and download free binary options strategies and trading systems! Download. Free Business Books PDF Forex Trading for Dummies Free Book PDF. How to Make Money in Forex Trading The Best Forex Broker. We currently trade at This Broker. Forex Winners Free Download Downlod free trading sysrems, indicators and forex Ebooks. Trading Tools; Forex Calculator. Currency Converter; Camarilla Calculator.
eBooks Because You'd Rather Be Trading For A Living! eBook Download Page. Free YTC eBooks: If you need to download the Adobe PDF Reader. Download the free forex ebook The Definitive Guide to Building Free eBooks; Free Forex eBook: The Definitive Guide to Building a Winning Forex trading.
Forex for Beginners: How to Make Money in Forex Trading for Forex Trading Success. 10. Developing a Forex Strategy practice Forex trading for free without. Forex Trading Strategy Books read best Forex ebooks, download free Forex trading books about strategies in Forex, Almost all Forex ebooks are in. pdf format. free forex scalping stratigies, pivot point strategies, free mt4 indicators, free forex ebooks forex trading mmts forex trading mmts. pdf
Winning Strategies for Trading Forex feel free to tweak or modify any of the parameters of these strategies to Trading forex involves substantial risk.
Free Books on Forex Technical Indicators. Partnership with IFC Markets Forex Broker. Download PDF Forex Oscillators.


text:
It could be a Lebanese Taverna. The only problem is that one side looks out over the gas station. I'd love one like the Lebanese Taverna in Baltimore because it can range from an elegant dinner to relatively casual, and it's family-friendly even though it is a white-table-cloth place.
But we'd take the casual one like Rockville [that has counter service like Maiwand Kabob or Bon Fresco]. Even though it isn't elegant, it has the great food, and you could do takeout. We've done take-out from Rockville, and it survived the trip well.
My argument is to look for things where the closest location is in another county . . . Look at it on the map. Lebanese Taverna is in Rockville and Baltimore. Nothing in the middle. Jamba Juice? There is nothing nearby.
Sir! Sir! Are we idiots? Get off the counter! [This is to one of the cats.]
I would also suggest moving Cuba de Ayer. But they may not want to move from Burtonsville. We'd welcome them.I repeated my hope for a bahn mi joint in Howard County. That may not be a top choice for everyone, but it seems like a way to expand a menu either for one of the Vietnamese places like An Loi Pho or for a place that already has great bread like Bon Fresco. Mrs. HowChow was flippin through Baltimore Magazine:
Look at the new Milk & Honey Market in Mt. Vernon. It has fresh fruits and vegetables. I don't really need the gourmet part, but it has oils, pastas, milk and honey. It has the [air quotes with the fingers] farmers market without the GNC aisle [like some organic markets]. It has the best parts of Whole Foods like the artisinal cheese and the deli meats. Plus, they serve breakfast and lunch. It is in this location that is dense and where people walk around.
[Cat jumped behind the television.] He is just ballsy without any balls.
I have never been there, but I would be happy with Bonefish Grill. Mrs. HowChow's friend loves it. I'd be happy with chains that are mid-priced but aren't here. I'd rather have a Noodles and Company than a Hair Cuttery. I'm thinking about Baltimore things where they would have a southern location. Cindy Wolf, Tony Foreman. Anything you want to open down here?And, of course, we would always take a southern location of Capogiro -- the gelato store that makes us plan trips to Philadelphia. What else do you want? Or what else do you know is coming?


text:
Steven Tyler said it was food poisoning, not drugs that led to his hospitalization earlier this week in South America.
The 63-year-old Aerosmith frontman and "American Idol" judge explained on NBC's "Today" show Thursday that he lost a couple teeth and had four stitches near his eye from falling in a hotel shower Tuesday in Paraguay's capital, Asuncion.
A photo aired on "Today" showed Tyler with a pronounced gap between his teeth, a black eye and other face bruising from what the rocker called "Montezuma's revenge."
U.S. & World
Stories that affect your life across the U.S. and around the world.
He laughed after host Matt Lauer told him he looked like the "wrong guy in a fight."
"Quite frankly I passed out," Tyler explained. "I was in the shower and I got nauseous and I started to get sick and I just passed out."
He said he woke up "with the water running on me wondering where in the hell I was."
After his tour manager called the American Embassy, Tyler was rushed to "the best hospital" where he had his eye stitched up, some dental work and even plastic surgery, he said.
Lauer asked whether Tyler had really fallen "in the shower or off the wagon," a turn of phrase Tyler said he appreciated.
"People thinking that is natural and normal," said Tyler, who has opened up in the past about struggles with drugs and alcohol.
In 2009, Tyler broke his shoulder while taking a spin off a catwalk while performing "Love in an Elevator" during a South Dakota show and entered rehab for painkillers.
He told Lauer that speaking to "Today" by phone from Buenos Aires, Argentina at such an early hour was evidence that he wasn't "someone who uses substances."
Tyler went on to explain why he has continued to perform in South America despite his injuries.
"Short of having my leg taken off, people are going to expect me on stage no matter what," he said. "I went out on stage and wore my sunglasses for the first song. I took them off and the crowd roared."
Visit msnbc.com for breaking news, world news, and news about the economy


text:
Jump to navigation
Comment ID:
Michalina Theodorou
DotMusic Limited
Application ID:
Panel/Objection Ground:
Community Evaluation Panel
Supporting .MUSIC Community Applicant
Comment Submission Date:12 August 2015 at 18:29:18 UTC
DotMusic's application follows unified principles that all the Community subscribes to, such as: creating a trusted identifier and safe haven for music consumption, protecting musicians' rights and intellectual property, fighting copyright infringement/piracy, supporting fair compensation and music education, with multi-stakeholder representation of all types of global music constituents without discrimination (Q18). DotMusic is supported by entities with members representing over 95% of global music consumed, including many mainly dedicated to the Community (Q20f).
Music is recognized by ICANN and GAC as a regulated sector, comprised of a logical alliance of interdependent communities relating to music with organized practices and institutions that enable and regulate the music production, distribution and consumption. As such, the string is aligned with the Community definition ("a strictly delineated and organized community of individuals, organizations and business, a logical alliance of communities of similar nature that relate to music," Q20). Its Nexus matches the string because it represents the Community, allowing all constituents to register a .MUSIC domain without conflict of interests, over-reaching or discrimination. DotMusic' application clarifies that it does not unfairly prevent access to domain names to those with legitimate musical interests that have the requisite awareness of the community addressed.
DotMusic "will use clear, organized, consistent and interrelated criteria to demonstrate Community Establishment beyond reasonable doubt and incorporate safeguards in membership criteria "aligned with the community-based Purpose" and mitigate anti-trust and privacy concerns by protecting the Community while ensuring there is no material detriment to Community rights and their legitimate interests. Registrants will be verified using Community-organized, unified "criteria taken from holistic perspective with due regard of Community particularities" that "invoke a formal membership" without discrimination, conflict of interest or "likelihood of material detriment to the rights and legitimate interests" of the Community," "encompassing global reaching commercial, non-commercial stakeholders and amateur stakeholders." (Q20) Community members can only register their names (or portion) or acronym, so they are assured they can register their names in a meaningful way, regardless of launch phase or whether they belong to a MCMO or not. They can also appeal if their name is illegitimately taken.
DotMusic's Public Interest Commitments clarify:
"All music constituent types that are associated with the string must have a relationship with "music" and have the requisite awareness of DotMusic's defined Community to be part of the Community (P.12)." To prevent malicious activity and to ensure music relevancy "entities with a casual, tangential relationship with music (i.e. those that have no clear recognition or awareness of the community addressed) are excluded from the Community definition since they compromise the Purpose of the applied-for string and would not otherwise have a legitimate claim or reason to register a .music especially given the growing number of other alternative, non-restrictive TLD options they can choose from (P.20)." However, those with legitimate musical interests and the requisite awareness of the community addressed are able to register a .MUSIC domain.
© 2013 Internet Corporation For Assigned Names and NumbersPrivacy PolicyTerms of ServiceCookies Policy
We have updated our privacy policies and certain website terms of service to provide greater transparency, promote simplification, and align with recent changes in privacy laws applicable to us.
Learn more.
This site uses cookies to deliver an efficient user experience and to help us see how the site is used. Learn more.


text:
I have what seemed like a very simple issue, but I just cannot figure it out. I have the following circles around a common point:
The Green and Blue circles represent circles that orbit the center point. I have been able to calculate the distance/radius from the point to the individual circles, but I am unable to plot the next point on either circle, given an angle from the center point. Presently, my calculation looks like the following:
The coordinates of one of my circles is:
y1 = 152
x1 = 140.5
And my calculation for the next point, 1 degree from the starting point
(140.5,152) is:
distance = SQRT((160-x1)^2 + (240-y1)^2) = 90.13
new x = 160 - (distance x COS(1 degree x (PI / 180)))
new y = 240 - (distance x SIN(1 degree x (PI / 180)))
My new x and y give me crazy results, nothing even close to my circle.
I can't figure out how to calculate the new position, given the offset of 160, 240 being my center, and what I want to rotate around. Where am I going wrong?
I have implemented what I believe to be the correct formula, but I'm only getting a half circle, e.g.
x1 = starting x coordinate, or updated coordinate
y1 = starting y coordinate, or updated y coordinate
cx = 100 (horizontal center)
cy = 100 (vertical center)
radius = SQRT((cx - x1)^2 + (cy - y1)^2)
arc = ATAN((y1 - cy) / (x1 - cx))
newX = cx + radius * COS(arc - PI - (PI / 180.0))
newY = cy + radius * SIN(arc - PI - (PI / 180.0))
Set the values so next iteration of drawing, x1 and y1 will be the new
base for the calculation.
x1 = newX
y1 = newY
The circle begins to draw at the correct coordinates, but once it hits 180 degrees, it jumps back up to zero degrees. The dot represents the starting point. Also, the coordinates are going counterclockwise, when they need to go clockwise. Any ideas?


text:
You have not viewed any products recently.
Symbolic of purity and innocence, white flowers can also express strength and unity, as well as elegant beauty. But when you add your own personalized vase to the mix using Vase Expressions®, you create a one-of-kind gift they'll never forget! Our florists combine an all-white arrangement of fresh blooms with your customized insert positioned inside the vase, printed on 100% waterproof paper that makes it a lasting keepsake.
Vase measures 7.75"H. Use Vase Expressions® to upload a favorite photo or personal message to create a waterproof insert. Our expert florists will print the insert and slip it into the vase to create a personalized, one-of-a-kind gift that can later can be easily dried off and repurposed to fit in a frame. Arrangement measures approximately 16"H x 11"L. Our florists select the freshest flowers available so colors and varieties may vary.
Order by 1:00 PM EST for same day pickup or delivery!
* Fee charged in addition to the Standard Delivery Fee
Enter full name. We'll ask for delivery information at checkout.
Box of Assorted Chocolates.
Add a cute plush from our plush selection. Selected plush will vary.
18" Happy Birthday Mylar Balloon. Styles may vary.
18" Happy Anniversary Mylar Balloon. Styles may vary.
18" I Love You Mylar Balloon. Styles may vary.


text:
iPhone 4S launch helps China top US to become largest smartphone market
The changing of the guard was noted this week by research firm Canalys, which said the arrival of the iPhone 4S in China in January helped the market move past the U.S. In the first quarter of 2012, China represented 22 percent of global smartphone shipments, while the U.S. accounted for 16 percent.
Just a year earlier, the roles were flipped: It was the U.S. that accounted for 22 percent of smartphone sales, while China was behind it with 16 percent.
Total smartphone shipments grew 45 percent year over year to 146 million units, but shipments in the U.S. rose just 5 percent year over year. Shipments in China doubled during the same period, allowing it to overtake the U.S.
To further show how the market has shifted, Canalys revealed that out of the top 10 countries where smartphones are sold, half of them are now located in the Asia-Pacific region. Shipments in the Asia-Pacific region grew a whopping 81 percent year over year in the first quarter.
The iPhone accounted for 19 percent of all smartphones shipped to China in the first quarter of 2012, making the company second only to Samsung, which took a 22 percent share of the market. Two-thirds of smartphones that shipped in China in the first quarter were based in China.
The importance of China to Apple was apparent in the iPhone maker's most recent quarterly earnings conference call, in which Chief Executive Tim Cook revealed that iPhone sales in Greater China were five times greater during the March quarter of 2012 than they were a year prior.
Apple's success in China also goes beyond the iPhone, as the company's much-touted "halo effect" also pushed Mac sales up 60 percent year over year during the last quarter. Cook said he considers it "mind boggling" that Apple could do so well in China, where revenue for the quarter was $7.39 billion.
"China has an enormous number of people moving into higher income groups â middle class, if you will," he said. "And this is creating a demand for goods â not just Apple's, but other companies' as well."
One analysis issued earlier this week from Chris Whitmore of Deutsche Bank found that iPhone sales are "just getting started" in China. He said that even if Apple doesn't forge a partnership with China Mobile, the largest carrier in the world, he still believes Apple will reach sales of 35 million iPhones in that market in 2013.
AppleInsider has affiliate partnerships and may earn commission on products purchased through affiliate links. These partnerships do not influence our editorial content.


text:
It's ornamental: Middletown students decorating state Christmas tree
MIDDLETOWN >> Middletown High school art students have been selected to make decorations for the state Christmas tree in Washington, D.C.
About 30 students were selected to make the ornaments, which were to be decorated with artwork having to do with Connecticut.
"They're decorating with things significant to your own state, like business, movies, history. Each one has to have a "Still Revolutionary" sticker on it...they're then hung on the tree in Washington, D.C.," said senior Erin Deleon.
"Still Revolutionary" is the latest marketing campaign from the state Department of Economic and Community Development's Offices of Culture and Tourism, the agency that includes the state Art Office.
The National Parks Service is responsible for decorating the national Christmas tree as well as the state trees and trees of U.S. territories.
They in turn contact individual state and territory arts and culture agencies, and those agencies select a school or group to create the decorations for the national display.
Deleon explained that students decorate the ornament -- a clear plexiglass ball that is split in two.
The ornaments are designed so that the inside of the orb can be painted, and then the two halves bonded together. By painting the inside, the image will be protected so it won't be scratched or scuffed while hanging on the state tree on the Ellipse with the national tree, according to art teacher Patrick Shugrue.
But a pair of students, thinking outside the ball, came up with putting 3D sculptures inside the ornaments.
"Originally, we were supposed to paint the inside. But two students, Naomi Adorno and Angela Holley, came up with the 3D idea...it really inspired others," Shugrue said.
Adorno's theme was Nathan Hale, with her ornament containing two scenes. On one side was an exterior scene of the Hale homestead. The other depicted the fireplace inside the home, with an image of Hale wearing a Hartford Whalers shirt, painted on the inside of the ball.
Emily Imbruglio, also a senior, decorated hers in the same style, though her theme was Middletown High School buildings.
On one side of her ornament was a depiction of the new high school, and on the other, a depiction of the city's first school, built in 1839 on Court Street.
"I found a picture of the (first) school hanging on the wall in the office," she said.
She said she plans on painting a blue dragon -- the current high school mascot -- on the inside of the ornament on the new school side.
Imbruglio said she researched the original school and learned its mascot was an orange and black tiger. She plans on painting that mascot on the side depicting the old school.
"I want to make it so you look into the animal's eyes to see the schools," she said.
Themes of other ornaments included images of the state insect, the praying mantis; the state bird, the American robin; images of the towers at Bushnell Park in Hartford; Connecticut business-themed ornaments, such as Pez and Lego and UConn Husky-themed ornaments.
Only 32 students could be selected to work on the ornaments.
Shugrue said he and his colleagues selected students based on their "artwork, dedication and effort."
"It's interesting how much was found out about the state by just digging," Shugrue said
"I see a growing pride as they connect with the themes they picked," said art teacher Charlotte McCoid. "More and more people are showing an interest."
The ornaments will be displayed on the Christmas tree in the high school main foyer before they are shipped off to Washington, D.C. on Nov. 2.


text: 365 Photo Challenge: Day 21/Day 22: Someone You Love 22/01/2013 by Alyssa Leave a comment Day 21/ 365: sunset I know I used this photo, already. Oh well 🙂 Day 22/365 Photo Challenge Rate this:Share this post!TweetShare on TumblrEmailMoreLike this:Like Loading... Related Author: Alyssa I am an East Texan graphic designer living in Canterbury, Kent, UK with my husband. My favorite sport is rearranging my furniture. When I'm not writing blogs, you can find me making fun of myself on Snapchat or Twitter, or being hipster on Instagram. Coffee, vintage and The Office reruns for life. Find me elsewhere: Snapchat: lyssssabeth | Twitter | Instagram | Pinterest


text:
0 Members and 1 Guest are viewing this topic.
I would have ran through a brick wall in the desert to play for Everton - no matter the manager...................pla y for the fans
If he wanted to keep that type of pressing game he could have put Besic on for McCarthy in a straight-swap and kept the same shape. I don't know if Besic was on the bench but he could have named him on the benchif that was what he intended.
He had someone to play with for once
If introducing Besic is ever part of your tactical plan then you've seriously misinterpreted what is required.
Barkley 3-4 weeks away from fitnessGana close to a new dealhttps://twitter.com/AHunterGuardian/status/923893244697686017
Whether or not Chelsea's B team was a good level of opposition, this looks good to me (click on the shot map):https://twitter.com/11tegen11/status/923617821409595393We allowed some decent opportunities* and it's not unusual to lose to superior finishing/goalkeeping but, even if you take away Calvert-Lewin's goal at the end, it looks like we created the better chances.* Not too much in the center of the box, though, which is promising.
Page created in 0.067 seconds with 26 queries.


text:
To celebrate the 85th birthday of the greatest living composer/lyricist, The Stephen Sondheim Society, in association with Richard Douglas Productions, would like to honour their patron with a star-studded charity gala at the Theatre Royal Drury Lane on Sunday 25th October. The renowned Musical Director Gareth Valentine will, schedule permitting, conduct the full-sized orchestra, and the leading lights of the West End, plus guests from across the pond, will give their thanks to Mr Sondheim, who has given his full blessing to the event.
Sondheim Gala: Hey, Old Friends is not available to book, please sign up to our newsletter for updates and offers on forthcoming and available shows.
Find out more about the venue for your show: Directions, Transport options and facilities.
(5mins) Go right on Long Acre; turn right into Bow Street and after 100 metres it will be on your left in Russell Street/Catherine Street.


text:
On Morals and Ethics.
At the link above, Ian Welsh covers The Basics of Ethics and Morality. Every now and then, a reminder is necessary. How we deal with the Other is often a fundamental aspect of Ourselves, and if we at least try to approach the Other on terms that would be pleasing to Ourselves were the shoe on the other foot ("Do unto others" and all that), we're probably going to be in a moral and ethical "good" space. It doesn't mean we will get our way or that we are always right or even that we will receive forgiveness for our own sins.
All it really means is that we try to live as if our lives had some meaning beyond our selfish desires and their momentary gratification.
It's not a hard concept, but it is one that many (including this author at times) need reminding of.
So, Ian has put it in as clear and concise a statement as I've seen recently. And it jars in a way because it is so out of step with the morals and ethics -- so called -- of the predators among us who sincerely believe their time has come and they are liberated to do whatever, to whomever, whenever they like. Ian's vision is like some crystal object out of an antique shop. Beautiful. Decorative. Useless.
And that is not to denounce or condemn his vision at all. In fact, in my view, he's got it right. And doing the right thing, even when it doesn't get you "something" right away, should be normal. But it's not. More and more it is marginal to the point of abnormality.
And so the Fall ensues. As Ian says:
When I hear those who believe in the greater good who want to torture other people, think prison rape is just or who like the idea of making other people crawl and beg, I know they have stared into the abyss too long. They aren't necessarily indistinguishable from the evil they fight, but they are walking that path.
Yes, they are. They don't necessarily become the evil they believe they are fighting, but they have lost any moral or ethical compass. Further:
At the same time, an insistence on complete moral purity is a road to evil of another kind, it is the road that leads to a man like Robespierre. And a strange part of the route to this evil is a refusal to accept petty human failings (like adultery, for example). A refusal to see that a person who has once done wrong, may still do much good. A refusal to believe that those who have done evil, can be redeemed.
It's my own view that for far too long far too many Americans have limited their consideration of "morality" to other people's sex lives. This is supposedly due to the Puritans' rigid sexual codes, but I think it is more about people's innate need for -- demand for -- gossip and rumor about others and rendering judgement thereon. It's more about human nature and how human nature is shaped by social norms. Sex sells, in other words, and it sells because it is a root interest, in the DNA of the species. In American society that interest and gossip and rendering judgement became the defining measure of "morality" in the Victorian age, in a kind of nostalgia for the colonial era, especially the moral certainty of the Puritans. The Victorian era was a highly disruptive period for most Americans, and uncertainty was the ever-present rule. So to find stability, Americans adopted certain elements of "morality." Dominated by other people's sex lives. Adultery should not be a matter of other people's judgement, nor should it even be discussed in the context of "evil." But here, Ian does it, probably unconsciously, and certainly not deliberately.
Demanding "purity" in public life leads directly to Robespierre and all the many permutations thereof, though not necessarily to the guillotine; no, purges seem sufficient these days. The problem with "purity" is that no one can ever be quite pure enough. There is always someone ready to denounce rivals as impure. Go figure.
But there must be some kind of limit:
I will submit that what must not be tolerated is people who allow themselves to take pleasure in the pain or degradation of other people. What was wrong with George Bush Jr. was that he was a sadist, a man who enjoyed other people's pain. And worse, he was not sickened by his own sadism, but embraced it, and saw it as his right.
Indeed, this should be the absolute, if there are to be any absolutes at all, and this is where our ruling class and its courtiers and retainers have utterly failed. It's not ultimately a matter of Bush's or Cheney's failures or those of any of the other moral/ethical monstrosities who have been in charge over the years. It is about the failure of post-modern governance to do anything about it. In fact, to categorically refuse to do anything about it, while fiercely punishing even the slightest transgression of the most obscure law among the Lower Orders.
So we come back to what we can control:
In this we come back to the maxim "if you aren't good, just act good". Character and personality are built up in part by habit. Kindness, generosity, love, are habits as much as anything else. Your mind is great at justifying whatever you do. Do evil and it will justify it, do good and it will justify that, and over time you will become a better person inside your head, inside your soul. Fake it till you make it.
Habits must be learned, and the best way to learn is through example. The problem we have today is that there are so few decent public examples, and if you don't have them in your own life, you're shit out of luck.
Which is another reason why reminders are so useful.


text:
Now Available: GAAFR Supplement
There have been several developments affecting accounting, auditing, and financial reporting for state and local governments since the Governmental Accounting, Auditing, and Financial Reporting (GAAFR or Blue Book) was published in 2012. First, the Governmental Accounting Standards Board (GASB) has released four new standards. Second, the Committee of Sponsoring Organizations (COSO) of theTreadway Commission has issued a significantly expanded version of its classic Internal Control Integrated Framework. The GAAFR Supplement contains the following new material to address those developments:
- A supplement to Chapter 22, Detailed Note Disclosures, which accounts for changes in note disclosure requirements resulting from the issuance of the three new GASB standards;
- A new version of Chapter 23, Pension Benefits, Other Postemployment Benefits (OPEB), and Termination Benefits, rewritten to reflect the new guidance on employer accounting for pensions in GASB Statement No. 68, Accounting and Financial Reporting for Pensions
- A supplement to Chapter 30, Other Specialized Applications, which incorporates the provisions of GASB Statement No. 69, Government Combinations and Disposals of Government Operations, and GASB Statement No. 70, Accounting and Financial Reporting for Nonexchange Financial Guarantees;
- A supplement to Chapter 32, Other Required Supplementary Information (RSI), which addresses employer RSI for pensions consistent with the requirements of GASB StatementNo. 68;
- A new version of Chapter 36, Postemployment Benefit Plans, rewritten to reflect the new guidancefor pension plans in GASB Statement No. 67, Financial Reporting for Pension Plans; and
- A new version of Chapter 42, The Comprehensive Framework of Internal Control, rewritten consistent with the new and expanded COSO framework.
To purchase a copy using the GFOA e-store, log into your e-store account and add the GAAFR SUPPLEMENT to your cart. When you have completed your order, click on the "Download Books" tab and follow the instructions to access the e-bookfile. If you submit your order via mail, fax, or e-mail,you will receive an e-mail the GFOA eStore with steps on how to download your e-book.
Policy Statement
The GAAFR Supplement in all its forms is copyrighted by the Government Finance Officers Association of the United States and Canada (GFOA). The GFOA does not permit copying or duplication in any form including both written and illustrated matter unless proper permission is obtained from the GFOA.
Copyright © 2014 by the Government Finance Officers Association. All Rights Reserved
Other Available E-Books
- An Elected Official's Guide: Interpreting Local Government Financial Statements - How to Avoid 25 Common Mistakes
- Governmental Accounting, Auditing, and Financial Reporting (GAAFR) (Includes GAAFR Supplement)
- An Elected Official's Guide: Internal Control
- An Elected Official's Guide: The New Pension Accounting
About GFOA E-Books
GFOA e-books are digital, downloadable versions of publications. Our e-books can bedownloaded and read on a variety of devices,such as a PC, Mac, or mobile device withe-reader applications. Once downloaded, access to the Internet is not required to read e-books. GFOA e-books are digitally rightsprotected by Adobe® and carry specific use attributes. The file format is EPUB.
Please note: To further assist you in using the material, the file settings have been configured to allow purchasers to print a working copy.
Download GAAFR Supplement Brochure


text: 1911, Fusion frame (new) W Clark carrel ... Arsenal Firearms,rare double barrel 9mm,... Rock Island Baby Rock .380ACP, 7 Rnd New... Republic Forge - 1911 45ACP Pws Mod 2 Fsc30 308 5-8x24 Rh Blk Guns Pistols Pistol Copies non Colt Trailblazer Lifecard Leather Sleeve Black | 207 | 0 | Lc | 640.5739ms View Category Trailblazer Lifecard Leather - Sleeve Black For Sale from www.GunFactory.com | Positive feedback: 100% View | Verified Seller | 22 Completed Sales View Sellers Items /UserImages/210843/967786427 14599035.jpg Description: Trailblazer lifecard leather sleeve black FEATURES:-Made in the USA-100% Genuine Leather-Trailblazer logo on the front Read More Condition: New In Box UPC: 864845000317 Location: GA Trades Accepted: No Read More *Flat Rate Shipping $20.00 We accept Visa, MasterCard, Discover, and American Express. We accept USPS money orders only. ALL CHECKS AND MONEY ORDERS ARE HELD UNTIL THEY CLEAR OUR INSTITUTION (Typically 10 days) We are enrolled in the California CFLC system California sales require an additional $50 S/H fee. Alaska, Hawaii, and Puerto Rico Sales require extra shipping costs, request a quote.Stock photos are used. Please confirm the MFG part number and UPC matches you are looking for. Orders are shipped within 3-5 business days after receiving payment and FFL. WE DO NOT SHIP TO PO BOXES. IF experiencing a PANDEMIC or national Disaster there may be delays in shipping. If concerned, ask before buying. Cancellations will incur a 20% restocking fee. The 3 day inspection period Is for defects. After a gun has been transferred to the customer, all issues must be handled through the manufacturer. Inspect the firearm at your FFL's location. If you complete and sign the 4473 form, the firearm is now considered yours. If denied by the ATF or are unable to complete the transfer, a 20% restocking fee on the return and you will be responsible for the return shipping cost. Please contact us via Gun Broker or email us at email@example.com. Your listed email address for your account must be valid and up to date. Some messages may take up to 48 hours to be answered. Not every item is a Avai Shipping Notes: See Description Read More Share Item Item #: 967786427 SKU: ZALCSB Stock No.: ZALCSB www.GunFactory.com Seller Since: Jul. 2018 Identity Verified ( Suwanee, GA ) Trusted Seller This seller is an FFL City: Suwanee State: GA Price: SOLD (Price reflects 3% cash discount.) This Seller Accepts Online Payment Shipping: Free! (or Arrange local transfer) Accepted Payment Methods: Returns: 3 Days Your Recently Viewed Items


text:
John Clare
John Clare (13 July 1793 – 20 May 1864 / Northamptonshire / England)
» Click to list general statistics » OR, select a date :
In Hilly-Wood
How sweet to be thus nestling deep in boughs,
Upon an ashen stoven pillowing me;
Faintly are heard the ploughmen at their ploughs,
read more >>
- Hits: Number of visitors who read the poem on the given date.
- Posts: Number of visitors who posted the poem to a friend (via e-mail) on the given date.
- Dates that have "0" hits may not be shown on the list.
- Dates, poems and poets that have "0" hits may not be shown on the list. Statistics are generated daily.


text:
When you're ready to start your next adventure in a new place, trust the experts at Watson Relocation Services to make your move an easy one. Whether you're moving to a new city, a new state, or even to a new country, we'll help you figure out all the important details – your timeline, goals, and priorities – beforehand so you don't have to.
Our commitment to providing every one of our customers with the best relocation experience possible has helped us grow into one of the largest relocation departments in the region. No matter the reason for your relocation, our team will work to ensure all your needs are met before and after you settle in your new home.
Awards & Achievements
Watson Relocation Services operates with the singular goal of providing customers across the globe with the most stress-free relocation services possible. Our dedication to our customers has been recognized by many respected professional organizations in the industry.
We're proud members of the Worldwide Employee Relocation Council (WERC), a global community of professionals dedicated to developing solutions to support the mobile workforce. Many members of our team even hold the WERC's Certified Relocation Professional designation.
We're also proud members of Leading Real Estate Companies of the World® , the nation's largest network of premier independent real estate brokers. Several team members hold the Global Relocation Professional (GRP) designation, while Watson Relocation Services as a whole is one of only approximately 30 companies nationwide to earn the RELO Quality Certification Award, the first standardized measure of quality and performance in the relocation industry.
Whether you're moving into Florida or leaving the area, we're here to help. Visit Watson Relocation Services to get started!


text:
https://beta.companieshouse.gov.uk/company/11359560,Instanthour.biz is operated by: INSTANT HOUR LIMITED.
Invite your friends and earn a part of their investments!Our referral program pays single-time 3-10% of deposits made by person you refer.!
An automated platform handles adding of deposits fast enough and offers instant payments directly into your wallet!
Our company website is completely free from Internet attacks to ensure the maximum time for normal operation.
Our website is protected by military grade SSL. You can be sure your details & funds are safe with us.
Professional Management Team.
Reliable Investment Plans.
Advanced Security.
We are professionally engaged in cryptocurrencies mining and trading, and have a large experience of the investment Industry.
INSTANT HOUR LIMITED is a private investment company incorporated in the United Kingdom.Our team consists of professionals who provide clients and partners with confidence and only best consulting and financial services. Join our company and use a great chance to conquer the trading market and be successful people.Our company, INSTANT HOUR LIMITED, is engaged in the cryptocurrencies mining and investments in Blockchain technology as one of the most promising technologies of the 21st century, and achieved high results in own activities.Registration number of INSTANT HOUR LIMITED is 11359560.Read More About Our Company


text:
Niko Bellic is the playable protagonist of Grand Theft Auto IV. He is a 30 year old from the Balkan region in Eastern Europe, who fought in the Yugoslav Wars as a teenager.
Early life and family
It is suggested that Niko was born in Yugoslavia and grew up in a small town in modern-day Serbia, close to his cousin, Roman Bellic. His father was an abusive alcoholic, whom Niko despised; his mother, Milica Bellic, was a long-suffering woman, unhappy that her son grew up in such a harsh place. In a conversation with Kate McReary, Niko says that he found his aunt (Roman's mother) raped and murdered some time after Roman's departure to the United States; knowing Roman would be even more devastated if he knew the true circumstances of his mother's death, Niko covered up what happened, telling him that she died in a house fire.
Bosnian Wars
Niko grew up in the harsh environment of the Bosnian Wars, and became a soldier himself as a teenager. Niko witnessed and committed numerous atrocities during the war, which led to his cynical perspective on life, and a certain degree of regret, depression, and emotional detachment. During the war, his unit of fifteen men (most of them Niko's friends from his home town) was ambushed by enemy forces, and all but three were killed: Darko Brevic, Florian Cravic, and Niko himself. Niko concluded that either Florian or Darko had sold the group out, and he vowed to uncover and kill the culprit, not only to gain revenge, but also to hopefully 'close the book' on the incident, and move on with his life.
Post-war life
Work was hard to come by following the war. Niko's cousin, Roman, had already moved to America to start a new life in Liberty City; Niko spent the next decade working in the European criminal underworld, leading to a brief period of incarceratation. After being released from prison, he began working for a human trafficking ring led by Rodislav Bulgarin; when a boat involved in the operation sank in the Adriatic during a smuggling run into Italy, Niko swam to safety, but everything and everyone else was lost. Bulgarin believed that Niko had intentionally scuttled the ship and stole his money; the gangster's reach was too powerful in Europe, so Niko joined the merchant navy to escape his influence.
Life in Liberty City
Niko spent seven months with the cargo ship Platypus, which eventually headed for Liberty City. Niko parted ways with the Platypus crew there, partly to reunite with his cousin, and partly to track down Florian Cravic, who had moved to Liberty City after the war. Roman had been boasting of great success in Liberty City, but in truth his assets amounted to a small taxi depot and rundown apartment, and he was saddled with heavy debts due to his gambling habit. Niko would assist Roman in his taxi business, and protect his cousin from the loansharks who were harassing him. Roman's connections eventually led to Niko taking work with the Russian Mafia, setting in motion the events of the game.
At the end of the game, a Weazel News report states that Niko is wanted for questioning by the police (although not as a suspect), for the events at his cousin's wedding.
Niko is very protective of his family and loved ones, particularly his cousin Roman, despite Roman's indiscreet nature frequently getting the pair into trouble. He is withdrawn among strangers, but has good manners, and shows a softer side with love interests like Kate McReary and Michelle; that said, the horrors of war, both witnessed and perpetrated by Niko, have given him a great sense of guilt, and an ambivalence about the value of human life — he warns away pursuers and expresses regret over his past violence, but also feels that killing is all that he can do, readily taking on jobs which necessarily involve murder. He has an explosive temper when he is lied to, manipulated, or his loyalty is questioned, but he is also quick to help the defenseless and unfortunate, even those he merely meets in passing; he apparently possesses a sense of idealism which was wounded by his wartime experiences. Unfortunately, such a split attitude leads to hypocrisy — Niko, for example, appears to genuinely sympathise with the McRearys' grief over the demise of one of their brothers, despite having secretly committed that murder himself.
Niko's bitterness at the murder of his friends during the war has consumed him, and he is unable to let it go, taking on several highly dangerous jobs merely to enable his quest for vengeance. He is urged by several of his friends, most notably Roman, to find a new reason to live, but it is only after Niko finally has the opportunity for revenge that the player may choose for him to take it, or let it go.
Niko's businesslike manner usually leads him to behave more maturely and cautiously than his acquaintances, although with acquaintances like Brucie Kibbutz, Bernie Crane and Roman, this is no surprise. He is a binge drinker, but has an apparent distaste for illicit drugs, turning down Little Jacob's offer of marijuana and warning against Packie's cocaine habit; he also finds it distasteful to traffick in cocaine and particularly heroin, although this may be due to the heavy jail sentences they attract as much as any moral qualms. He is skeptical of American mainstream culture, which he sees as shallow, hypocritical and debauched, and has trouble relating to Roman's fascination with the country.
Naming and language errors
The surname "Bellic" would not exist in either the Serbian or Croatian languages, as these do not allow consecutive consonants (ie, the double-L in "Bellic"); "Bellic" is also pronounced with a hard 'C' ("bel-lik") throughout the game -- a proper pronunciation would use a hard 'ch' (as used in-game with the names "Darko Brevic" and "Florian Cravic"). A more authentic rendering of Niko's surname would be Belić. At one point, Florian, speaking in his native Sebian, pronounces Belic correctly, suggesting that "Bellic" is an Anglicised version of his surname.
Niko's first name is distinctively Croatian, rather than Serbian -- the Serbian equivalent would be "Nikola", although "Niko" may also simply be short for such.
Niko's voice actor, Michael Hollick, is American, and the accent he assumed for Niko is not a Serbian one; Niko's spoken Serbian is frequently mispronounced or wrongly emphasized.
GTA IV: TLAD Mission Appearances
LCPD Database Information
- Surname: Bellic
- First Name: Niko
- Age: 30
- Place of Birth: Unknown
- Affiliations: Linked to Russian and West Indian Criminals in Broker
- Criminal Record: 2008 - Grand Theft Auto
- Notes:
- Recent immigrant to Liberty City from Eastern Europe
- Appears to be avoiding allegiance to one particular criminal organization
See also