text: Unlike the Articles of Confederation, the US Constitution separated the legislative, executive and judicial powers. Article III separates and places the judicial power in the judiciary. This idea is most often attributed to Montesquieu. Although not the progenitor, Montesquieu's writing on the separation of power in "The Spirit of Laws" was immensely influential on the U.S. Constitution.


title: Article Three of the United States Constitution

text: Section 1 is one of the three vesting clauses of the United States Constitution, which vests the judicial power of the United States in federal courts, requires the supreme court, allows inferior courts, requires good behavior tenure for judges, and prohibits decreasing the salaries of judges.


text: Article III authorizes one Supreme Court, but does not set the number of justices that must be appointed to it. Article I, Section 3, Clause 6 refers to a "Chief Justice" (who shall preside over the impeachment trial of the President of the United States). Since 1869 the number of justices has been fixed at nine (by the Judiciary Act of 1869): one chief justice, and eight associate justices.


text: Proposals have been made at various times for organizing the Supreme Court into separate panels; none garnered wide support, thus the constitutionality of such a division is unknown. In a 1937 letter (to Senator Burton Wheeler during the Judicial Procedures Reform Bill debate), Chief Justice Charles Evans Hughes wrote, "the Constitution does not appear to authorize two or more Supreme Courts functioning in effect as separate courts."


text: The Supreme Court is the only federal court that is explicitly established by the Constitution. During the Constitutional Convention, a proposal was made for the Supreme Court to be the only federal court, having both original jurisdiction and appellate jurisdiction. This proposal was rejected in favor of the provision that exists today. The Supreme Court has interpreted this provision as enabling Congress to create inferior (i.e., lower) courts under both Article III, Section 1, and Article I, Section 8. The Article III courts, which are also known as "constitutional courts", were first created by the Judiciary Act of 1789, and are the only courts with judicial power. Article I courts, which are also known as "legislative courts", consist of regulatory agencies, such as the United States Tax Court.


text: In certain types of cases, Article III courts may exercise appellate jurisdiction over Article I courts. In "Murray's Lessee v. Hoboken Land & Improvement Co." (), the Court held that "there are legal matters, involving public rights, which may be presented in such form that the judicial power is capable of acting on them," and which are susceptible to review by an Article III court. Later, in "Ex parte Bakelite Corp." (), the Court declared that Article I courts "may be created as special tribunals to examine and determine various matters, arising between the government and others, which from their nature do not require judicial determination and yet are susceptible of it." Other cases, such as bankruptcy cases, have been held not to involve judicial determination, and may therefore go before Article I courts. Similarly, several courts in the District of Columbia, which is under the exclusive jurisdiction of the Congress, are Article I courts rather than Article III courts. This article was expressly extended to the United States District Court for the District of Puerto Rico by the U.S. Congress through Federal Law 89-571, 80 Stat. 764, signed by President Lyndon B. Johnson in 1966. This transformed the article IV United States territorial court in Puerto Rico, created in 1900, to an Article III federal judicial district court.


text: The Judicial Procedures Reform Bill of 1937, frequently called the court-packing plan, was a legislative initiative to add more justices to the Supreme Court proposed by President Franklin D. Roosevelt shortly after his victory in the 1936 presidential election. Although the bill aimed generally to overhaul and modernize the entire federal court system, its central and most controversial provision would have granted the President power to appoint an additional justice to the Supreme Court for every incumbent justice over the age of 70, up to a maximum of six.


text: The Constitution is silent when it comes to judges of courts which have been abolished. The Judiciary Act of 1801 increased the number of courts to permit Federalist President John Adams to appoint a number of Federalist judges before Thomas Jefferson took office. When Jefferson became President, the Congress abolished several of these courts and made no provision for the judges of those courts. The Judicial Code of 1911 abolished circuit riding and transferred the circuit courts authority and jurisdiction to the district courts.


text: The Constitution provides that judges "shall hold their Offices during good Behaviour." The term "good behaviour" is interpreted to mean that judges may serve for the remainder of their lives, although they may resign or retire voluntarily. A judge may also be removed by impeachment and conviction by congressional vote (hence the term good behaviour); this has occurred fourteen times. Three other judges, Mark W. Delahay, George W. English, and Samuel B. Kent, chose to resign rather than go through the impeachment process.


text: The compensation of judges may not be decreased, but may be increased, during their continuance in office.


text: Section 2 delineates federal judicial power, and brings that power into execution by conferring original jurisdiction and also appellate jurisdiction upon the Supreme Court. Additionally, this section requires trial by jury in all criminal cases, except impeachment cases.


text: Clause 1 of Section 2 authorizes the federal courts to hear actual cases and controversies only. Their judicial power does not extend to cases which are hypothetical, or which are proscribed due to standing, mootness, or ripeness issues. Generally, a case or controversy requires the presence of adverse parties who have a genuine interest at stake in the case. In "Muskrat v. United States", , the Supreme Court denied jurisdiction to cases brought under a statute permitting certain Native Americans to bring suit against the United States to determine the constitutionality of a law allocating tribal lands. Counsel for both sides were to be paid from the federal Treasury. The Supreme Court held that, though the United States was a defendant, the case in question was not an actual controversy; rather, the statute was merely devised to test the constitutionality of a certain type of legislation. Thus the Court's ruling would be nothing more than an advisory opinion; therefore, the court dismissed the suit for failing to present a "case or controversy."


text: A significant omission is that although Clause 1 provides that federal judicial power shall extend to "the laws of the United States," it does not also provide that it shall extend to the laws of the "several" or individual states. In turn, the Judiciary Act of 1789 and subsequent acts never granted the U.S. Supreme Court the power to review decisions of state supreme courts on pure issues of state law. It is this silence which tacitly made state supreme courts the final expositors of the common law in their respective states. They were free to diverge from English precedents and from each other on the vast majority of legal issues which had never been made part of federal law by the Constitution, and the U.S. Supreme Court could do nothing, as it would ultimately concede in "Erie Railroad Co. v. Tompkins" (1938). By way of contrast, other English-speaking federations like Australia and Canada never adopted the "Erie" doctrine. That is, their highest courts have always possessed plenary power to impose a uniform nationwide common law upon all lower courts and never adopted the strong American distinction between federal and state common law.


text: In "Chisholm v. Georgia", , the Supreme Court ruled that Article III, Section 2 abrogated the States' sovereign immunity and authorized federal courts to hear disputes between private citizens and States. This decision was overturned by the Eleventh Amendment, which was passed by the Congress on March 4, 1794 and ratified by the states on February 7, 1795. It prohibits the federal courts from hearing "any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State".


text: Clause 2 of Section 2 provides that the Supreme Court has original jurisdiction in cases affecting ambassadors, ministers and consuls, and also in those controversies which are subject to federal judicial power because at least one state is a party; the Court has held that the latter requirement is met if the United States has a controversy with a state. In other cases, the Supreme Court has only appellate jurisdiction, which may be regulated by the Congress. The Congress may not, however, amend the Court's original jurisdiction, as was found in "Marbury v. Madison", (the same decision which established the principle of judicial review). "Marbury" held that Congress can neither expand nor restrict the original jurisdiction of the Supreme Court. However, the appellate jurisdiction of the Court is different. The Court's appellate jurisdiction is given "with such exceptions, and under such regulations as the Congress shall make."


text: Often a court will assert a modest degree of power over a case for the threshold purpose of determining whether it has jurisdiction, and so the word "power" is not necessarily synonymous with the word "jurisdiction".


text: The power of the federal judiciary to review the constitutionality of a statute or treaty, or to review an administrative regulation for consistency with either a statute, a treaty, or the Constitution itself, is an implied power derived in part from Clause 2 of Section 2.


text: Though the Constitution does not expressly provide that the federal judiciary has the power of judicial review, many of the Constitution's Framers viewed such a power as an appropriate power for the federal judiciary to possess. In "Federalist No. 78", Alexander Hamilton wrote,


text: Hamilton goes on to counterbalance the tone of "judicial supremacists," those demanding that both Congress and the Executive are compelled by the Constitution to enforce all court decisions, including those that, in their eyes, or those of the People, violate fundamental American principles:


text: "Marbury v. Madison" involved a highly partisan set of circumstances. Though Congressional elections were held in November 1800, the newly elected officers did not take power until March. The Federalist Party had lost the elections. In the words of President Thomas Jefferson, the Federalists "retired into the judiciary as a stronghold". In the four months following the elections, the outgoing Congress created several new judgeships, which were filled by President John Adams. In the last-minute rush, however, Federalist Secretary of State John Marshall had neglected to deliver 17 of the commissions to their respective appointees. When James Madison took office as Secretary of State, several commissions remained undelivered. Bringing their claims under the Judiciary Act of 1789, the appointees, including William Marbury, petitioned the Supreme Court for the issue of a writ of mandamus, which in English law had been used to force public officials to fulfill their ministerial duties. Here, Madison would be required to deliver the commissions.


text: "Marbury" posed a difficult problem for the court, which was then led by Chief Justice John Marshall, the same person who had neglected to deliver the commissions when he was the Secretary of State. If Marshall's court commanded James Madison to deliver the commissions, Madison might ignore the order, thereby indicating the weakness of the court. Similarly, if the court denied William Marbury's request, the court would be seen as weak. Marshall held that appointee Marbury was indeed entitled to his commission. However, Justice Marshall contended that the Judiciary Act of 1789 was unconstitutional, since it purported to grant original jurisdiction to the Supreme Court in cases not involving the States or ambassadors. The ruling thereby established that the federal courts could exercise judicial review over the actions of Congress or the executive branch.


text: However, Alexander Hamilton, in "Federalist No. 78", expressed the view that the Courts hold only the power of words, and not the power of compulsion upon those other two branches of government, upon which the Supreme Court is itself dependent. Then in 1820, Thomas Jefferson expressed his deep reservations about the doctrine of judicial review:


text: Clause 3 of Section 2 provides that Federal crimes, except impeachment cases, must be tried before a jury, unless the defendant waives their right. Also, the trial must be held in the state where the crime was committed. If the crime was not committed in any particular state, then the trial is held in such a place as set forth by the Congress. The United States Senate has the sole power to try impeachment cases.


text: Two of the Constitutional Amendments that comprise the Bill of Rights contain related provisions. The Sixth Amendment enumerates the rights of individuals when facing criminal prosecution and the Seventh Amendment establishes an individual's right to a jury trial in certain civil cases. It also inhibits courts from overturning a jury's findings of fact. The Supreme Court has extended the right to a jury in the Sixth Amendment to individuals facing trial in state courts through the Due Process Clause of the Fourteenth Amendment, but has refused to do so with the Seventh.


text: The Constitution defines treason as specific acts, namely "levying War against [the United States], or in adhering to their Enemies, giving them Aid and Comfort." A contrast is therefore maintained with the English law, whereby crimes including conspiring to kill the King or "violating" the Queen, were punishable as treason. In "Ex Parte Bollman", , the Supreme Court ruled that "there must be an actual assembling of men, for the treasonable purpose, to constitute a levying of war."


text: Under English law effective during the ratification of the U.S. Constitution, there were several species of treason. Of these, the Constitution adopted only two: levying war and adhering to enemies. Omitted were species of treason involving encompassing (or imagining) the death of the king, certain types of counterfeiting, and finally fornication with women in the royal family of the sort which could call into question the parentage of royal successors. James Wilson wrote the original draft of this section, and he was involved as a defense attorney for some accused of treason against the Patriot cause. The two forms of treason adopted were both derived from the English Treason Act 1351. Joseph Story wrote in his "Commentaries on the Constitution of the United States" of the authors of the Constitution that:


text: Based on the above quotation, it was noted by the lawyer William J. Olson in an "amicus curiae" in the case "Hedges v. Obama" that the Treason Clause was one of the enumerated powers of the federal government. He also stated that by defining treason in the U.S. Constitution and placing it in Article III "the founders intended the power to be checked by the judiciary, ruling out trials by military commissions. As James Madison noted, the Treason Clause also was designed to limit the power of the federal government to punish its citizens for 'adhering to [the] enemies [of the United States by], giving them aid and comfort.'"


text: Section 3 also requires the testimony of two different witnesses on the same overt act, or a confession by the accused in open court, to convict for treason. This rule was derived from another English statute, the Treason Act 1695. The English law did not require both witnesses to have witnessed the same overt act; this requirement, supported by Benjamin Franklin, was added to the draft Constitution by a vote of 8 states to 3.


text: In "Cramer v. United States", , the Supreme Court ruled that "[e]very act, movement, deed, and word of the defendant charged to constitute treason must be supported by the testimony of two witnesses." In "Haupt v. United States", , however, the Supreme Court found that two witnesses are not required to prove intent, nor are two witnesses required to prove that an overt act is treasonable. The two witnesses, according to the decision, are required to prove only that the overt act occurred (eyewitnesses and federal agents investigating the crime, for example).


text: Punishment for treason may not "work Corruption of Blood, or Forfeiture except during the Life of the Person" so convicted. The descendants of someone convicted for treason could not, as they were under English law, be considered "tainted" by the treason of their ancestor.


title: Carnegie Steel Company

text: Carnegie Steel Company was a steel-producing company primarily created by Andrew Carnegie and several close associates to manage businesses at steel mills in the Pittsburgh, Pennsylvania area in the late 19th century. The company was formed in 1892 and was subsequently sold in 1901 in one of the largest business transactions of the early 20th century, to become the major component of U.S. Steel. The sale made Carnegie one of the richest men in history.


title: Carnegie Steel Company

text: Carnegie began the construction of his first steel mill, the Edgar Thomson Steel Works, in 1872 at Braddock, Pennsylvania. The Thomson Steel Works began producing rails in 1874. By a combination of low wages, efficient technology infrastructure investment and an efficient organization, the mill produced cheap steel, which sold for a large profit in the growing markets of industrial development. Carnegie alone estimated that 40% was returned on the investment, i.e., a profit of $40,000 from a $100,000 investment in the mill.


title: Carnegie Steel Company

text: The profits made by the Edgar Thomson Steel Works were substantial enough to let Carnegie and his partners, including Henry Clay Frick, his cousin George Lauder, and Henry Phipps Jr., buy other nearby steel mills. These included the Homestead Steel Works, which Carnegie acquired in 1883. The presence of the Allegheny, Monongahela, and Ohio rivers provided transport for the heavy materials used in steel production. Each plant was near to or alongside a river.


title: Carnegie Steel Company

text: Carnegie agreed to Frick's subsequent proposal that the various plants and assets, including H. C. Frick & Company, be consolidated into a single company. This consolidation occurred on July 1, 1892, with the formation of the Carnegie Steel Company.


title: Carnegie Steel Company

text: The company headquarters were located in the Carnegie Building, an early skyscraper in Downtown Pittsburgh. Built to show its use of steel in its construction, the building was fifteen stories high and was left uncovered for a full year. The Carnegie Building was demolished in 1952. It was later rebuilt as a memorial in 2012.


title: Carnegie Steel Company

text: Carnegie Steel made major technological innovations in the 1880s, especially the installation of the open hearth furnace system at Homestead in 1886. It now became possible to make steel suitable for structural beams and, with the advanced work of George Lauder in arms and armament, for armor plate for the US Navy and the militaries of other governments, which paid far higher prices for the premium product. In addition, the plant moved increasingly toward the continuous system of production. Carnegie installed vastly improved systems of material-handling, like overhead cranes, hoists, charging machines, and buggies. All of this greatly sped the process of steelmaking and allowed the production of far vaster quantities of steel. As the mills expanded, the labor force grew rapidly, especially less skilled workers. The more skilled union members reacted with the unsuccessful 1892 Homestead Strike along with demands for reduced working hours and against pay cuts. After the unsuccessful strike the company continued to expand and profits grew year on year, with the company having earned net profits of $21 million in 1899.


title: Carnegie Steel Company

text: J&L Steel was the most important competitor to the Carnegie Steel Company (and later to U. S. Steel) in the vicinity of Pittsburgh.


title: Carnegie Steel Company

text: Carnegie Steel Company was sold in 1901 to U.S. Steel, a newly formed organization set up by J. P. Morgan. It sold at roughly $492 million ($14.8 billion in 2019), of which $226 million went to Carnegie himself. U.S. Steel was a conglomerate with subsidiary companies. The name of the subsidiary company was changed to the Carnegie-Illinois Steel Company in 1936.


title: Carnegie Steel Company

text: Changes in production processes to create steel had already appeared before the Carnegie Steel Company was sold. Steel manufacturers had begun to abandon the Bessemer converters and install open-hearth furnaces. Open-hearth furnaces were widely employed until the 1980s, when basic oxygen steelmaking, the electric arc furnace and continuous casting made them obsolete. The Edgar Thomson Steel Works in Braddock is still active, producing steel slabs that are shipped upriver to the Irvin Works in West Mifflin to become finished coils.


title: Shawn Fonteno

text: Shawn Darnell Fonteno, also known as Solo, is an American actor and rapper. He is best known for playing Franklin Clinton in the 2013 video game "Grand Theft Auto V". He is the older cousin of American rapper Young Maylay, who played Carl "CJ" Johnson, the protagonist in the 2004 video game "". Fonteno was raised in Watts, Los Angeles. Aside from his portrayal of Franklin Clinton, Fonteno has acted in films such as "The Wash".


title: Shawn Fonteno

text: In 2021, Fonteno and fellow "Grand Theft Auto V" actor Slink Johnson reprised their roles as Franklin Clinton and Lamar Davis respectively in a live-action re-enactment of a cutscene in the game where Lamar mocks Franklin for his haircut. The scene experienced a resurgence in popularity in late 2020 when parodies of the cutscene were uploaded on YouTube and other video hosting sites, usually involving Lamar's character model being replaced with various popular culture icons such as Darth Vader, Vegeta and Snow White among others. Later that year, Fonteno and Johnson once again reprised their roles in "The Contract" DLC for "Grand Theft Auto Online", which featured an homage to the original cutscene.


title: Shawn Fonteno

text: Fonteno has a daughter named Bria. Fonteno is also the cousin of voice actor and rapper Young Maylay who voiced Carl Johnson in .


title: Misa Hylton

text: Misa Hylton (previously known as Misa Hylton-Brim) is an American stylist and fashion designer. Known as a pioneer in the fashion industry, she has styled many hip-hop and R&B artists since the 1990s, most notably Lil' Kim and Mary J. Blige. Hylton's style, referred to as "hip-hop glamorous," has been credited with influencing fashion trends in popular culture. Hylton is a global creative partner for MCM and was the centerpiece of the 2019 documentary "".


title: Misa Hylton

text: Hylton was raised in Mount Vernon, New York to a mother who is of Japanese and Jamaican heritage, and a father who is African American. She enjoyed fashion from a young age and was also a hip-hop fan. Hylton listened to hip-hop radio stations and envisioned what the artists might be wearing. Her future boyfriend, Sean "Puffy" Combs, also grew up in Mount Vernon and lived close to one of Hylton's childhood friends.


title: Misa Hylton

text: Hylton began working in fashion when she was a 17-year-old high school student, when she assisted on a Jodeci music video. Her boyfriend and A&R intern, Sean Combs, invited her to the set, and together they convinced Uptown Records founder Andre Harrell to let the group members wear combat boots, hoodies, and backwards hats. Combs later introduced her to other artists at Uptown Records, who became some of her first clients.


title: Misa Hylton

text: Hylton most notably dressed Lil' Kim and Mary J. Blige, who she considered her muses. She began to design clothes due to the difficulty she experienced finding clothes for Lil' Kim, who was 4'11" and wore a size 4.5 shoe. Hylton was the designer and stylist for the purple jumpsuit and pasty that Lil' Kim wore to the 1999 VMAs. She stated that she focused on innovation and risk-taking with her early styles, and connected that pattern to being a member of the "hip hop generation". Hylton took inspiration from "The Wiz" for the fashion in Lil' Kim's "Crush on You" video. She also styled Lil' Kim for her solo debut album, "Hard Core".


title: Misa Hylton

text: When she was 21, Hylton founded Chyna Doll Enterprises and provided stylists for video shoots, magazine covers, and public appearance. Chyna Doll Enterprises styled artists such as Aaliyah, Faith Evans, Jodeci, Q-Tip, Foxy Brown, and Dru Hill. By age 25 Hylton had made one million dollars as a stylist. Hylton has also styled Combs, Missy Elliott, 50 Cent, La La Anthony, Mase, Terrence Howard, and Mary J. Blige in the "Not Gon' Cry" video.


title: Misa Hylton

text: She has spoken on the barriers she faced as a young woman of the color in the fashion world. The fashion her clients wore was referred to as "ghetto fabulous," which Hylton called "hip hop glam," and was not accepted by the mainstream fashion world. She would purchase luxury fashion for her clients on her own credit card.


title: Misa Hylton

text: When Lil' Kim gained credibility after a MAC campaign, Hylton's clients began to be courted by fashion houses such as Galliano. Hylton stated in an "Billboard" interview that one of her favorite brands to pull for is Versace, in part because they featured Naomi Campbell as a model when dark skinned models were rarely walked by major fashion houses.


title: Misa Hylton

text: Hylton frequently collaborates with Dapper Dan. Together they created custom shorts for rapper Trina fabricated from twenty dollar bills, and styled the Fendi Zucca print suits for the "Let's Get It" music video.


title: Misa Hylton

text: Hylton starred in the documentary,"", about the role of fashion in hip-hop. The film premiered at the 2019 Tribeca Film Festival.


title: Misa Hylton

text: In February 2020, Harlem's Fashion Row honored Hylton, April Walker, and Dapper Dan for their contributions to the fashion industry.


title: Misa Hylton

text: Hylton is a global creative partner for MCM. In 2018, she designed the fashion in the "Apeshit" video by Beyonce and Jay-Z. She designed custom MCM chaps and a western hat for Megan Thee Stallion's July 2019 "Jimmy Kimmel Live!" performance. Hylton also styled and provided fashion direction for "Paper"'s November 2020 Flo Milli editorial shoot, which included a custom denim bustier, panty, pasties, and headwrap.


title: Misa Hylton

text: In 2021, Hylton launched her INC fashion collection for Macy’s department stores. This was part of an 'Icons of Style' campaign run by the store to promote and showcase the work of Black American style-makers and designers, including Ouigi Theodore and Zerina Akers as well as Hylton.


title: Misa Hylton

text: Hylton frequently dressed clients in Western-inspired attire in the 90s, such as in Mary J. Blige's "All That I Can Say" music video. The trend has been traced to the "Yeehaw" style of 2019.


title: Misa Hylton

text: She is credited with shaping the way women rappers dressed in the 90s, and those styles are thought to influence women artists today. While women emcees of the 80s wore more masculine fashion, Hylton "encouraged girls in the game to celebrate their sexuality through fashion." Celebrities such as Rihanna have referenced Lil' Kim, one of Hylton's key clients, as inspirations for their fashion sense. Cardi B's gold chained headdress from the video "Money" and matching red fur and bob wig from "Backin it Up" are traced to Hylton's selections for Lil' Kim.


title: Misa Hylton

text: Hylton encouraged her first professional styling clients, Jodeci, to wear modern, casual clothing including hoodies and backwards hats instead of the de rigueur formal clothes and hard bottom shoes. The look went on to influence R&B fashion and is said to remain a point of reference for contemporary artists.


title: Misa Hylton

text: Hylton has three children. Rap mogul Sean Combs is the father of her first son, Justin (b.1993). She has two children with ex-husband and music executive Jojo Brim: a daughter, Madison Star Brim, who attended Howard University and is also pursuing a career in fashion; and a son, Niko, who is a rapper.


title: Tsuga

text: Tsuga (, from Japanese (), the name of "Tsuga sieboldii") is a genus of conifers in the subfamily Abietoideae of Pinaceae, the pine family. The common name hemlock is derived from a perceived similarity in the smell of its crushed foliage to that of the unrelated plant poison hemlock. Unlike the latter, "Tsuga" species are not poisonous.


title: Tsuga

text: The genus comprises eight to ten species (depending on the authority), with four species occurring in North America and four to six in eastern Asia.


title: Tsuga

text: They are medium-sized to large evergreen trees, ranging from tall, with a conical to irregular crown, the latter occurring especially in some of the Asian species. The leading shoots generally droop. The bark is scaly and commonly deeply furrowed, with the colour ranging from grey to brown. The branches stem horizontally from the trunk and are usually arranged in flattened sprays that bend downward towards their tips. Short spur shoots, which are present in many gymnosperms, are weakly to moderately developed. The young twigs, as well as the distal portions of stem, are flexible and often pendent. The stems are rough due to pulvini that persist after the leaves fall. The winter buds are ovoid or globose, usually rounded at the apex and not resinous.


title: Tsuga

text: The leaves are flattened to slightly angular and range from long and broad. They are borne singly and are arranged spirally on the stem; the leaf bases are twisted so the leaves lie flat either side of the stem or more rarely radially. Towards the base, the leaves narrow abruptly to a petiole set on a forward-angled pulvinus. The petiole is twisted at the base so it is almost parallel with the stem. The leaf apex is either notched, rounded, or acute. The undersides have two white stomatal bands (which are inconspicuous on "T. mertensiana") separated by an elevated midvein. The upper surface of the leaves lack stomata, except those of "T. mertensiana". They have one resin canal that is present beneath the single vascular bundle.


title: Tsuga

text: The pollen cones grow solitary from lateral buds. They are usually up to in length, ovoid, globose, or ellipsoid, and yellowish-white to pale purple, and borne on a short peduncle. The pollen itself has a saccate, ring-like structure at its distal pole, and rarely this structure can be more or less doubly saccate. The seed cones are borne on year-old twigs and are small ovoid-globose or oblong-cylindric, ranging from long, except in "T. mertensiana", where they are cylindrical and longer, in length; they are solitary, terminal or rarely lateral, pendulous, and are sessile or on a short peduncle up to long. Maturation occurs in 5–8 months, and the seeds are shed shortly thereafter; the cones are shed soon after seed release or up to a year or two later. The seed scales are thin, leathery, and persistent. They vary in shape and lack an apophysis and an umbo. The bracts are included and small. The seeds are small, from long, and winged, with the wing being in length. They also contain small adaxial resin vesicles. Seed germination is epigeal; the seedlings have 4–6 cotyledons.


title: Tsuga

text: Mountain hemlock ("T. mertensiana") is unusual in the genus in several respects. The leaves are less flattened and arranged all round the shoot, and have stomata above as well as below, giving the foliage a glaucous color; and the cones are the longest in the genus, long and cylindrical rather than ovoid. Some botanists treat it in a distinct genus as "Hesperopeuce mertensiana" (Bong.) Rydb., though it is more generally only considered distinct at the rank of subgenus.


title: Tsuga

text: Another species, bristlecone hemlock, first described as "T. longibracteata", is now treated in a distinct genus "Nothotsuga"; it differs from "Tsuga" in the erect (not pendulous) cones with exserted bracts, and male cones clustered in umbels, in these features more closely allied to the genus "Keteleeria".


title: Tsuga

text: The species are all adapted to (and are confined to) relatively moist, cool temperate areas with high rainfall, cool summers, and little or no water stress; they are also adapted to cope with heavy to very heavy winter snowfall and tolerate ice storms better than most other trees. Hemlock trees are more tolerant of heavy shade than other conifers; they are, however, more susceptible to drought.


title: Tsuga

text: The two eastern North American species, "T. canadensis" and "T. caroliniana", are under serious threat by the sap-sucking insect "Adelges tsugae" (hemlock woolly adelgid). This adelgid, related to the aphids, was introduced accidentally from eastern Asia, where it is only a minor pest. Extensive mortality has occurred, particularly east of the Appalachian Mountains. The Asian species are resistant to this pest, and the two western American hemlocks are moderately resistant. In North America, hemlocks are also attacked by hemlock looper. Larger infected hemlocks have large, relatively high root systems that can bring other trees down if one falls. The foliage of young trees is often browsed by deer, and the seeds are eaten by finches and small rodents.


title: Tsuga

text: Old trees are commonly attacked by various fungal disease and decay species, notably "Heterobasidion annosum" and "Armillaria" species, which rot the heartwood and eventually leave the tree liable to windthrow, and "Rhizina undulata", which may kill groups of trees following minor grass fires that activate growth of the "Rhizina" spores.


title: Tsuga

text: The wood obtained from hemlocks is important in the timber industry, especially for use as wood pulp. Many species are used in horticulture, and numerous cultivars have been selected for use in gardens. The bark of the hemlock is also used in tanning leather.


title: Iligan

text: Iligan, officially the City of Iligan (; ; Maranao: "Inged a Iligan"), is a 1st class highly urbanized city in the region of Northern Mindanao, Philippines. According to the 2020 census, it has a population of 363,115 people.


title: Iligan

text: It is geographically within the province of Lanao del Norte but administered independently from the province. It was once part of Central Mindanao (Region 12) until the province was moved under Northern Mindanao (Region 10) in 2001. Iligan is approximately 90 kilometers away from the capital of the province, Tubod, and approximately 800 kilometers from the capital of the Philippines, Manila.


title: Iligan

text: Iligan has a total land area of , making it one of the 10 largest cities in the Philippines in terms of land area. Among the 33 highly urbanized cities of the Philippines, Iligan is the third-least dense, with a population density of 421 inhabitants per square kilometer, just behind Butuan and Puerto Princesa.


title: Iligan

text: The name Iligan is from the Higaunon (Lumad/Native of Iligan) word "Ilig" which means "to go downstream". However, some also claim that the name of Iligan was taken and inspired by the Higaunon term "iligan" or "ilijan", which means "fortress of defense", an appropriate term due to frequent attacks incurred by pirates as well as other Mindanao tribes.


title: Iligan

text: Iligan had its beginnings in the village of Bayug, four kilometers north of the present Poblacion. It was the earliest pre-Spanish settlement of native sea dwellers. In the later part of the 16th century, the inhabitants were subdued by the Visayan migrants from the island-nation called the Kedatuan of Dapitan, on Panglao island.


title: Iligan

text: In the accounts of Jesuit historian Francisco Combes, the Moluccan Sultan of Ternate invaded Panglao. This caused the Dapitans to flee in large numbers to a re-established Dapitan, Zamboanga del Norte.


title: Iligan

text: In Dapitan, the surviving Datu of Panglao Pagbuaya, received Legazpi's expedition in 1565. Later, Pagbuaya's son Manook was baptized Pedro Manuel Manook. Sometime afterward in by the end of the 16th century after 1565 Manook subdued the "higaunon" (animist) village of Bayug and turned it into one of the earliest Christian settlements in the country. Although the settlement survived other raids from other enemies, especially Muslims from Lanao, the early settlers and converts moved their settlement from Bayug to Iligan, which the Augustinian Recollects founded in 1609, thus establishing the oldest town in northern Mindanao.


title: Iligan

text: The Jesuits replaced the Recollects in 1639. Iligan was the Spaniards' base of operations in attempting to conquer and Christianize the Lake Lanao area throughout its history. A stone fort called Fort St. Francis Xavier was built in 1642 where Iliganons sought refuge during raids by bandits. But the fort sank due to floods. Another fort was built and this was named Fort Victoria or Cota de Iligan.


title: Iligan

text: In 1850, because of floods, Don Remigio Cabili, then Iligan's gobernadorcillo, built another fort and moved the poblacion of the old Iligan located at the mouth of Tubod River west of the old market to its present site.


title: Iligan

text: Being the oldest town in Northern Mindanao, Iligan was already a part of the once undivided Misamis Province by the year 1832. However, it did not have an independent religious administration because its diocese by then was based at Misamis, the provincial capital. It was one of the biggest municipalities of Misamis Province.


title: Iligan

text: The Spaniards abandoned Iligan in 1899, paving the way for the landing of the American forces in 1900.


title: Iligan

text: In 1903, the Moro Province was created. Iligan, because of its Moro residents, was taken away from the Misamis Province. Then, Iligan became the capital of the Lanao District and the seat of the government where the American officials lived and held office. Later in 1907, the capital of the Lanao District has transferred to Dansalan.


title: Iligan

text: In 1914, under the restructuring of Moroland after the end of the Moro Province (1903–1913), Iligan became a municipality composed of eight barrios together with the municipal district of Mandulog. After enjoying peace and prosperity for about 40 years, Iligan was invaded by Japanese forces in 1942.


title: Iligan

text: The liberation of Iligan by the Philippine Commonwealth forces attacked by the Japanese held sway in the city until 1944 to 1945 when the war ended. On November 15, 1944, the city held a Commonwealth Day parade to celebrate the end of Japanese atrocities and occupation.


title: Iligan

text: Using the same territorial definition as a municipality, Iligan became a chartered city of Lanao del Norte on June 16, 1950. It was declared a first-class city in 1969 and was reclassified as First Class City "A" on July 1, 1977, by virtue of Presidential Decree No. 465. In 1983, Iligan was again reclassified as a highly urbanized city.


title: Iligan

text: Republic Act No. 9724, an Act separating the City of Iligan from the First Legislative District of the Province of Lanao del Norte was approved by President Gloria Macapagal Arroyo on October 20, 2009.


title: Iligan

text: Iligan is bounded on the north by three municipalities of Misamis Oriental (namely Lugait, Manticao and Opol), to the south by three municipalities of Lanao del Norte (Baloi, Linamon and Tagoloan) and two municipalities of Lanao del Sur (Kapai and Tagoloan II), to the north-east by the city of Cagayan de Oro, to the east by the municipality of Talakag, Bukidnon; and to the west by Iligan Bay.


title: Iligan

text: To the west, Iligan Bay provides ferry and container ship transportation. East of the city, flat cultivated coastal land gives way to steep volcanic hills and mountains providing the waterfalls and cold springs for which the area is well known.


title: Iligan

text: Iligan falls within the third type of climate wherein the seasons are not very pronounced. Rain is more or less evenly distributed throughout the year. Because of its tropical location, the city does not experience cold weather. Neither does it experience strong weather disturbances due to its geographical location (being outside the typhoon belt) And also because of the mountains that are surrounding the city.


title: Iligan

text: Iliganons are composed of a Cebuano-speaking majority and local minorities, mainly Maranaos, and other cultural minorities and immigrants. It is not only rich in natural resources and industries but it is also the home of a mix of cultures: the Maranaos of Lanao, the Higaonon of Bukidnon, and many settlers and migrants from other parts of the country. It is known for its diverse culture.


title: Iligan

text: Cebuano is the most spoken language in the city, with 92.27% reporting it as their first language. Minor languages include Maranao, Hiligaynon, Ilocano, Chavacano, and Waray. The majority of the population can speak and understand Tagalog (Filipino) and English, the official languages of the country. Tagalog (Filipino) and English are taught in the city's schools.


title: Iligan

text: The majority of Iligan citizens are Christians (mainly Roman Catholics). The city is also the center of the Roman Catholic Diocese of Iligan which has 25 parishes in Iligan City and twelve municipalities of Lanao del Norte (Linamon, Kauswagan, Bacolod, Maigo, Kolambugan, Tubod, Baroy, Lala, Kapatagan, Sapad, Salvador, and Magsaysay). It covers an area of 3,092 square kilometers with a population of 1,551,000, which 65.5% of the population are Roman Catholics.


title: Iligan

text: Iligan is known as the Industrial Center of the South and its economy is largely based on heavy industries. It produces hydroelectric power for the Mindanao region through the National Power Corporation (NAPOCOR), the site of the Mindanao Regional Center (MRC) housing Agus V, VI, and VII hydroelectric plants. Moreover, Holcim Philippines' largest Mindanao cement plant is located in the city. It also houses industries like steel, tinplate, cement, and flour mills.


title: Iligan

text: After the construction of Maria Cristina (Agus VI) Hydroelectric Plant by National Power Corporation (NPC, NAPOCOR) in 1950, the city experienced rapid industrialization and continued until the late 1980s. The largest steel plant in the country, National Steel Corporation (NSC), was also established in 1962.


title: Iligan

text: During the 1997 Asian financial crisis, the city experienced a severe economic slowdown. A number of industrial plants were closed, notably the National Steel Corporation.


title: Iligan

text: The city saw its economic revival with the reopening of the National Steel Corporation, renamed Global Steelworks Infrastructures, Inc. (GSII) in 2004. In October 2005, GSII officially took a new corporate name: Global Steel Philippines (SPV-AMC), Inc.


title: Iligan

text: Aside from heavy industries, Iligan is also a major exporter and producer of various plants and crops.


title: Iligan

text: As of the fiscal year 2018, Iligan has a current operating income of ₱2,052.89 million. The income grew by 8% compared to the fiscal year of 2017 in which Iligan's operating income was ₱1,900 million. According to the 2017 Financial Report by the Commission on Audit, Iligan's total assets amounted to ₱10.27 billion.


title: Iligan

text: Iligan along with its neighboring city, Cagayan de Oro, are the two major components for the Cagayan de Oro-Iligan Corridor, the fastest developing area in Northern Mindanao.


title: Iligan

text: Diyandi Festival and Street Dancing is Iligan's month-long cultural celebration held every month of September and concludes on the feast day of Saint Michael the Archangel on September 29. The highlight of the event is Kasadya Street Dancing, a Comedia or ritual dance offered to the patron saint as thanksgiving.


title: Iligan

text: Michael, the Archangel is widely regarded as the patron saint of the beloved city. The city fiesta in devotion to him is considered one of the Largest Religious Fiesta All over Mindanao and rising being ranked as one of the Pilgrim Festivals in the Major Islands of the country such as Traslacion of the Black Nazarene held in Manila, Peñafracia Festival of Bicol Region in Luzon and the Sinulog Festival in honor of Señor Sto Niño of Cebu in the Visayas. it is held every September 29 the Actual Feastday of the Archangel.


title: Iligan

text: He is locally known by the Spanish version of his name, Señor San Miguel. Devotion to him is common to Christians in Iligan as he is mentioned in all the sacred scriptures in the Bible.


title: Iligan

text: Iligan is commonly known as the "City of Majestic Waterfalls" because of the numerous waterfalls located within its area. The many waterfalls in the area attract tourists from all over the world with their beauty and power. There are about 24 waterfalls in the city. The most well-known is the Maria Cristina Falls. It is also the primary source of electric power of the city, harnessed by the Agus VI Hydroelectric Plant.


title: Iligan

text: Other waterfalls in the city are Tinago Falls, accessible through a 300-step staircase in Barangay Ditucalan. Mimbalut Falls in Barangay Buru-un, Abaga Falls in Barangay Suarez, and Dodiongan Falls in Barangay Bonbonon.


title: Iligan

text: Limunsudan Falls in Barangay Rogongon about 50 kilometers from the city proper of Iligan. These are the highest waterfalls in the Philippines, at 265 m (870 feet).


title: Iligan

text: Iligan is a highly urbanized city and is politically independent of the province of Lanao del Norte. Registered voters of the city no longer vote for provincial candidates such as the Governor and Vice Governor, unlike its nearby towns that make up the provinces as a result of its charter as a city in the 1950s.


title: Iligan

text: Iligan's seat of government, the city hall, is located at Buhanginan Hills in Barangay Pala-o. The local government structure is composed of one mayor, one vice mayor, and twelve councilors. Each official is elected publicly to a 3-year term and can be re-elected up to 3 terms in succession. The day-to-day administration of the city is handled by the city administrator.


title: Iligan

text: The Port of Iligan is located along the northern central coastal area of Mindanao facing the Iligan Bay with geographical coordinates of approximately .


title: Iligan

text: It serves the port users and passengers coming from the hinterlands of the provinces of Lanao del Norte, Lanao del Sur, parts of Misamis Oriental, and the Cities of Iligan and Marawi.


title: Iligan

text: Passenger and cargo shipping lines operating in the Port of Iligan serve the cities of Manila, Cebu City, and Ozamiz.


title: Iligan

text: There are around seven private seaports in Iligan operated by their respective heavy industry companies. These private seaports can be found in Barangays Maria Cristina, Suarez, Tomas L. Cabili, Santa Filomena, and Kiwalan.


title: Iligan

text: The main airport is Laguindingan Airport, located in the municipality of Laguindingan, Misamis Oriental, which opened on June 15, 2013, the airport replaced Lumbia Airport as the main airport of Misamis Oriental and Northern Mindanao. It has daily commercial flights to and from Manila, Cebu, Davao, Zamboanga, Tagbilaran, Iloilo, Bacolod, Caticlan, Dumaguete and Clark via Philippine Airlines and Cebu Pacific.


title: Iligan

text: Maria Cristina Airport (Momongan Airport), is located in Balo-i, Lanao del Norte, and was the main airport of Iligan in the late 1980s. Aerolift Philippines, a now-defunct regional airline, ceased its services when its passenger plane crashed into some structures at the end of the runway of the Manila Domestic Airport in 1990 which resulted to its bankruptcy. Thus, it ended its service to Iligan's airport at Balo-i which also resulted in the closure of the airport. Philippine Airlines served the city for many years before ending flights in 1998 due to the Asian financial crisis.


title: Iligan

text: Rural Transit (RTMI) and Super 5 Transport are the dominant public bus companies with daily trips from and to Iligan. Passenger vans and jeeps also service various municipalities in Lanao del Norte, Lanao del Sur, and Misamis Oriental.


title: Iligan

text: The public modes of transportation within the city are Jeepneys, Taxis, and Pedicabs. "Tartanillas" service main roads in Barangay Pala-o and Barangay Tambacan.


title: Iligan

text: The City of Iligan has one state university and seven private colleges specialized in Engineering and Information Technology, Health Services, Maritime Science, Business and Administration, Primary and Secondary Education, and Arts and Social Sciences.


title: Iligan

text: With a total of 181 schools (106 public; 75 private; 17 madaris) including vocational and technical schools, Iligan has an average literacy rate of 94.71, one of the highest in the whole Philippines.


title: Iligan

text: The Mindanao State University – Iligan Institute of Technology (Iligan Tech) is one of the few autonomous external campuses of the Mindanao State University (MSU) and "the light-bearer of the several campuses of the MSU System." It is considered one of the best universities in the Philippines with a standing of being within the top ten best universities in the country with excellence in Science and Technology, Engineering, Mathematics, Information Technology, and Natural Sciences. The institution has also produced many top-notchers and rankers in multiple board exams.


title: Corvée

text: Corvée () is a form of unpaid, forced labour, that is intermittent in nature lasting for limited periods of time: typically for only a certain number of days' work each year.


title: Corvée

text: Statute labour is a corvée imposed by a state for the purposes of public works. As such it represents a form of levy (taxation). Unlike other forms of levy, such as a tithe, a corvée does not require the population to have land, crops or cash.


title: Corvée

text: The obligation for tenant farmers to perform corvée work for landlords on private landed estates was widespread throughout history before the Industrial Revolution. The term is most typically used in reference to medieval and early modern Europe, where work was often expected by a feudal landowner (of their vassals), or by a monarch of their subjects.


title: Corvée

text: The application of the term is not limited to that time or place; the corvée has existed in modern and ancient Egypt, ancient Sumer, ancient Rome, China, Japan, everywhere in continental Europe, the Incan civilization, Haiti under Henry I and under American occupation (1915–1934), and Portugal's African colonies until the mid-1960s. Forms of statute labour officially existed until the early twentieth century in Canada and the United States.


title: Corvée

text: The word "corvée" itself has its origins in Rome, and reached the English language via France. In the Later Roman Empire the citizens performed "opera publica" in lieu of paying taxes; often it consisted of road and bridge work. Roman landlords could also demand a certain number of days' labour from their tenants, and also from the freedmen; in the latter case the work was called "opera officialis". In medieval Europe, the tasks that serfs or villeins were required to perform on a yearly basis for their lords were called "opera riga". Plowing and harvesting were principal activities to which this applied. In times of need, the lord could demand additional work called "opera corrogata" (Latin "corrogare", "to requisition"). This term evolved into "coroatae", then "corveiae", and finally "corvée", and the meaning broadened to encompass both the regular and exceptional tasks.


title: Corvée

text: The medieval agricultural corvée was not entirely unpaid: by custom the workers could expect small payments, often in the form of food and drink consumed on the spot. Corvée sometimes included military conscription, and the term is also occasionally used in a slightly divergent sense to mean forced requisition of military supplies; this most often took the form of "cartage", a lord's right to demand wagons for military transport.


title: Corvée

text: Because corvée labour for agriculture tended to be demanded by the lord at exactly the same time as the peasants needed to attend to their own plots – e.g. planting and harvest – the corvée was an object of serious resentment. By the 16th century its use in agricultural settings was on the wane; it became increasingly replaced by money payments for labour. It nevertheless persisted in many areas of Europe until the French Revolution and beyond. The word survives in modern usage, meaning any kind of "inevitable or disagreeable chore".


title: Corvée

text: From the Egyptian Old Kingdom (c. 2613 BC) onward, (the 4th Dynasty), corvée labour helped in 'government' projects; during the times of the Nile River floods, labour was used for construction projects such as pyramids, temples, quarries, canals, roads, and other works.


title: Corvée

text: The 1350 BC Amarna letters, mostly addressed to the pharaoh of Ancient Egypt, has one short letter, with the topic of corvée labour. Of the 382–Amarna letters, it is an example of an undamaged letter, from Biridiya of Megiddo, entitled "Furnishing corvée workers". See: city Nuribta.


title: Corvée

text: In later Egyptian times, during the Ptolemaic dynasty, Ptolemy V, in his Rosetta Stone Decree of 196 BC, listed 22 accomplishments for being honored and the ten rewards granted to him for his accomplishments. The last reward listed is his making of the Rosetta Stone (the Decree of Memphis (Ptolemy V)), in three scripts, to be displayed to the public in the temples (two near complete copies).


title: Corvée

text: Until the late 19th century, many of the Egyptian Public Works, including the Suez Canal, were built using corvée labour.


title: Corvée

text: Corvée labor in Egypt ended after 1882. The British Empire took control of Egypt in 1882 and opposed forced labor on principle, but they postponed abolition until Egypt had paid off its foreign debts. It disappeared as Egypt modernised after 1860. During the 19th century the corvée had expanded into a national program. It was favoured for temporary projects such as building irrigation works and dams. However Nile Delta landowners replaced it with cheap temporary labor recruited from Upper Egypt. As a result, the corvée was used only in scattered locales, and even then there was peasant resistance. It disappeared by the 1890s.


title: Corvée

text: Corvée labour (specifically, socage) was essential in the feudal economic system of the Habsburg monarchy – later Austrian Empire – and most German states that have belonged to the Holy Roman Empire. Farmers and peasants were obliged to do hard agricultural work for their nobility, typically six months of the year. When a cash economy became established, the duty was gradually replaced by the duty to pay taxes.


title: Corvée

text: After the Thirty Years' War, the demands for corvée labour grew too high and the system became dysfunctional. The official decline of corvée is linked to the abolition of serfdom by Joseph II, Holy Roman Emperor and Habsburg ruler, in 1781. Corvée labour continued to exist, however, and was only abolished during the revolutions of 1848, along with the legal inequality between the nobility and common people.


title: Corvée

text: Bohemia (or Czech lands) were a part of the Holy Roman Empire as well as the Habsburg monarchy and corvée labour itself was called "robota" in Czech. In Russian and other Slavic languages, "robota" denotes any work but in Czech, it specifically refers to unpaid unfree work, corvée labour, serf labor, or drudgery. The Czech word was imported to a part of Germany where corvée labour was known as Robath, and into Hungarian as "robot". The word "robota" turned out to be optimal for Czech writer Karel Čapek who, after a recommendation by his brother Josef Čapek, introduced the word "robot" for (originally anthropomorphic) machines that do unpaid work for their owners in his 1920 play "R.U.R.".


title: Corvée

text: In France the corvée existed until 4 August 1789, shortly after the beginning of the French Revolution, when it was abolished along with a number of other feudal privileges of the French landlords. In these later times it was usually directed mainly towards improving the roads. It was greatly resented, and is considered an important cause of the Revolution. Counterrevolution revived the corvée in France, in 1824, 1836, and 1871, under the name "prestation"; every able-bodied man had to give three days' labour or its money equivalent in order to be allowed to vote. The corvée also continued to exist under the seigneurial system in what had been New France, in British North America.


title: Corvée

text: In 1866, during the French occupation of Mexico, the French Army under Marshal François Achille Bazaine set up the corvée to provide labor for public works in place of a system of fines.


title: Corvée

text: The independent Kingdom of Haiti based at Cap-Haïtien under Henri Christophe imposed a corvée system of labor upon the common citizenry which was used for massive fortifications to protect against a French invasion. Plantation owners could pay the government and have laborers work for them instead. This enabled the Kingdom of Haiti to maintain a stronger economic structure than the Republic of Haiti based in Port-au-Prince in the South under Alexandre Pétion which had a system of agrarian reform distributing land to the laborers.


title: Corvée

text: After deploying to Haiti in 1915 as an expression of the Roosevelt Corollary to the Monroe Doctrine, the U.S. Armed Forces enforced a corvée system of labor in the interest of making improvements to infrastructure.


title: Corvée

text: Imperial China had a system of conscripting labor from the public, equated to the western corvée by many historians. Qin Shi Huang, the first emperor, and following dynasties imposed it for public works like the Great Wall, the Grand Canal, and the system of national roads and highways.


title: Corvée

text: However, as the imposition was exorbitant and punishment for failure draconian, Qin Shi Huang was resented by the people and criticized by many historians. Corvée labor was effectively abolished following the Ming dynasty.


title: Corvée

text: The Inca Empire levied tribute labor through a system called Mit'a which was perceived as a public service to the empire. At its height of efficiency, some subsistence farmers could be called to as much as 300 days of "mit'a" per year. The Spanish colonial rulers co-opted this system after the Spanish conquest of Peru and turned it into unfree labor for natives forced to work on encomiendas and in silver mines. The Incan system that focused on public works found a comeback during the 1960s government of Fernando Belaúnde Terry as a federal effort, with positive effects on Peruvian infrastructure.


title: Corvée

text: Remnants of the system are still found today in modern Peru, such as the Mink'a () communal work that is levied in Andean Quechua communities. An example is the campesino village of Ocra close to Cusco, where each adult is required to perform four days of unpaid labor per month on community projects.


title: Corvée

text: Corvée-style labor ("viṣṭi" in Sanskrit) existed in ancient India and lasted until the early twentieth century. The practice is mentioned in the Mahabharata, where forced labor is said to accompany the army. Manu says mechanics and artisans should be made to work for the king one day a month; other writers advocated for one day of work every fortnight (in all Indian lunar calendars, every month is divided into two fortnights, corresponding to the waxing and the waning moons). For poorer citizens, forced labor was seen as a way to pay their taxes since they could not pay ordinary taxes. Citizens, especially skilled workers, were sometimes made to both pay ordinary taxes and work for the state. If called to work, citizens could pay in cash or kind to discharge their obligations in some cases. In the Maurya and post-Maurya time period, forced labor had become a regular source of income for the state. Epigraphic evidence shows rulers granting lands and villages with and without the right to forced labor from workers of those lands.


title: Corvée

text: Corvée-style labor called was found in pre-modern Japan. During the 1930s, it was common practice to import Corvée laborers from both China and Korea to work in coal mines. This practice continued until the end of World War II.


title: Corvée

text: France annexed Madagascar as a colony in the late 19th century. Governor-General Joseph Gallieni then implemented a hybrid corvée and poll tax, partly for revenue, partly for labour resources (the French had just abolished slavery there), and partly to move away from a subsistence economy; the last feature involved paying small amounts for the forced labour. This was one attempt at a solution to problems that came up under colonialism. The problems were addressed in a way that was typical of colonialism; that way, and the contemporary thinking behind it, are described in a 1938 work:


title: Corvée

text: The system of forced labor otherwise known as evolved within the framework of the system, introduced into the South American colonies by the Spanish government. in the Philippines refers to 40 days forced manual labour for men ranging 16 to 60 years of age; these workers built community structures such as churches. Exemption from was possible via paying the (corruption of the Spanish , meaning "absence"), which was a daily fine of one and a half real. In 1884, the required tenure of labour was reduced to 15 days. The system was patterned after the Mexican selection for forced labur.


title: Corvée

text: In Portuguese Africa (e.g. Mozambique), the Native Labour Regulations of 1899 stated that all able bodied men must work for six months of every year, and that "They have full liberty to choose the means through which to comply with this regulation, but if they do not comply in some way, the public authorities will force them to comply."


title: Corvée

text: Africans engaged in subsistence agriculture on their own small plots were considered unemployed. The labour was sometimes paid, but in cases of rule violations it was sometimes not—as punishment. The state benefited from the use of the labour for farming and infrastructure, by high income taxes on those who found work with private employers, and by selling corvée labour to South Africa. This system of corvée labour, called , was not abolished in Mozambique until 1962, and continued in some forms until the Carnation Revolution in 1974.


title: Corvée

text: In Romania, the corvée was called . Karl Marx describes the corvée system of the Danubian Principalities as a pre-capitalist form of compulsory over-work. The labor of the peasant needed for his own maintenance is distinctly marked off from the work he supplies to the land-owner (the boyar, or , in Romanian) as surplus labour. The 14 days of labour due to the land-owner – as prescribed by the code of the corvée in the – actually amounted to 42 days, because the working day was considered the time required for the production of an average daily product, "and that average daily product is determined in so crafty a way that no Cyclops would be done with it in 24 hours." The code of the corvée was supposed to abolish serfdom, but it could not achieve anything in regard to this goal.


title: Corvée

text: A land reform took place in 1864, after the Danubian Principalities became unified and formed The United Principalities of Moldavia and Wallachia, which abolished the corvée and turned the peasants into free proprietors. The former owners were promised compensation, which was to be paid from a fund the peasants had to contribute to for 15 years. Besides the annual fee, the peasants also had to pay for the newly owned land, although at a price below market value. These debts made many peasants return to a life of semi-serfdom.


title: Corvée

text: In the Russian Tsardom and the Russian Empire there were a number of permanent corvees called (): carriage corvée ( ), coachman corvée ( ), lodging corvée ( ), etc.


title: Corvée

text: In the context of the history of Russia, the term "corvée" is also sometimes used to translate the terms () or (), which refer to the obligatory work that the Russian serfs performed for the (Russian landed nobility) on the 's land. While no official government regulation to the extent of existed, a 1797 ukase by Paul I of Russia described a of three days a week as normal and sufficient for the landowner's needs.


title: Corvée

text: Corvée was used in several states and provinces in North America especially for road maintenance and this practice persisted to some degree in the United States and Canada. Its popularity with local governments gradually waned after the American Revolution with the increasing development of the monetary economy. After the American Civil War, some Southern states, with money in short supply, commuted taxing their inhabitants with obligations in the form of labor for public works, or let them pay a fee or tax to avoid it. The system proved unsuccessful because of the poor quality of work; in 1894, the Virginia Supreme Court ruled that corvée violated the state constitution, and in 1913 Alabama became among the last states to abolish it.


title: Corvée

text: The government of Myanmar is well known for its use of the corvée and has defended the practice in its official newspapers.


title: Corvée

text: In Bhutan, the "" calls for citizens to do work, such as dzong construction, in lieu of part of their tax obligation to the state.


title: Corvée

text: In Rwanda, the centuries-old tradition of umuganda, or community labor, still continues, usually in the form of one Saturday a month when citizens are required to perform this work.


title: Corvée

text: Vietnam maintains corvée for females (ages 18–35) and males (ages 18–45) of 10 days yearly for public works at the discretion of the authorities. This is termed Labor duty ().


title: Corvée

text: The British overseas territory of Pitcairn Islands, which has a population of about 50 and no income or sales tax, has a system of "public work" whereby all able-bodied people are required to perform, when called upon, jobs such as road maintenance and repairs to public buildings.


title: Corvée

text: Since the mid-late 19th century, most countries have restricted corvée labour to conscription (military or civilian service), or prison labour.


title: Erica Tazel

text: Erica Tazel (born 1977) is an American theatre and television actress best known for the role of US Deputy Marshall Rachel Brooks in the FX television series "Justified" (2010–2015).


title: Erica Tazel

text: Tazel holds a B.A. from Spelman College and an M.F.A. from New York University's Graduate Acting Program.


title: Erica Tazel

text: She made her professional acting debut at the New York Shakespeare Festival’s "The Winter’s Tale" (2000); further roles include at the Royal Shakespeare Company's "Cymbeline", and an off-Broadway appearance in Playwrights Horizons' "Juvenilia". Tazel was nominated for the L.A. Drama Critics Circle award for Lead Performance, for her work in "I Have Before Me a Remarkable Document Given To Me by a Young Lady from Rwanda" (role of Juliette, 2007) at The Colony Theatre in Burbank, CA, and received the NAACP Theatre Award for Best Lead Female (2007) for that same role.


title: Erica Tazel

text: On screen, Tazel has made limited appearances, including a minor role in the David Duchovny drama "House of D" (2004, table below), starring Anton Yelchin, Robin Williams, Téa Leoni, and Erykah Badu.


title: Erica Tazel

text: Tazel's television debut was as a dance teacher in an episode of "Sex and the City" (2001); prior to her supporting role in "Justified" she was a guest lead on "Without A Trace", had recurring roles on "Jericho" and "Third Watch", and guest roles on programs including "The Office", "ER", "Law & Order" and "", "Life", "Heartland", "Bones", and "Firefly".


title: Cao Pi

text: Cao Pi () ( – 29 June 226), courtesy name Zihuan, was the first emperor of the state of Cao Wei in the Three Kingdoms period of China. He was the second son of Cao Cao, a warlord who lived in the late Eastern Han dynasty, but the eldest son among all the children born to Cao Cao by his concubine (later wife), Lady Bian. According to some historical records, he was often in the presence of court officials in order to gain their support. He was mostly in charge of defence at the start of his career. After the defeat of Cao Cao's rival Yuan Shao at the Battle of Guandu, he took Yuan Xi's widow, Lady Zhen, as a concubine, but in 221 Lady Zhen died and Guo Nüwang became empress.


title: Cao Pi

text: On 25 November 220, Cao Pi forced Emperor Xian, the last ruler of the Eastern Han dynasty, to abdicate in his favour, after which on 11 December 220 he proclaimed himself emperor and established the state of Cao Wei. Cao Pi continued the wars against the states of Shu Han and Eastern Wu, founded by his father's rivals Liu Bei and Sun Quan respectively, but did not make significant territorial gain in the battles. Unlike his father, Cao Pi concentrated most of his efforts on internal administration rather than on waging wars against his rivals. During his reign, he formally established Chen Qun's nine-rank system as the base for civil service nomination, which drew many talents into his government. On the other hand, he drastically reduced the power of princes, stripping off their power to oppose him, but at the same time, rendering them unable to assist the emperor if a crisis arose within the state. After Cao Pi's death, his successor Cao Rui granted him the posthumous name "Emperor Wen" and the temple name "Shizu".


title: Cao Pi

text: Cao Pi was also an accomplished poet and scholar, just like his father Cao Cao and his younger brother Cao Zhi. He wrote "Yan Ge Xing" (), the first Chinese poem in the style of seven syllables per line (). He also wrote over a hundred articles on various subjects.


title: Cao Pi

text: Cao Pi was the eldest son of Cao Cao and his concubine Lady Bian, but he was the second among all of Cao Cao's sons. (The first was Cao Ang) At the time of Cao Pi's birth, Cao Cao was a mid-level officer in the imperial guards in the capital Luoyang, with no hint that he would go on to the great campaigns he eventually carried out after the collapse of the imperial government in 190. Cao Pi was recorded as excellent swordsman as he studied martial arts from Shi E, a gentleman of the household from the "Rapid as Tigers" () division of the imperial guards. In the period after 190 when Cao Cao was constantly waging war against other rival warlords, it is not known where Cao Pi and Lady Bian were, or what they did. The lone reference to Cao Pi during this period was in 204, when he took Yuan Xi's widow Lady Zhen as his wife.


title: Cao Pi

text: The next immediate reference to Cao Pi's activities was in 211, when he was appointed General of the Household for All Purposes () and Vice Imperial Chancellor (). This position placed him second to his father, who was then Imperial Chancellor () and the "de facto" head of government in China. The eldest of all of Cao Cao's sons, Cao Ang, had died early, so Cao Pi was regarded as the eldest among all his father's sons. Besides, Cao Pi's mother had also become Cao Cao's official spouse after Cao Cao's first wife Lady Ding was deposed. Cao Pi thus became the presumptive heir to his father.


title: Cao Pi

text: However, Cao Pi's status as heir was not immediately made legal, and for years there were lingering doubts on whom Cao Cao intended to make heir. Cao Cao greatly favoured Cao Zhi (his third son with Lady Bian), who was known for his literary talents. Both Cao Pi and Cao Zhi were talented poets, but Cao Zhi was more highly regarded as a poet and speaker. By 215, the brothers appeared to be in harmony with each other, but each had his own group of supporters and close associates engaging the other side in clandestine rivalry. Initially, Cao Zhi's party appeared to be prevailing, and in 216 they were successful in falsely accusing two officials supporting Cao Pi – Cui Yan and Mao Jie. Cui Yan was executed, while Mao Jie was deposed. However, the situation shifted after Cao Cao received advice from his strategist Jia Xu, who concluded that changing the general rules of succession (primogeniture) would be disruptive – using Yuan Shao and Liu Biao as negative examples. Cao Pi was also fostering his image among the people and created the sense that Cao Zhi was wasteful and lacking actual talent in governance. In 217, Cao Cao, who had received the title of a vassal king – King of Wei () – from Emperor Xian (whom he still paid nominal allegiance to), finally declared Cao Pi as his heir apparent (). Cao Pi would remain as such until his father's death in 220.


title: Cao Pi

text: Cao Cao died in the spring of 220 in Luoyang. Even though Cao Pi had been his father's heir apparent for several years, there was initially some confusion as to what would happen next. The apprehension was particularly heightened when, after Cao Cao's death, the Qingzhou Corps under the general Zang Ba suddenly deserted, leaving Luoyang and returning home. Besides, Cao Pi's younger brother Cao Zhang (also born to Lady Bian) had arrived in Luoyang in a hurry, resulting in rumours that he was intending to seize power from his elder brother. Upon hearing these news at Cao Cao's headquarters at Ye, Cao Pi hastily declared himself the new King of Wei and issued an edict in the name of his mother Queen Dowager Bian, before receiving an official confirmation from Emperor Xian, to whom he still nominally paid allegiance. After Cao Pi's self-declaration, neither Cao Zhang nor any other individual took action against him. Cao Pi then ordered his brothers, including Cao Zhang and Cao Zhi, to return to their respective fiefs. With the help of Jiang Ji, the political situation soon stabilised.


title: Cao Pi

text: In the winter of 220, Cao Pi made his move for the imperial throne, strongly suggesting to Emperor Xian that he should yield the throne. Emperor Xian did so, and Cao Pi formally declined three times (a model that would be followed by future usurpers in Chinese history), and then finally accepted, establishing the state of Cao Wei. This event marked the official end of the Han dynasty and the beginning of the Three Kingdoms period. The dethroned Emperor Xian was granted the title "Duke of Shanyang" (). Cao Pi granted posthumous titles of emperors to his grandfather Cao Song and his father Cao Cao , while his mother Queen Dowager Bian became empress dowager. He also moved the imperial capital from Xuchang to Luoyang.


title: Cao Pi

text: After news of Cao Pi's ascension (and an accompanying false rumour that Cao Pi had executed Emperor Xian) arrived in Liu Bei's domain of Yi Province (covering present-day Sichuan and Chongqing), Liu Bei also declared himself emperor in 221, establishing the state of Shu Han. Sun Quan, who controlled the vast majority of southeastern and southern China, did not take any affirmative steps one way or another, leaving his options open.


title: Cao Pi

text: An armed conflict between Liu Bei and Sun Quan quickly materialised, because in late 219 Sun Quan had sent his general Lü Meng to invade Jing Province and seize the territories from Liu Bei, which resulted in the death of Liu's general Guan Yu. To avoid having to fight on two fronts, Sun Quan formally paid allegiance to Cao Pi, expressing his willingness to become a vassal under Wei. Cao Pi's strategist Liu Ye suggested to reject and instead attack Sun Quan on a second front. This would effectively partition Sun Quan's domain with Shu, and would eventually allow Cao Pi to destroy Shu as well. Cao Pi declined this suggestion, in a fateful choice that most historians believe doomed his empire to ruling only northern and central China; such an opportunity would not come again. Indeed, against Liu Ye's advice, Cao Pi granted Sun Quan the title "King of Wu" () and the nine bestowments.


title: Cao Pi

text: Sun Quan's submission did not last long. After Sun Quan's forces, under the command of Lu Xun, defeated Shu forces at the Battle of Xiaoting in 222, Sun Quan began to distance himself from Wei. When Cao Pi demanded that Sun Quan send his heir apparent, Sun Deng, to Luoyang as a hostage, Sun Quan refused and formally broke ties with Wei. Cao Pi personally led an expedition against Sun Quan, and in response, Sun Quan declared independence from Wei, establishing the state of Eastern Wu (but he continued ruling as "King of Wu" and did not declare himself emperor until 229). By this time, having defeated Shu, the Wu forces enjoyed high morale and effective leadership from Sun Quan, Lu Xun and a number of other capable generals. Cao Pi's forces were not able to make significant advances against them despite several large-scale attacks in the next few years. The division of the former Han Empire into three states has become firmly established, particularly after Liu Bei's death in 223. The Shu chancellor Zhuge Liang, serving as regent for Liu Bei's son and successor Liu Shan, re-established the alliance with Wu, resulting in Wei having to defend itself on two fronts and unable to conquer either. Exasperated, Cao Pi made a famous comment in 225 that "Heaven created the Yangtze River to divide the north and the south."


title: Cao Pi

text: Cao Pi was generally viewed as a competent, but unspectacular, administrator of his empire. He commissioned a number of capable officials to be in charge of various affairs of the empire, employing his father's general guidelines of valuing abilities over heritage. However, he was not open to criticism, and officials who dared to criticise him were often demoted and, on rare occasions, put to death.


title: Cao Pi

text: Since Cao Pi was still fearful and resentful of Cao Zhi, he soon had the latter's fief reduced in size and had a number of his associates executed. Ding Yi, who was chief among Cao Zhi's strategists, had his whole clan exterminated as a result of assisting the latter in the past. In summary, under regulations established by Cao Pi, not only were the Wei princes (unlike princes of the Han dynasty) distanced from central politics, they also had minimal authority even in their own principalities and were restricted in many ways, particularly in the use of military force.


title: Cao Pi

text: Cao Pi was recorded to frequently ridicule his subordinates. For example, Yu Jin was captured by Liu Bei's general Guan Yu at the Battle of Fancheng in 219, and was later taken back to Wu and detained there after the Wu invasion of Jing Province. Yu Jin was allowed to return to Wei after Wu briefly became a vassal state under Wei in 221. Cao Pi reinstated Yu Jin as General Who Pacifies the Borders () and announced that he would send Yu Jin back to Eastern Wu – where he had been imprisoned – as an envoy. However, before Yu Jin's departure, he was instructed to travel to Ye to pay his respects at Cao Cao's tomb. When Yu Jin arrived, he found that the emperor had commissioned artists to paint, in his father's tomb, scenes of the Battle of Fancheng. These scenes showed Yu Jin begging for his life to be spared and succumbing to the victorious Guan Yu, while his subordinate Pang De was shown dying an honourable death by resisting the invading forces to his last breath. Upon seeing the vivid mural, Yu Jin was so filled with regret and shame that he fell ill and soon died. Cao Pi further gave the deceased Yu Jin a negative-sounding posthumous title, "Marquis Li" (), for people to remember the latter as the "stony marquis (or vicious marquis)". Wang Zhong, a general who followed Cao Cao for many years, was also a subject of ridicule by Cao Pi.


title: Cao Pi

text: An immediate issue after Cao Pi became emperor in 220 was who the empress would be. Lady Zhen was his wife. Cao Pi summoned Lady Zhen to Luoyang, but Lady Zhen refused because of her poor health. In 221 Lady Zhen died and the position of empress went to Guo Nüwang.


title: Cao Pi

text: Guo Nüwang did not bear Cao Pi any children. Cao Rui was the eldest of Cao Pi's sons, but because of his mother's death, he was not instated as the crown prince. Instead, Cao Rui was appointed "Prince of Pingyuan" after his father's ascension to the throne. Cao Pi did not appear to have seriously considered any other son as heir. (It might have been because the other sons were all significantly younger, although their ages were not recorded in history.) In the summer of 226, when Cao Pi was seriously ill, he finally named Cao Rui as his crown prince. On his deathbed, he entrusted Cao Rui to the care of Cao Zhen, Chen Qun and Sima Yi. Following his father's death, Cao Rui ascended the throne at the age of 21.


title: Cao Pi

text: Cao Pi appears as a playable character in Koei's "Dynasty Warriors" and "Warriors Orochi" video game series. He also appears in Koei's "Romance of the Three Kingdoms" series.


title: Spoil tip

text: A spoil tip (also called a boney pile, culm bank, gob pile, waste tip or bing) is a pile built of accumulated "spoil" – waste material removed during mining. These waste materials are typically composed of shale, as well as smaller quantities of Carboniferous sandstone and other residues. Spoil tips are not formed of slag, but in some areas, such as England and Wales, they are referred to as slag heaps. In Scotland the word "bing" is used.


title: Spoil tip

text: The term "spoil" is also used to refer to material removed when digging a foundation, tunnel, or other large excavation. Such material may be ordinary soil and rocks (after separation of coal from waste), or may be heavily contaminated with chemical waste, determining how it may be disposed of. Clean spoil may be used for land reclamation.


title: Spoil tip

text: Spoil is distinct from tailings, which is the processed material that remains after the valuable components have been extracted from ore.


title: Spoil tip

text: The phrase originates from the French word "espoilelier", a verb conveying the meaning: to seize by violence, to plunder, to take by force.


title: Spoil tip

text: Spoil tips may be conical in shape, and can appear as conspicuous features of the landscape, or they may be much flatter and eroded, especially if vegetation has established itself. In Loos-en-Gohelle, in the former mining area of Pas-de-Calais, France, are a series of five very perfect cones, of which two rise from the plain.


title: Spoil tip

text: Most commonly the term is used for the piles of waste earth materials removed during an excavation process.


title: Spoil tip

text: Spoil banks can also refer to refuse heaps formed from removal of excess surface materials. For example, alongside livestock lots, spoil banks are formed of manure and other slurry periodically removed from the surface of the livestock lot areas.


title: Spoil tip

text: Spoil tips sometimes increased to millions of tons, and, having been abandoned, remain as huge piles today. They trap solar heat, making it difficult (although not impossible) for vegetation to take root; this encourages erosion and creates dangerous, unstable slopes. Existing techniques for regreening spoil tips include the use of geotextiles to control erosion as the site is resoiled and simple vegetation such as grass is seeded on the slope.


title: Spoil tip

text: The piles also create acid rock drainage, which pollutes streams and rivers. Environmental problems have included surface runoff of silt, and leaching of noxious chemical compounds from spoil banks exposed to weathering. These cause contamination of ground water, and other problems.


title: Spoil tip

text: In the United States, current state and federal mining regulations require that the earth materials from excavations be removed in such a fashion that they can be replaced after the mining operations cease in a process called mine reclamation, with oversight of mining corporations. This requires adequate reserves of monetary bonds to guarantee a completion of the reclamation process when mining becomes unprofitable or stops. (See for example, the Surface Mining Control and Reclamation Act of 1977.)


title: Spoil tip

text: In some spoil tips, the waste resulting from industries such as coal or oil shale production can contain a relatively high proportion of hydrocarbons or coal dust. Spontaneous subterranean combustion may result, which can be followed by surface fires. In some coal mining districts, such fires were considered normal and no attempt was made to extinguish them.


title: Spoil tip

text: Such fires can follow slow combustion of residual hydrocarbons. Their extinction can require complete encasement, which can prove impossible for technical and financial reasons. Sprinkling is generally ineffective and injecting water under pressure counter-productive, because it carries oxygen, bringing the risk of explosion.


title: Spoil tip

text: The perceived weak environmental and public health effects of these fires leads generally to waiting for their natural extinction, which can take a number of decades.


title: Spoil tip

text: The problem of landslides in spoil tips was first brought to public attention in October 1966 when a spoil tip at Aberfan in Wales gave way, killing 144 people, 116 of them children. The tip was built over a spring, increasing its instability, and its height exceeded guidelines. Water from heavy rainfall had built up inside the tip, weakening the structure, until it suddenly collapsed onto a school below.


title: Spoil tip

text: The wider issue of stability had been known about prior to the Aberfan disaster; for example, it was discussed in a paper by Professor George Knox in 1927, but received little serious consideration by professional engineers and geologists — even to those directly concerned with mining.


title: Spoil tip

text: In February 2013, a spoil tip landslip caused the temporary closure of the Scunthorpe to Doncaster railway line in England.


title: Spoil tip

text: Landslides are rare in spoil tips after settling and vegetation growth act to stabilise the spoil. However, when heavy rain falls on spoil tips that are undergoing combustion, infiltrated water changes to steam; increasing pressure that may lead to a landslide. In Herstal, Belgium, a landslide on the Petite Bacnure spoil tip in April 1999 closed off a street for many years.


title: Spoil tip

text: Several techniques of re-utilising the spoil tips exist, usually including either geotechnics or recycling. Most commonly, old spoil tips are partially revegetated to provide valuable green spaces since they are inappropriate for building purposes. At Nœux-les-Mines, an artificial ski slope has been constructed on the tip. If spoil tips are considered to contain sufficient amounts of residual material, various methods are employed to remove the spoil from the site for subsequent processing.


title: Spoil tip

text: The oldest coal-based spoil tips may still contain enough coal to begin spontaneous slow combustion. This results in a form of vitrification of the shale, which then acquires sufficient mechanical strength to be of use in road construction. Some can therefore have a new life in being thus exploited; for example, the flattened pile of residue from the 11/19 site of Loos-en-Gohelle. Conversely, others are painstakingly preserved on account of their ecological wealth. With the passage of time, they become colonised with a variety of flora and fauna, sometimes foreign to the region. This diversity follows the mining exploitation. In South Wales some spoil tips are protected as Sites of Special Scientific Interest because they provide a unique habitat for 57 species of Lichen, several of which are at risk due to their limited environment being developed and by vegetation development.


title: Spoil tip

text: For example, because the miners threw their apple or pear cores into the wagons, the spoil tips became colonised with fruit trees. One can even observe the proliferation of buckler-leaved sorrel (French sorrel – "Rumex scutatus"), the seeds of which have been carried within the cracks in the pine timber used in the mines. Furthermore, on account of its dark colour, the south face of the spoil tip is significantly warmer than its surroundings, which contributes to the diverse ecology of the area. In this way, the spoil tip of Pinchonvalles, at Avion, hosts 522 different varieties of higher plants. Some sixty species of birds nest there.


title: Spoil tip

text: Some are used to cultivate vines, as in the case of Spoil Tip No. 7 of the coal-mining region of Mariemont-Bascoup near Chapelle-lez-Herlaimont (province of Hainaut). It produces some 3,000 litres of wine each year from a vineyard on its slopes.


title: Spoil tip

text: Some spoil tips are used for various sporting activities. The slopes of the spoil tips of 11/19 at Loos-en-Gohelle, or again, at Nœux-les-Mines, are used for winter sports, for example ski and luge. A piste was built on the flank of the heap. In Belgium, a long distance footpath along the spoil tips (GR-412, "Sentier des terrils") was opened in 2005. It leads from Bernissart in western Hainaut to Blegny in the province of Liège.


title: Spoil tip

text: In the United States, mining companies have not been allowed to leave behind abandoned piles since the Surface Mining Control and Reclamation Act was passed in 1977. The Virginia City Hybrid Energy Center uses coal gob as a fuel source for energy production.


title: Spoil tip

text: One of the highest, at least in Western Europe, is in Loos-en-Gohelle in the former mining area of Pas-de-Calais, France. It comprises a range of five cones, of which two reach , surpassing the highest peak in Flanders, Mont Cassel. One of the regions of Europe most "littered" with (mountainous) spoil heaps is the Donbas, in Ukraine, especially around the city of Donetsk, which alone boasts about 130 of them.


title: Spoil tip

text: In Ukrainian, they are called "terikony" (soil cones, in the singular: "terikon") because of their shape.


title: Spoil tip

text: In Heringen, Hesse, Germany, is the popularly called "Monte Kali", made of spoil from potash mining and rising some 200 meters above the surrounding terrain. "La Muntanya de Sal" (The Salt Mountain), another potash mine spoil heap, lies in Cardona, Catalonia, at about 120 meters in height. A larger and higher pile is that of "El runam del Cogulló" (The Spoil Heap of El Cogulló), also known as "El runam de la democràcia" (The Slag Heap of Democracy) or "Montsalat" (Salty Boy Mountain), in Sallent, which has already grown higher than the small mountain it was named after (El Cogulló, 474 meters above sea level).


title: Spoil tip

text: Richard Llewellyn's novel "How Green Was My Valley" (1939) describes the social and environmental effects of coal mining in Wales at the turn of the 20th century. The local mine's spoil tip, which he calls a slag heap, is the central figure of devastation. Eventually the pile overtakes the entire valley and crushes Huw Morgan's house:


title: Spoil tip

text: The slagheap is moving again. I can hear it whispering to itself, and as it whispers, the walls of this brave little house are girding themselves to withstand the assault. For months, more that I ever thought it would have the courage to withstand, that great mound has borne down upon these walls, this roof. And for those months the great bully has been beaten, for in my father’s day men built well for they were craftsmen. Stout beams, honest blocks, good work, and love for the job, all that is in this house. But the slag heap moves, pressing on, down and down, over and all round this house which was my father’s and my mother’s and now is mine. Soon, perhaps in an hour, the house will be buried, and the slag heap will stretch from the top of the mountain right down to the river in the Valley. Poor river, how beautiful you were, how gay your song, how clear your green waters, how you enjoyed your play among the sleepy rocks (102).


title: Allis-Chalmers

text: Allis-Chalmers was a U.S. manufacturer of machinery for various industries. Its business lines included agricultural equipment, construction equipment, power generation and power transmission equipment, and machinery for use in industrial settings such as factories, flour mills, sawmills, textile mills, steel mills, refineries, mines, and ore mills.


title: Allis-Chalmers

text: The first Allis-Chalmers Company was formed in 1901 as an amalgamation of the Edward P. Allis Company (steam engines and mill equipment), Fraser & Chalmers (mining and ore milling equipment), the Gates Iron Works (rock and cement milling equipment), and the industrial business line of the Dickson Manufacturing Company (engines and compressors). It was reorganized in 1912 as the Allis-Chalmers Manufacturing Company. During the next 70 years its industrial machinery filled countless mills, mines, and factories around the world, and its brand gained fame among consumers mostly from its farm equipment business's orange tractors and silver combine harvesters.


title: Allis-Chalmers

text: In the 1980s and 1990s, a series of divestitures transformed the firm and eventually dissolved it. Its successors today are Allis-Chalmers Energy and AGCO.


title: Allis-Chalmers

text: Author-photographer Randy Leffingwell (1993) aptly summarized the firm's origins and character. He observed that it "grew by acquiring and consolidating the innovations" of various smaller firms and building upon them; and he continued that "Metal work and machinery were the common background. Financial successes and failures brought them together."


title: Allis-Chalmers

text: Former marketing executive Walter M. Buescher (1991) said that Allis-Chalmers "was a conglomerate before the word was coined." Whether or not it is literally true that Allis-Chalmers predated the sense of "conglomerate" meaning a widely diversified parent corporation, Buescher's point is valid: Allis-Chalmers, despite its common theme of machinery, was an amalgamation of disparate business lines, each with a unique marketplace, beginning in an era when consolidations within industries were fashionable but those "across" industries were not yet common.


title: Allis-Chalmers

text: Edward P. Allis was an entrepreneur who in 1860 bought a bankrupt firm at a sheriff's auction, the Reliance Works of Milwaukee, Wisconsin, which had been owned by James Decker and Charles Seville. Decker & Seville were millwrights who made equipment for flour milling. Under Allis's management, the firm was reinvigorated and "began producing steam engines and other mill equipment just at the time that many sawmills and flour mills were converting to steam power." Although the financial panic of 1873 "caught Edward Allis overextended" and forced him into bankruptcy, "his own reputation saved him and reorganization came quickly," forming the Edward P. Allis Company. Leffingwell said, "He set out to hire known experts: George Hinkley, who perfected the band saw; William Gray, who revolutionized the flour-milling process through roller milling; and Edwin Reynolds, who ran the Corliss Steam Engine works." Allis died in 1889, but under his sons (Charles Allis and William Allis) and the other principals, the firm continued to prosper, and by 1900 it had grown to become one of America's largest steam engine builders.


title: Allis-Chalmers

text: Thomas Chalmers was a Scottish immigrant to America who came to the U.S. about 1842. By 1844 he was at Chicago, Illinois and had found work with P.W. Gates, whose foundry and blacksmithing shops produced plows, wagons, and flour-milling equipment. The Gates firm "built the first steam-operated sawmill in the country at a time when Chicago was the leading producer of milled lumber in the country." In 1872, Thomas Chalmers founded the Fraser & Chalmers firm to manufacture mining machinery, boilers, and pumps. By 1880 steam engines were part of the product line and by 1890, the firm had become one of the world's largest manufacturers of mining equipment. Thomas Chalmers's son, William James Chalmers, was president of the company from circa 1890 to 1901. Meanwhile, the Gates Iron Works, with Chalmers family involvement, had become a manufacturer of crushers, pulverizers, and other rock and cement milling equipment.


title: Allis-Chalmers

text: Another Scottish immigrant family, the Dickson family, came to Canada and the U.S. in the 1830s. By 1852, they had organized a small machine shop and foundry (Dickson & Company) in Scranton, Pennsylvania. In 1856 Thomas Dickson became its president, and in 1862 the firm incorporated as the Dickson Manufacturing Company. By 1900 they were building boilers, steam engines, locomotives, internal combustion engines, blowers, and air compressors.


title: Allis-Chalmers

text: By 1901 the principals of the Edward P. Allis, Fraser & Chalmers, and Gates firms had decided to merge their companies. Edwin Reynolds believed Allis could control the industrial engine business. In May 1901 the Allis-Chalmers Company was formed. It acquired Dickson's industrial engine business. Dickson's locomotive business was rolled into the new locomotive consolidation, the American Locomotive Company (ALCO).


title: Allis-Chalmers

text: The managing director of the new company was Charles Allis, his brother William was chairman of the board, and William J. Chalmers was deputy managing director. Shortly after the merger was completed, a new factory was built in an area west of Milwaukee that was then known as North Greenfield. In 1902, with this new factory, the locale was renamed West Allis, Wisconsin.