Forty miles to the west of Tucson, a developer attempted to develop an "oasis" glade in the Sonoran Desert. He created a glade that, the developer claims, is as lush and plant-filled as the ambient 35 degree C temperatures allow. In particular, the developer planted several native fruit-bearing plants, such as prickly-pear cactus. Once the glade was established, a number of desert birds and mammals would regularly inhabit the glade, often eating most of the fruit that falls from the plants. The considerations given best serve as part of an argument that: ['the presence of the desert animals in the glade do not serve as evidence against the claim of the developer.', 'most of these desert animals in the glade would have perished if the glade had not been created in that location.', 'the shade from all the plants in the glade measurably reduces the ambient temperature within the glade.', "enclosing the fruit -- bearing plants in wire cages to prevent consumption by desert animals would allow for fruit sales to cover the cost of the glade's development."]