Wednesday, January 20, 2010

Nolon on The Land Use Stabilization Wedge Strategy

John R. Nolon (Pace) has posted The Land Use Stabilization Wedge Strategy: Shifting Ground to Mitigate Climate Change, forthcoming in William & Mary Environmental Law and Policy Review, Vol. 34, p. 1, 2009.  The abstract:

This article describes how local governments, through the clever application of existing land use techniques, can mitigate climate change. This strategic path follows one developed by Princeton professor Robert Socolow, who identified and described fifteen categories for organizing society’s climate change mitigation efforts. Five of Socolow’s strategic categories fall within the reach of local land use authority: reduced use of vehicles, energy efficient buildings, vegetative carbon sequestration, wind power, and solar power. Through the aggregation of these local land use techniques, significant energy savings and carbon dioxide (CO2) reduction can be achieved. After making some background points, this article describes how local governments are attacking the root causes of climate change and how state and federal policies can embrace local power, energy, and people to launch a coordinated attack on perhaps the greatest challenge our nation faces.

Matt Festa

January 20, 2010 in Clean Energy, Environmental Law, Green Building, Scholarship | Permalink | Comments (0) | TrackBack (0)

Tuesday, January 19, 2010

Symposium on Climate Change, Water, and Adaptive Law

From our itinerant friend, Tony Arnold, who is visiting at University of Houston this semester:

The University of Houston Law Center and the Environmental & Energy Law
& Policy Journal are pleased to announce a Symposium on Climate Change,
Water, and Adaptive Law to be held on Friday, February 26, 2010, from
8:00 a.m. to 5:00 p.m. at the Czech Center Museum, 4920 San Jacinto,
Houston, Texas 77004.  Leading experts from diverse universities,
disciplines, professional backgrounds, and policy making roles will
address how law and the legal system need to adapt to address the
impacts of climate change on water resources and regimes, and the extent
to which it can.

Speakers include:

Panel on State and Local Adaptation to Climate Change’s Impacts on

1. Robin Kundis Craig, Attorneys’ Title Professor and Associate Dean for
Environmental Programs, Florida State University College of Law (Opening
Presentation of the Symposium)

2. Noah Hall, Assistant Professor of Law, Wayne State University Law
School; Visiting Professor, University of Michigan Law School; Executive
Director, Great Lakes Environmental Law Center

3. Craig Anthony (Tony) Arnold, Boehl Chair in Property & Land Use,
Professor of Law, Affiliated Professor of Urban Planning, Chair of the
Center for Land Use & Environmental Responsibility, University of
Louisville; Symposium Visiting Professor, University of Houston Law

4. Kathleen Miller, Scientist III, Institute for the Study of Society
and the Environment, National Center for Atmospheric Research

5. Daniella Landers, Shareholder, The Sutherland Law Firm, Houston, TX

Luncheon Keynote Speech:  The Hon. Eliot Shapleigh (D-El Paso), Texas
State Senate

Panel on Energy, Climate Change, and Water: The Complex Intersection

1. A. Dan Tarlock, Distinguished Professor of Law and Director of the
Program in Environmental and Energy Law, Chicago-Kent College of Law,
Illinois Institute of Technology

2. Lea-Rachel Kosnik, Assistant Professor of Economics, University of
Missouri-St. Louis; Dispute Resolution Panel Member for Federal
Hydropower Dam Relicenses, Federal Energy Regulatory Commission

3. Amy Hardberger, Attorney, Environmental Defense Fund, Austin, TX

4. Elizabeth Burleson, Assistant Professor of Law, University of South
Dakota School of Law; Consultant, United Nations

5. Scott Deatherage, Partner, Environmental Law Section, & Practice
Group Leader, Climate Change & Renewable Energy Practice Group, Thomspon
& Knight, LLP, Dallas, TX

Symposium Description: "Water use and climate change share a complex,
dynamic, multiscalar interdependence.  Water use contributes to climate
change in the energy used to transfer water substantial distances, the
destruction of carbon-sequestering vegetation and erosion of soils (and
the subsequent release of greenhouse gases into the atmosphere) from too
much or too little water, and the facilitation of sprawling (and
arguably unsustainable) development, among other relationships.
Hydropower has been suggested as an alternative energy source that
reduces emission of greenhouse gases, but poses a variety of other
ecological and social concerns.  Perhaps most importantly, climate
change will affect water supplies and watersheds, contributing to water
scarcity, rising sea levels, saltwater intrusion into groundwater, more
severe storm-event cycles that alter watershed hydrology, and changes to
riparian vegetation and stream structures that similarly alter watershed
functioning and composition.  This symposium will address the capacity
of water law to adapt to the changing, uncertain, and potentially
extreme demands and stresses that climate change -- and our responses to
climate change -- will put on water resources."

For more in, or contact Chief Symposium
Editor/Director - Lisa Baiocchi-Mooney,  The
Symposium will offer 8 hours of CLE credit for the State of Texas.

Jamie Baker Roskie

January 19, 2010 in Clean Energy, Conferences, Environmental Law, Water | Permalink | Comments (0) | TrackBack (0)

TDRs in Beaufort

Will Cook and I are headed to Beaufort, South Carolina this week to assist in the implementation of their Transfer of Development Rights program.  I have been working with various jurisdictions in Georgia on TDRs since the clinic started in 2002.  In fact, one of our first projects was drafting a TDR ordinance for Chattahoochee Hill Country. Since then I've worked with TDR expert Rick Pruetz and other faculty here at UGA on TDR feasibility studies for other Georgia counties. 

This time Rick and I have joined forced with Bill Fulton (a planner so famous he has his own Wikipedia page) and his crackerjack staff at DC&E consulting (particularly Aaron Engstrom, who specializes in TDR work).

Beaufort's TDR program is interesting for a number of reasons.  It will be an inter-jurisdictional program with the City of Beaufort and the Town of Port Royal.  It also has twin goals, to conserve agricultural land and to protect the overflight zone of the Marine Corps Air Station.

We'll have more to report as this project progresses. Also, if Will brings a digital camera, maybe we'll even have some pictures! This is a beautiful area - and where many movies have been filmed, most famously The Big Chill.

Jamie Baker Roskie

January 19, 2010 in Georgia, Planning, Property Rights, Transferable Development Rights | Permalink | Comments (0) | TrackBack (0)

Fair Housing video...

We recently completed the landlord/tenant portion of Property I.  I usually focus a great deal on the FHA because it combines statutory and common law into a nice blend for the students.

Along those lines, here's an interesting Fair Housing PSA that one of my students sent along:

--Chad Emerson, Faulkner U.

January 19, 2010 | Permalink | Comments (1) | TrackBack (0)

Monday, January 18, 2010

Duany's Smart Growth Manual

Duany SmartGrowth manual The Miami Herald has an article/interview about Andres Duany's latest publication, The Smart Growth Manual (Duany, Jeff Speck, & Mike Lydon, McGraw-Hill 2009)From the story:

Want to be green? Dump the cul-de-sac. Ban the mall. Leave the Prius at home. The best thing you can do for the environment is to push for dense, compact, attractive and walkable urban neighborhoods that mix homes, shops and offices, just like we used to.

That, in a sharpened nutshell, is the message delivered by The Smart Growth Manual (McGraw-Hill Professional, $24.95), an intentionally slim, readable, well-illustrated and portable how-to guide co-written by Miami architect, planner and pioneering anti-sprawl combatant Andrés Duany.

The book is a follow-up of sorts to their seminal new urbanist text Suburban Nation: The Rise of Sprawl and the Decline of the American Dream (Duany, Plater-Zyberk, & Speck 2001).  Of course Miami 21 is highly relevant and gets mentioned in the article.  Aside from the substantive contribution that this book will make, I was particularly interested in this snippet from the Herald piece:

Q: Why do you use `Smart Growth' and not `New Urbanist' in the title? Is there a difference between the two?

A: Smart Growth has always been the more popular title. It's not correct. Smart growth is government-initiated. New Urbanist is market-initiated. Smart Growth is almost entirely New Urbanist propositions but repackaged with a more effective name. But the book is balanced (between the two).

Matt Festa

January 18, 2010 in Architecture, Books, New Urbanism, Planning, Smart Growth | Permalink | Comments (2) | TrackBack (0)

Eichholtz, Kok, & Quigley on Green Office Buildings

Piet M.A. Eichholtz (Maastricht--Economics), Nils Kok (Maastricht--Economics), and John M. Quigley (Berkeley--Economics) have posted Doing Well by Doing Good? Green Office Buildings, forthcoming in the American Economic Review.  The abstract:

This paper provides the first credible evidence on the economic value of the certification of “green buildings” - derived from impersonal market transactions rather than engineering estimates. Our analysis of clusters of certified green buildings and nearby comparables establishes that buildings with “green ratings” command substantially higher rents and selling prices than otherwise identical buildings.

Moreover, variations in the premium for green office buildings are systematically related to their energy-saving characteristics. An increase in the energy efficiency of a green building is associated with a substantial increase in selling price - over and above the premium for a labeled building. Further evidence suggests that the intangible effects of the label itself may also play a role in determining the values of green buildings in the marketplace.

Matt Festa

January 18, 2010 in Environmental Law, Green Building, Scholarship | Permalink | Comments (0) | TrackBack (0)

Rule Change for Federal Funding of Local Transit?

Administrative law buffs will take note of the recent news that the Administration Loosens Purse Strings for Transit Projects (NYT). 

WASHINGTON — The Obama administration will make it easier for cities and states to spend federal money on public transit projects, and particularly on the light-rail systems that have become popular in recent years, Transportation Secretary Ray LaHood said Wednesday.

Administration officials said they were reversing guidelines put in place by the Bush administration that called for evaluating new transit projects largely by how much they cost and how much travel time they would save.

Transit advocates have long complained that such cost-effectiveness tests have kept many projects from being built — especially light-rail projects, since streetcars are not fast — and made it much harder for transit projects to win federal financing than highway projects.

Here's the DOT press release.  Transportation Secretary Ray LaHood says

“Our new policy for selecting major transit projects will work to promote livability rather than hinder it,” said Secretary LaHood. “We want to base our decisions on how much transit helps the environment, how much it improves development opportunities and how it makes our communities better places to live.”

Sec. LaHood discusses it further on his Official Blog, Welcome to the Fast Lane.  He states that under the new rule the feds will evaluate local projects by six criteria:

  • Economic development
  • Mobility improvements
  • Environmental benefits
  • Operating efficiencies
  • Cost effectiveness
  • Land use

For an example of how this federal rule change might affect one local government's light rail plans, see this Houston Chronicle analysis.  The Federal Transit Administration will soon be initiating a rulemaking process, with notice and comment.  Stay tuned. 

Matt Festa

January 18, 2010 in Environmental Law, Houston, Local Government, Transportation | Permalink | Comments (0) | TrackBack (0)

A Bird's Eye View...

Metropolis Magazine has a very interesting article and photo essay from a long-time observer of sprawl from the sky:

“With these pictures, I am interested in exploring the intersection of art and environmental politics,” Gielen says. “I hope to trigger a reevaluation of our built environment and the methods of its development, to ask: What can be considered a viable, ecologically sound growth process?”

Read and view the entire article here.

--Chad Emerson, Faulkner U.

January 18, 2010 | Permalink | Comments (0) | TrackBack (0)

Sunday, January 17, 2010

Revised Landmarks Guide


In case readers missed it last year, the New York City Landmarks Preservation Commission has published the fourth edition of its well-known Guide to New York City Landmarks (John Wiley & Sons).  This useful guide covers over 1,200 buildings, 90 historic districts, and four centuries of the Big Apple's history, including new research that even the most devoted students of NYC may not yet have encountered.  Although the guide is city-specific, it offers lessons on architectural history that communities across the country can appreciate.  The Guide makes clear that during an unprecedented period of development, the Landmarks Preservation Commission's efforts at identifying and highlighting iconic buildings provided a signficant counterpoint.  Learn more about these efforts by clicking here

The Landmarks Preservation Commission is the mayoral agency responsible for protecting and preserving New York City's architecturally, historically, and culturally significant buildings and sites.  Since its creation in 1965, the Landmarks Commission has granted landmark status to more than 25,000 individual buildings, including 1,215 individual landmarks, 110 interior landmarks, 10 scenic landmarks, and 92 historic districts in all five boroughs.  Under the City's landmarks law, considered the most powerful in the nation, the Commission must be comprised of at least three architects, a historian, a realtor, a planner or landscape architect, as well as a representative of each borough.

Will Cook, Charleston School of Law 

January 17, 2010 in Historic Preservation | Permalink | Comments (1) | TrackBack (0)

Cruise Ships & Land Use


The talk in Charleston these days--apart from Boeing's decision to build a new manufacuturing center nearby--focuses primarily on proposed plans to construct an upgraded terminal for cruise lines--specifically for Carnival, doubling the current number of cruises departing from the Holy City.  Even though Charleston boasts a seafaring past, the land use community's reception to the proposal has been mixed.  By way of example, for those who've visited Old San Juan, Puerto Rico, on a busy day when thousands of tourists pour from multiple muti-story cruise ships and overwhelm local infrastructure, similar developments in Charleston may not be such a good thing.  To this end, preservationists are weighing in, pro and con, on the proposed two-story system of shops, dining, and lodging planned for the area adjacent to the terminal.  Striking the right balance between tourism, economic diversity, quality of life for local residents, and preservation of historic resources is never easy, but public discussions on the topic suggest that local consensus may be reached.  Click here and here to learn more.  New York design firm Cooper Robertson & Partners, which has already designed several public buildings in historic Charleston (Visitors Center, Judicial Center, College of Charleston School of Education) has been selected to do the work. 

Will Cook, Charleston School of Law

January 17, 2010 in Aesthetic Regulation, Charleston, Community Design, Community Economic Development, Development, Downtown, Historic Preservation | Permalink | Comments (0) | TrackBack (0)

Rocky Mountain Land Use Institute Director Leaves for "Greener Pastures"

James Van Hemert, AICP and sustainability advocate, has left the directorship of the Rocky Mountain Land Use Institute to become the planning director of a small town in Vancouver, BC and an organic farmer.  This according to "DU Today," the news service of the University of Denver.  RMLUI has been associated with the University of Denver for almost 20 years, and it is a strong voice for smart growth in Colorado.  However, according to the article on DU Today, Van Hemert believes Denver's moves toward sustainability have been "tepid at best," and so he and his wife decided on this move to BC as an attempt to live a more sustainable lifestyle themselves.  Although we'll miss his presence in the academic realm, I'm sure this is not the last we'll hear from James.  We wish him well in his new endeavors.

Jamie Baker Roskie

January 17, 2010 | Permalink | Comments (0) | TrackBack (0)

Friday, January 15, 2010

Penalver & Katyal on Property Outlaws

Outlaws Eduardo M. Penalver (Cornell) and Sonia Katyal (Fordham) have posted on SSRN the front matter and introduction to their new book, Property Outlaws: How Squatters, Pirates, and Protesters Improve the Law of Ownership (Yale University Press, 2010).  Click on the picture for a link to the book on Amazon; here is the abstract to the SSRN posting:

Property Outlaws puts forth the intriguingly counterintuitive proposition that, in the case of both tangible and intellectual property law, disobedience can often lead to an improvement in legal regulation. The authors argue that in property law there is a tension between the competing demands of stability and dynamism, but its tendency is to become static and fall out of step with the needs of society.

The authors employ wide-ranging examples of the behaviors of “property outlaws” - the trespasser, squatter, pirate, or file-sharer-to show how specific behaviors have induced legal innovation. They also delineate the similarities between the actions of property outlaws in the spheres of tangible and intellectual property. An important conclusion of the book is that a dynamic between the activities of “property outlaws” and legal innovation should be cultivated in order to maintain this avenue of legal reform.

Matt Festa

January 15, 2010 in Books, Property, Scholarship | Permalink | Comments (0) | TrackBack (0)

Thursday, January 14, 2010

Videos for 2009 Smart Growth Achievement Awards

From the folks at US EPA Smart Growth Program

The videos for the 2009 National Award for Smart Growth Achievement are
now available online!

These videos provide a direct look at why this year's winning
communities, from rural farmland to an urban downtown, make great places
to live, work and play. The videos include stunning shots of smart
growth in practice, as well as interviews with policy makers and local
citizens from each of the four award winners.

Congratulations again to the 2009 winners!

Overall Excellence in Smart Growth
Envision Lancaster County Comprehensive
Lancaster County Planning Commission, Lancaster, Pennsylvania

Policies and Regulations
The City of Charlotte
Charlotte Department of Transportation, Charlotte, North Carolina

Built Projects
Parkside of Old Town
Chicago Housing Authority, FitzGerald Associates Architects, and Holsten
Real Estate Development Corporation, Chicago, Illinois

Smart Growth & Green Building
Tempe Transportation Center
City of Tempe and Architekton + Otak, Tempe, Arizona

Jamie Baker Roskie

January 14, 2010 in Community Design, Local Government, Planning, Smart Growth | Permalink | Comments (0) | TrackBack (0)

Wednesday, January 13, 2010

UGA Conference on Human Rights and Climate Change

Here is a conference announcement from the Georgia Journal of International and Comparative Law and The Dean Rusk Center

“International Human Rights and Climate Change”

 February 12, 2010,

at the University of Georgia School of Law in Athens, Georgia.

 Thomas Pogge, of Yale University, will present the keynote address: “Poverty, Climate Change, and Overpopulation,” exploring the extent to which the struggles to deal with these three phenomena are in competition with one another and/or synergistic, using a human rights standard as a common metric of assessment.

The day long conference will take the form of a moderated round table discussion, with a lunchtime keynote address.

Topics: The United Nations’ Process of Linking Human Rights and Climate Change; Potential Human Rights Effects of Proposed Climate Change Regime; Litigation— including Citizen Suits, Judicial Review, and Access to Information; Human Rights and Environmental Regulation; Climate Change Refugees.

The conference is slated to offer 5.5 MCLE Credits, including 1 Trial Practice and 1 Professionalism Credit.  

 Participants include: Prof. Peter Appel, University of Georgia; Prof. Dan Bodansky, University of Georgia; Prof. John Bonine, University of Oregon; Prof. Rebecca Bratspies, City University of New York; Prof. Harlan Cohen, University of Georgia; Prof. John Knox, Wake Forest University; Prof. Svitlana Kravchenko, University of Oregon; Ms. Elizabeth O’Sullivan, US EPA Region 4; Prof. Naomi Roht-Arriaza, University of California, Hastings College of Law; and Prof. Dinah Shelton, George Washington University.

More information can be found at:  If you have any further questions, please contact: Blake McDaniel, Executive Conference Editor, at: or (229) 522-0790.

Jamie Baker Roskie 

January 13, 2010 in Conferences, Environmental Justice, Environmental Law | Permalink | Comments (1) | TrackBack (0)

Tuesday, January 12, 2010

Daily Sprawl Videos...

Like most areas of the country, the Central Alabama River Region has suffered from the residential and commercial real estate problems.

To chronicle specific examples, I've begun a series of informal "windshield" tours of problem projects in our region.  The first in the series is a lifestyle center in a suburb north of Montgomery. 

This city incentivized the development (just as the crisis was hitting in 2007), in part, by adding new infrastructure.  To pay for that infrastructure, news reports indicate that the city issued bonds--to be paid back through the increased sales tax revenue that the city would realize from the new stores.

The problem?  The vast majority of the lifestyle center never found tenants.  The big question facing the city will be how do they pay back the bonds if the lifestyle center remains this dormant.

Here's the video:

--Chad Emerson, Faulkner U.

January 12, 2010 | Permalink | Comments (0) | TrackBack (0)

Monday, January 11, 2010

Journal of Land, Resources, and Environmental Law

Bellemare on The Productivity Impacts of De Jure and De Facto Land Rights

Marc F. Bellemare (Duke--Pubic Policy & Economics) has posted The Productivity Impacts of De Jure and De Facto Land Rights.  The abstract:

There is an important literature on the causal relationship between the quality of institutions and macroeconomic performance. This paper studies this link at the micro level by looking at the productivity impacts of land rights. Whereas previous studies used proxies for soil quality and instruments to control for the endogeneity of land titles, the data used here include precise measures of soil quality, which allow controlling for both the heterogeneity between plots and the endogeneity of land titles. Results indicate that de jure rights (i.e., titles) have no impact on productivity and de facto rights have heterogeneous productivity impacts. Productivity is higher for plots on which landowners report having the right to plant trees, but lower for plots on which landowners report having the right to build a tomb and the right to lease out. Moreover, while the right to lease out increases both the likelihood that the landowner has the intention to seek a title for her plot and her willingness to pay to do so, whether her children will enjoy similar rights on the plot has the opposite effect.

Matt Festa

January 11, 2010 in Property Rights, Scholarship | Permalink | Comments (0) | TrackBack (0)

South Carolina Counties Face-Off Over Environmental Issues...

I ran across this recent story from the local Bluffton, South Carolina paper on one of my listservs.  The inter-county nature of the issues caught my attention--especially with the state legislature apparently getting involved:

In May, Herbkersman introduced a bill to strengthen Beaufort County’s legal hand in the face of development runoff from neighboring counties.

The bill, H. 4020, was co-sponsored by Reps. Richard Chalk, R-Hilton Head, Shannon Erickson, R-Beaufort, and Curtis Brantley, a Democrat who represents Jasper County and part of Beaufort County.

The bill was sent to the Senate, where it awaits action. The legislation would allow Beaufort County to sue Jasper, Colleton and Hampton counties if their traffic and storm water runoff affect the quality of life in Beaufort County.

One interesting things about the dynamic in this matter is that, as the article discusses, Beaufort County is a fairly well-off county while most of the others are among the economically-weakest in the state.

This reminds me somewhat of a paper that one of my students wrote last semester in Land Planning and Development that discussed the law, equity, and ethical issues facing counties and cities with large landfills and other waste dumps. Apparently, in pursuit of even small amounts of revenue, some impoverished jurisdictions are more willing to accept projects that could have longer-term negative effects.

I'm not saying that this story and that issue present a perfect analogy. But, in today's tough economic times, it will be interesting to see how much a jurisdiction is willing to bend long-term goals to generate short-term results.

--Chad Emerson, Faulkner, U.

January 11, 2010 | Permalink | Comments (0) | TrackBack (0)

Friday, January 8, 2010

"Rest Stops R.I.P."

From the very eclectic website "Good" comes a story about the death of the American rest stop.  My husband found this story after we passed a closed rest stop on I-95 near Richmond, Virginia over the holidays. This is another Virginia budget-saver, along with banning cul de sacs.  Virginia, however, isn't the only state closing its rest stops.  If, like me, you're a sometime solo female traveler who enjoys a safe, warm place for a pit stop, this is not a happy trend.  Also, if you're a fan of the kitschy mid-century modern look of many of the rests stops, or a preservation advocate in general, the loss of these rest stops is worrisome.  Of course, we can always stop at Starbucks or McDonalds to use the loo and top up on caffinated beverages.  But, for me, rest stops are an integral part of the interstate highway system, and I mourn their loss a little.

Jamie Baker Roskie

Follow up - Another article, this time from The New York Times, about a political kerfuffle in Arizona over closed rest stops.

January 8, 2010 in Architecture, Historic Preservation, Transportation | Permalink | Comments (1) | TrackBack (0)

George Will on Atlantic Yards & Eminent Domain

George Will wrote a column for the Washington Post titled "Avaricious developers and governments twist the meaning of 'blight.'"  Will discusses the Atlantic Yards project (which we have blogged about) in light of the more general controversy over economic development takings.  He starts with a mention of the 1776 Battle of Brooklyn and then gets to the contemporary issue:

The fight involves an especially egregious example of today's eminent domain racket. The issue is a form of government theft that the Supreme Court encouraged with its worst decision of the past decade -- one that probably will be radically revised in this one.

The Atlantic Yards site, where 10 subway lines and one railway line converge, is the center of the bustling Prospect Heights neighborhood of mostly small businesses and middle-class residences. Its energy and gentrification are reasons why 22 acres of this area -- the World Trade Center site is only 16 acres -- are coveted by Bruce Ratner, a politically connected developer collaborating with the avaricious city and state governments.

To seize the acres for Ratner's use, government must claim that the area -- which is desirable because it is vibrant -- is "blighted." The cognitive dissonance would embarrass Ratner and his collaborating politicians, had their cupidity not extinguished their sense of the absurd.

It's interesting that Will credits Kelo as the "worst decision" of the millenium so far, yet thinks that it will be "radically revised."  I don't think that it will, but we'll see.  But also interesting is his promotion of the Atlantic Yards case (through his Washington Post platform) as a national issue.  The NY Courts have basically given it a pass under both Kelo and state law.  We will have to see if it gets any traction as a public-use case.  But he is correct that the controversy over "blight" designations, and the perception that the blight loophole eviscerates may purported post-Kelo "reforms," will probably increase. 

Matt Festa

January 8, 2010 in Caselaw, Eminent Domain, Property Rights, Redevelopment, Takings | Permalink | Comments (0) | TrackBack (0)