Assessment in Special Education: Philippines Essay

The Status of Assessment of Children with Special Needs in the Philippines I. Assessment Processess Involved in Assessment a. tests b. measurement c. evaluation II. Assessment of Children with Disabilities in America History of Assessment Purposes of Assessment in Education a. regular education b. special education Process of Educational Assessment III. Assessment of Children with Disabilities in the Philippines Policies and Guidelines of Special Education Process of Educational Assessment Trends and Issues in Assessment. The Status of Assessment of Children with Special Needs in the Philippines Assessment is an indispensable process in the educational system, especially in educating children with disabilities. It is a process of obtaining information for decisions about students, curriculum and programs, decisions and on educational the of policies. of Moreover, goals this involves psychological assessment of children with relevance to making appropriateness instructional at and objectives, assigning management counselling. This process involves the use of tests, measurement, and evaluation. The instruments for the systematic procedure are called tests. These are used for observing and describing one or more characteristic of children using a numerical scale or classification scheme. Paper-and-pencil tests, teacher-made tests, standardized tests are among the other instruments used. The scores earned in correctly answered items provide the teacher the quantitative and objective information as to how much a student has learned. The procedure for assigning number or score to a specified attribute or characteristics is called measurement. Through this, the order of people in the group being measured is maintained. This measurement provides the value judgement of the student’s score or performance. This process of evaluation serves as the basis for decisions about the course of action to be followed. This gives an objective picture of the status of the child which could be done through either formative or summative evaluation. Formative evaluative involves a progressive monitoring on the quality of learning a child is gaining. Whereas summative teaching strategies, appropriate classification, placement opportunities and guidance and evaluation is done after a period of time which determines the quality or worth of materials a student has gained. Assessment encompasses testing, measurement, and evaluation; it is broader than all the process. However, measurement, in some cases, may not be utilized due to lack of tools. This may lead to subjectivity. Thus, it would require a deep knowledge of the qualitative and quantitative attributes to arrive at a sound assessment. Assessment in special education dated way back the Medieval Times when people with non-purposive behaviour are considered mentally-ill and were placed in asylum. Maria Montessori, an Italian doctor, once worked with people with this distress. She clarified that many of the cases in the asylum do not possess medical problems but pedagogical problems. Thus, they will benefit from instructional intervention. This was followed by the works of Itard and Seguine who designed a training program to improve visual, auditory and tactile senses. Their objective was to refine the senses. However, their study did not go on but was continued by Samuel Howe and Edward Seguine who then started an institution for children with mental retardation. In 1838, Esquirol wrote a book on mental deficiency who described the disability in a varying continuum. He explained further that the use of language is a dependable criterion to determine the individual’s level of intellect. John Locke illustrated further the difference between an insane an idiot. The insane talks too much and uses words incoherently while the idiot, on the other hand, when he talks has limited language. But they came to a realization that there is a need for a tool to identify the problems of children who are not learning at the same rate as their peers. During the late 1800s, Alfred Binnet proposed to French Ministry of Public Instruction that there is a need for a further study of children who  are failing in school and must not be dismissed. So, the need for special instruction was identified. He, together with Theodore Simon developed a tool with 30 items with ascending order of difficulty during the early 1900s. It has a wide variety of function with emphasis on judgement, comprehension, and reasoning which are the components of intelligence. This was called Simon-Binnet Test. However, there are still glitches on the use of this tool because most items are verbal and scoring procedure is not available. The second version of the tool added more items and removed unsatisfactory items. Accordingly, test items are grouped according to age level. Scoring was also established by interpreting it through mental level. The third version was done in 1911. There were some minor revision and repositioning of items according to level of difficulty. The tool was brought to America and was studied further in Standford University by Lewis Therman. It was normed and standardized resulting to its name these days as StanfordBinnet Intelligence Test. However between1920-1950, the prominent tests used to assess children with disabilities are projective tests and personality tests. Unfortunately, it did not gain much fame because of its lack of objectivity. After a century, there was an increase in the use of standardized test on perception. This was influenced by Samuel Kirk’s definition of exceptional children. Intelligence tests during that time focused on perceptual-motor senses. Usually, these tests are accompanied by programs. However, it has not improved the performance of children with difficulty. In the 1970s, Behavioral Model was the trend. It emphasized on observation procedures. In this model, evaluation and value judgement became their basis for instruction. However, children with disabilities do not progress despite the use of standardized tests in assessing; thus, it must not be the sole tool to be used in assessment. There must be a balance between the use of formal and informal models. Accordingly, assessment tools must correspond to the assessment objective. Madeline Will, between the mid-1980 – early 1990s, brought up the idea that children in the regular classroom must not remain difficult but must receive a special instruction. She underscored that assessment is a shared responsibility of the general education teacher and the special education teacher. It must start with pre-referral assessment and pre-referral intervention. This is the core idea of today’s Regular Education Incentive (REI) in America. In the new millennium, functional-behavioural assessment became the support of REI. Among other purposes, this evaluates student’s behaviour within environmental context that can contribute to an intervention plan. A balance between formal and informal assessment procedure was observed. Generally, assessment helps teachers make decisions about the curriculum and make educational programs for the child. But assessment in special education is more focused on individual student. It aims to screen and identify the seriousness of the problem; identify and determine the current level of academic performance and educational need of the child in terms of academic area and strengths and weaknesses; determine eligibility in special programs; make decisions about placement in different programs taking into consideration the least restrictive environment (LRE);evaluate teaching program and strategies designed for the child; develop an individualized educational plan (IEP); and monitor and document student’s progress pertinent to the target goals. Assessment in America is guided by the principles present in PL 94-142 Education for all Handicapped. According to this public law, all children must be given free appropriate public education (FAPE) or the zero-reject principle; it stresses the avoidance of discrimination in the assessment procedure used; an IEP must be carefully planned containing important details; an educational setting must be least restrictive for the child to move; each child deserves fairness and accountability of professionals and parents who makes decisions on his assessment; parents would have to know the honest objective of the test. The process of educational assessment in America follows three stages: pre-referral, referral and IEP development and educational placement. Due to Madeline Will’s initiative, pre-referral stage has been a MUST in the assessment process in America. This process is inexpensive. This is divided into two sub-stages, general screening and problem identification. During the first sub-stage, the teacher initiates the data gathering on the learning problems the child encounters which makes the child significantly different compared to his peers. This entails the use of short tests (individual or group) which is broadly focused on all areas of development or on a specific subject area. From the data, the teacher will identify the child’s difficulty and determine what she will address. Here comes the pre-referral intervention plan of the teacher. Progress must be assessed after a certain period of time to determine whether the chid needs to continue the plan with some additions or refer the child to a professional. During the referral stage, a comprehensive assessment is planned through referral to the special education team (SPED team). The team will evaluate the intervention plan used and will make some revision to make assessment more formative. However, if a child do not progress in this stage, he/she will be then referred to the multidisciplinary/ transdisciplinary team who will conduct further study and prepare comprehensive and integrated assessment report reflecting important findings. The report will be translated in an IEP. The IEP serves as the framework in which the child will benefit. A special education teacher must implement this. Progress monitoring and evaluation must be done to give feedback to students and teachers. This must be carefully evaluated at the end of the year so that revisions will be made. Truly, the assessment procedure in America gave an impact to the Philippines’ special education system. In fact, the Philippine constitution and Magna Carta for Disabled Person of 1992 guided the formulation of policies and guidelines in special education in the Philippines. Article XIV, Section 1 of the 1987 Philippine Constitution states, â€Å"The state shall promote the right of all citizens to quality education at all levels and shall take appropriate steps to make such education accessible to all. † Magna Carta likewise provides that the State shall ensure that disabled person are provided with adequate access to quality education and ample opportunities to develop their skills; take appropriate steps to make such education accessible to all disabled person; and take into consideration the special requirements of disabled persons in the formulation of education policies and programs. As stated in Article 3: Identification, Screening, Assessment and Evaluation of Children, identification and assessment of every child shall be conducted as early as possible and shall be conducted by the school and the community utilizing appropriate assessment instruments. The team shall be composed of persons with working knowledge and understanding of special children such as parents, guardians, neighbours, friends, teachers, guidance counsellors, health workers, social workers and others. Aspects to be covered in the identification, screening, assessment and education of children shall cover the following aspects: physical (height, weight, physical deformities, gross and fine motor coordination, hearing, visual acuity, oral hygiene and dental development), psycho-social (family history, personality, bahavior) and educational (learning disabilities, language and speech, medical). As mentioned, appropriate instruments shall be developed or adopted in order to identify handicapping condition as  early as possible; it must be on-going; and the synthesis of identification shall be the basis for the appropriate educational placement for the child with special needs. In a paper presented to the Department of Social Welfare and Development in 2010, it highlighted three (3) phases of assessment in the Philippines: sensing the special need, assessment, intervention. In the first phase, the people involved are the parents, family, siblings, caregiver, teachers, family doctor, the pediatrician and the child. It takes into consideration the impressions, comparisons, reports and complaints, initial assessment and school performance of the child. In the second phase, the diagnosis of the difficulty is given by a medical specialist. Through which, special needs of the child are identified. The child will be then referred to a multidisciplinary team where they consolidate their diagnosis. The multidisciplinary team may include developmental paediatrician, occupational therapist, speech therapist, physical therapist, reading specialist, educational therapist and music therapist. Intervention of the difficulty start with the formulation of the Individualized Intervention Program (IIP) which is carefully planned by the teacher from the diagnosis under the guidance of case consultants, area specialists, school administrator, psychologist and the parents. The third phase is a continuous process of implementing, monitoring, and re-formulating IIP until such time when the child is able to manage himself and achieve the objectives formulated. However, the country is still at its process in polishing these ideals to conform with the emerging needs of children with special needs. Maria Melisa Rossana C. Sta. Ana, in her article written in 2006 entitled â€Å"Education of Children with Multiple Disabilities in the Philippines,† highlighted that though the school curriculum is established, there are still major concerns for the preparation of educational programs and support for children with multiple disability like the lack of available culture-based assessment tools in evaluating students with multiple disabilities. On another note, she points out that many Filipino parents of children with disability cannot see the importance of sending their child to school due to poverty and negative stereotypes. This gave light to a number of children with disabilities in the Philippines who do not receive proper education support that they need. On another light, there are private schools and foundations catering to children with special needs. One of which is Cupertino Center for Special Education. Their approach to assessment is done through a clinical team approach, special education teachers, occupation and speech therapists and psychologists. Another school which accepts children with special needs is O. B. Montessori Center Inc. (OBMCI). Children with special needs are admitted to OBMCI thru its guidance program where children are identified accordingly (Sta, Ana, 2010). The school gives importance on the professional diagnostic assessment which was made prior to enrolment of assessment to identify the child’s sensory potential, identify the individual needs and development of the individual educational program. This will help determine the child’s strength and limitation which will eventually influence his/her educational program. Filipino parents have very little choice with regard to the education of their special children in the Philippines, especially families in the marginal sector. However, through proper implementation of policies and endeavours in the field of special education, the special education system in the country will progress and each child with disability will receive appropriate education. References: Sta. Ana, M. (2010). Education of children with multiple disabilities in the Philippines. Retrieved February 8,2013 from http://staana. blogspot. com/multipledisabilities Inciong, T. (2005). The development of welfare and education for children with mental retardation towards inclusion: The Philippine experience. Paper Presentation. Retrieved February 8, 2013 from www. deped. gov. ph/regioniva/paper/inciongt Learn more about special education. (2010). PowerPoint Presentation. Retrieved February 8, 2013 from www. slideshare. net/sped/learmoreaboutspedsept19-100920211910phpqapp1 Madrid, M. (2012). A PowerPoint Presentation: Policies and guidelines of special education in the Philippines. Retrieved February 8, 2013 from www. slideshare. net/m_apostol_madrid_s/policies-120427023552phpapp1.

Freedom Of Speech A Theoretic Approach - Free Essay Example

Sample details Pages: 17 Words: 5059 Downloads: 10 Date added: 2019/05/13 Category Law Essay Level High school Tags: Freedom of Speech Essay Did you like this example? Freedom of Speech: A Theoretic Approach INTRODUCTION The Constitution â€Å"demands that content-based restrictions on speech be presumed invalid and that the Government bear the burden of showing their constitutionality.†[footnoteRef:1] That is to say, anything recognizable as a conception of freedom of expression must require that government, at least in its capacity as regulator, maintain a position of neutrality regarding messages. However, there are content-based restrictions on speech that have been allowed but only in a few instances such as incitement, obscenity, defamation, speech important to establish criminal conduct, fighting words, child pornography, fraud, true threats, and speech creating a serious and imminent threat the government has the power to prevent. As hate speech and rumors proliferate social media, many countries have attempted to implement â€Å"fake news† laws. Don’t waste time! Our writers will create an original "Freedom Of Speech: A Theoretic Approach" essay for you Create order Malaysia, Sri Lanka, and Myanmar have all seen an increase in â€Å"fake news† and have attempted to criminalize anyone who delivers â€Å"fake news† including Brazil, Germany, France, and Kenya. Moreover, according to the decision in U.S. v. Alvarez, the United States has attempted and failed to criminalize â€Å"fake news.† [1: Ashcroft v. American Civil Liberties Union, 542 U.S. 656, 660, 124 S.Ct. 2783, 159 L.Ed.2d 690] Malaysia passed a law that would punish citizens on social media or those who are working at a digital publication for spreading fake news with a $123,000 dollar fine along with a possible prison sentence of up to six years. In France, the parliament has passed a law that targets fake news. The new law will impose a quick-response judicial review of potentially â€Å"manipulative† information shared during electoral periods. The new law will allow election candidates to sue for the removal of contested news reports during election periods, as well as forcing platforms such as Facebook and Twitter to disclose the source of funding for sponsored content.[footnoteRef:2] Germany introduced a plan that fined social media platforms if they did not remove posts that included hate speech. However, in the Philippines, the regulators stated that banning fake news in their country would be outright unconstitutional. The movement to ban fakes news is trending and nations like the United States are trying to come up with a solution that does not abridge the First Amendment. One way to curb fake news without abridging the First Amendment is allowing or encouraging companies or the market to handle it. For instance, YouTube is making a $25 million dollar investment to â€Å"improve its news features, joining Facebook, Apple, and parent company Google in campaigns to curb fake news†¦Ã¢â‚¬ [footnoteRef:3] Additionally, companies like RedPen are reducing the problem by using a combination of innovative technologies, including AI, natural language processing and sentiment analysis, to for multiple angles of a trending story in a single user interface. This information is great for companies; but what can the government do? Unlike private companies, the government is in a tough predicament due to the constraints of the First Amendment. The Government cannot censor speech while private companies can. To fully understand the concept of fake news, we have to look further into the past pre-trump era. [2: YOUNG, ZACHARY French Parliament passes law against ‘fake news’ 7/4/18, 12:44 PM CET Updated 7/4/18, 1:15 PM CET] [3: Olenski, Steve. â€Å"5 Ways Brands Can Combat Fake News† https://www.forbes.com/sites/steveolenski/2018/07/12/5-ways-brands-can-combat-fake-news/#5e6f771448f6 ] Fake news is not a new concept and has been around for quite some time. Even in 1938, a radio broadcast adaptation of H. G.Well’s drama The War of the Worlds frightened an estimated one million residents.[footnoteRef:4] The residents believed what they heard on the radio station was, in fact, happening since the radio was the main source of media in the 1930s. Currently, now that online platforms, particularly social media, are becoming the main sources of news for a growing number of individuals, misinformation seems to have found a new channel.[footnoteRef:5] Fake news is the intentional and verifiably false information that could mislead readers.[footnoteRef:6] Social media has changed news distribution and has challenged traditional beliefs of how news should look. Quick snippets of information from innumerable sources delivered every second of the day would cause a lot of confusion. [4: Edson C. Tandoc Jr., Zheng Wei Lim Richard Ling 2018] [5: Tandoc 2018] [6: Id.] The news is supposed to be based on truth, but who decides what the truth is? Statements are true if they correspond to the facts in the world. Truth is not absolute but maybe its relative to the culture, nation, ethnic backgrounds, and schools of thought. For example, science is a way to make the truth more absolute. There are methodologies, case studies, and empirical research that make of the paradigm of science. However, even with the scientific methods, we still find disagreement. The truth tends to be relative to a particular frame or reference. In order to determine what news is considered fake, we must look at what is the nature of â€Å"real news.† Traditionally, the news was expressed by journalists who adheres to a code of professionalism. A journalist must be objective and accurate. Above all, provide citizens with accurate and truthful information so they can be free and self-governing. With that responsibility, there comes liability. A journalist must stray away from providing misinformation and never provide disinformation. While misinformation refers to â€Å"the inadvertent sharing of false misinformation,† disinformation refers to â€Å"the deliberate creation and sharing of information known to be false.†[footnoteRef:7] Traditional news forums have printed misinformation plenty of times. Trump credits himself as being the creator of the term but the term has been around for a while. It was used heavily in campaigns during the 90s. [7: Wardle 2017 para. 1.] Since 2016 the Supreme Court has made references to how ambiguous and vague the phrase is. For instance, in Cohen v. California, the statement â€Å"fuck-the-draft† tapped directly into the vagueness issues and definitional difficulties afflicting the statutory phrase â€Å"offensive conduct† and whether, in turn, â€Å"fuck† fell within that definition.[footnoteRef:8] At the most fundamental level, fake news is a speech based phenomenon[footnoteRef:9]. It typically features words and may involve images. The First Amendment, thus, is relevant to the extent that restricting fake news necessitates government action targeting its producers and disseminators. The possibility of such government regulation is much more than just a hypothetical. California attempted to pass a bill that made it illegal to knowingly and willingly make, publish, or circulate on an Internet Website, or cause to be made, published, or circulated in any writing posted on a website, a false or deceptive statement designed to influence the vote on either a voter or candidate for office.[footnoteRef:10] Eventually, the bill was struck down. The major barrier, of course, is that political speech lies within the heart of the First Amendment. The Supreme Court and lawmakers must first understand what â€Å"fake news† actually means before any useful law can be passed. First, statements of opinion are not considered fake news. One possibility is that fake news consists of content that conveys the impression of being a real news article in print or, more appropriately, on the Internet.[footnoteRef:11] [8: Cohen v. California, 403 U.S. 15, 25 (1971).] [9: Calvert, Clay. First Amendment Law review. Vol 16. Pg. 156] [10: Id. ] [11: Id. at 161] For the purposes of this paper, the term fake news will be an intentional sharing of false information that gives the impression of being a real news article in print or on the Internet. This paper will determine whether fake news should be protected by the First Amendment, explore recent court decisions including Alvarez, apply Free Speech Theory and determine which theory or theories are best equipped to address the implications of the fake news, particularly, the news that was spread before the 2016 Presidential election. ANALYSIS A. United States v. Alvarez In Alvarez, Justice Kennedy stated Content-based restrictions on speech are subject to strict scrutiny and are almost always invalid, except in rare and extreme circumstances. While low categories of speech, such as defamation and true threats, present a serious and imminent threat, false statements alone do not present such a threat. Congress drafted the Stolen Valor Act too broadly, attempting to limit speech that could cause no harm.[footnoteRef:12] This principle regarding causation of harm, drawn from Justice Anthony Kennedy’s plurality opinion in United States v.Alvarez, becomes most relevant if the government attempts to regulate fake news.[footnoteRef:13] The Alvarez rule that proof of causation of harm must be demonstrated to uphold a content-based restriction on speech under strict scrutiny springs from the Court’s 2011 decision in the violent video game case of Brown v. Entertainment Merchants Association. The majority concluded that punishment for false stat ements are improper and unconstitutional. Hence, Justice Breyer agreed with the overall decision but not in the analysis. Justice Breyer stated that instead of applying strict scrutiny, intermediate scrutiny is warranted. Even with applying intermediate scrutiny, punishment for false statements, the Stolen Valor Act, in this instance would be unconstitutional because it violates intermediate scrutiny and it applies to situations that are unlikely to cause harm.[footnoteRef:14] However, the dissent essentially stated that the Stolen Valor Act could not have been drafted any narrower, while still preventing the substantial harm caused by false statements concerning military decoration.[footnoteRef:15] [12: United States v. Alvarez, 567 U.S. 709 (2012).] [13: Id. at 725.] [14: Id.] [15: Id.] The best argument made in the opinion is the concurrence by Justice Breyer and Kagan. Intermediate scrutiny or the proportionality analysis should be used because the statute works First Amendment harm, while the Government can achieve its legitimate objectives in less restrictive ways. This approach is necessary if the First Amendment is to offer proper protection in the many instances in which a â€Å"statute adversely affects constitutionally protected interests but warrants neither near-automatic condemnation (as â€Å"strict scrutiny† implies) nor near-automatic approval (as is implicit in â€Å"rational basis† review).†[footnoteRef:16] However, the dissent points out that â€Å"there are broad areas in which any attempt by the state to penalize purportedly false speech would present a grave and unacceptable danger of suppressing truthful speech.†[footnoteRef:17] In fact, the court has not extended First Amendment protection on several occasions. The dissent points out several examples such as defamation of a public official. The dissent further leans on New York v. Sullivan stating â€Å"[e]ven a false statement may be deemed to make a valuable contribution to public debate, since it brings about ‘the clearer perception and livelier impression of truth, produced by its collision with error.†[footnoteRef:18] The dissent believes the plurality fears that we will see laws making it a crime to lie about civilian awards such as college degrees or certificates of achievement in the arts and sports.[footnoteRef:19] The dissent believes that the Stolen Valor Act is a narrowly tailored law to address an important issue. Congress was entitled to conclude that falsely claiming to have won the Medal of Honor is qualitatively different from even the most prestigious civilian awards and that the misappropriation of that honor warrants crimina l sanction.[footnoteRef:20] Although the dissent makes a good argument, the plurality made the best argument that I align myself with. False statements should not be regulated by the government unless it essential the elements of a crime such as Fraud. [16: U.S. v. Alvarez at 731] [17: Id. at 751] [18: J. Mill, On Liberty at 15] [19: U.S. v. Alvarez at 753] [20: Id. at 754 ] The plurality and concurrence fear that the government will misuse and overreach if the government is allowed to regulate. Because the statute, as drafted, applies even in a family, social, or other private contexts where lies are unlikely to cause harm, it creates too significant a burden on protected speech.[footnoteRef:21] The government could achieve its goals in a less burdensome way. The best solution to restrictions of speech, in this case, is intermediate scrutiny. [21: Id.] B. REGULATION Speech regulation is adopting policies and taking actions designed to reduce the prevalence of one or more classes of speech; therefore, it is an effort to reduce the amount of particular speech. Even mature democracies struggle with the issue of fake news. On January 1, 2018, Germany announced that it would begin to enforce a law, known as NetzDG, requiring social media sites to remove hate speech and fake news within 24 hours or face fines of up to 50 million Euros.[footnoteRef:22] The European Commission’s High Level Group on fake news and online disinformation take a 5 pillar approach to the fake news concept. In March 2018, the High Level Group issued a report concluding that although disinformation may not necessarily be illegal, it nevertheless is harmful to democratic values. This approach reminds me of the Harm Principle and although apparently avoiding â€Å"any form of censorship, either public or private,† it advocates greater self-regulation in the short te rm, with a long-range goal of developing a Code of Practices to encourage transparency, media literacy, diversity, the development of tools to â€Å"tackle† disinformation, and further research to monitor and assess the sources and impact of fake news.[footnoteRef:23] On the other hand, also in March, the Dutch Parliament voted to retract EUvsDisinfo.eu, a European Union website created by the East Stratcom Task Force in 2015 to report disinformation and fake news allegedly spread by Russian actors. Its Dutch opponents characterize it as a state publication that â€Å"passes judgments whether a publication in the free media contains the correct views or not. If your publication ends up in its database, you’re officially labeled by the EU as a publisher or disinformation and fake news.†[footnoteRef:24] [22: European Commission, â€Å"A multi-dimensional approach to disinformation.† ] [23: Id.] [24: Id. at 18.] These examples illustrate how problematic it can be when governmental entities become arbiters of what is true and what is fake. As the Dutch critics argued, governments should be loath to interfere in freedom of the press because â€Å"it makes it impossible for the truth to emerge in the public debate.†[footnoteRef:25] The marketplace of ideas must have been an underlying reason in the Dutch critic’s argument. It was definitely at the core of the pivotal 1964 U.S. Supreme Court decision, New York Times v. Sullivan. [25: Id. at 22] The Sullivan case arose during the civil rights movement, involving a Montgomery, Alabama, public safety commissioner named L.B. Sullivan, who sued the New York Times after it published a fundraising advertorial that described law enforcement actions designed to discourage protests by activists such as Martin Luther King Jr. and his followers. Sullivan claimed that the ad, which made several factually inaccurate allegations about the Montgomery police, had defamed him personally, even though he was not identified by name or title. In other words, Sullivan claimed the publication was fake news. He sought and won $500,000 in damages, without being required under Alabama law to prove that his reputation was actually harmed. But in a decision by Justice William Brennan, the high court reversed, concluding that under the First and Fourteenth Amendments, public officials like Sullivan could prevail in a libel suit only if they were also able to show not only falsity but actual malice on the part of the publisher. In other words, a publisher had knowledge that the statement was false, or proof that the publisher acted with reckless disregard for the truth. A showing of hatred or ill will, known as common law malice, is not sufficient to meet that test. According to Justice Brennan, because some factual errors are inevitable even in the most careful news reporting, this protection is essential to avoid media self-censorship, to promote vigorous reporting on government and public officials, and to preserve our â€Å"profound national commitment to the principle that debate on public issues should be uninhibited, robust and wide-open.† In subsequent years, the First Amendment protection expanded to include lawsuits by public figures as well as government officials. Alleging falsity was not enough. No doubt this situation is what prompted Donald Trump, first as a candidate and then as president, to float the idea that the law should be changed. Regulation should increase due to the swelling fabrication of news that is highly contentious. When there is social tension, especially if there are serious political, religious, racial or cultural differences, then people will be more vulnerable to fabricated news.[footnoteRef:26] The items can also be shared on social media and thus further gain legitimacy since the individual is receiving them from people they trust.[footnoteRef:27] This is a problem because most young and middle age, and a growing number of past generations rely heavily on social media for their news source.[footnoteRef:28] [26: Kirtley, Jane â€Å"Getting to the Truth: Fake News, Libel Laws, and â€Å"Enemies of the American People† American Bar Association] [27: Id.] [28: Head, Alison. â€Å"How Students Engage With News.† https://www.projectinfolit.org/news_study.html] C. Freedom of Expression and Free Speech Theory A marketplace of ideas approach provides the community with the opportunity to hear all ideas whether good or bad. The marketplace of ideas is imperfect but essential to facilitate the search for truth. This approach, because of the immense volume of ideas, allows for good ideas to emerge. The theory is that truth beats error in the competition of ideas. This concept and process is beneficial in discovering the best truth because the individual is exposed to a variety of paradigms and ideologies which help build a better, more tolerant, community. This approach does not silence the expression of opinion or ideas whether good or bad. Furthermore, under the Justice Holmes approach to the marketplace of ideas, the approach does not consider whether government interference is desired in order to prevent harm. It does state, however, that government interference should be minimal so that the truth would not be tainted in the marketplace. Notwithstanding where the government can actively e ngage in speech to further governmental ideas, you can infer that this approach is at the foundation of the Alvarez opinion. Under this approach, false statements are inevitable if there is to be an open and vigorous expression of views in public and private conversation, an expression the First Amendment seeks to guarantee.[footnoteRef:29] The marketplace of ideas is a great theory, however, this theory is based on an important assumption. [29: United States v. Alvarez, 567 U.S. 709, 718 (2012)] If there is fake news, there must be truth out there somewhere. If we accept that there is fake news then the assumption is that everyone is in search for the truth or best truth. This theme has been endorsed by famous writers of many eras. John Milton stated â€Å"Let Truth and Falsehood grapple; who ever knew Truth put to the worse, in a free and open encounter.†[footnoteRef:30] And Justice Oliver Wendell Holmes, in his famous dissenting opinion stated â€Å"[W]hen men have realized that time has upset many fighting faiths, they may come to believe even more than they believe the very foundations of their own conduct that the ultimate good desired is better reached by free trade in ideas – that the best test of truth is the power of the thought to get itself accepted in the competition of the market.†[footnoteRef:31] Since 2016, it seems clear that marketplace competition forces, standing alone, will not drive fake news from the field of expression.[footnoteRef :32] For some people, the truth may be outweighed or overpowered when grappling, more like passively accepting, fake news. [30: Milton 1644] [31: Abrams v. United States 1919, 630] [32: Calvert, Clay. First Amendment Law review. Vol 16.] The marketplace of ideas approach focuses on speech maximization which increases the amount of speech in particular classes through forums, media, speech tokens and types. This specific method is offered to combat fake news or false information. However, in a marketplace full of bad ideas, flooding the market with good ones does not seem to solve the problem. The marketplace could be chaotically flooded with ideas making it hard to discern and extract the good ideas from the bad. This will further exacerbate the problem and lead to misinformation being distributed making it difficult for individuals to extract the best truth. Additionally, the marketplace of ideas will become the marketplace of opinions or fake news. For instance, social media outlets such as Facebook makes it extremely difficult for citizens to discern the truth. I know the marketplace of ideas is not the marketplace of facts, but I believe the pioneers of the theory thought it should be a place of competing ideological convictions and fidelity to the true idea. Currently, there is a shift towards a preference for online news resources. In a study conducted by Alison Head found that the high school and college population is no longer on Facebook. The study indicated that high school and college students get their news from real-life discussions with peers (93%) and not just from social media (89%).[footnoteRef:33] Professors were considered a significant news source as well (70%), but librarians were not as effective as a source of news (7%).[footnoteRef:34] The most common source of news is memes, instagram, and snapchat. Head states that the tech giant Facebook is dying. Seeing this change, you would think that citizens would be more aware of fake news. People who understand fake news as a reality should rightfully be more skeptical about the veracity of what they read rather than accepting it blindly or at face value.[footnoteRef:35] If a consumer knows that fake news exists, it should encourage the consumer to be a more attentive, active, and always challenging the status quo. Some would even look at fake news circulating the market as a benefit because unfortunately, fake news will always circulate the marketplace, we just have to educate ourselves with discernment. [33: Head, Alison. â€Å"How Students Engage With News.† https://www.projectinfolit.org/news_study.html ] [34: Id.] [ 35: Calvert, Clay. First Amendment Law review. Vol 16.] Today, no matter whether the information is true, marketing is most important. Even when the idea itself is fake, as long as the party distributing the false information claims that the opposing idea is â€Å"fake news† they have an upper hand due to market trends. For example, a republican claiming that a democrat is conveying fake news. Maybe we should focus on real news and, specifically, ways to make it more appealing to the massive number of Americans who bypass reading traditional daily newspapers and watching local television newscasts produced by reputable organizations.[footnoteRef:36] Therefore, the marketplace of ideas approach alone may not be the best solution to solving fake news. There is no doubt that tackling fake news is a muti-faceted approach. We need news literacy. We need to educate ourselves on how to vet disreputable reputable sources, and how to properly research. However, here, we will focus on the theory or theories that will help weed out fake news without abridging the First Amendment. [36: Benton, Joshua Get Serious About Getting Rid of Fake News, NIEMAN REPS., Fall 2016, at 38, 39.] The regulation of fake news might even be contradictory to the marketplace principle. However, the Harm principle might play a major role in regulating fake news. Under the Harm principle fake news would be okay so long as it does not cause anyone harm. Moreover, the only purpose that power can be exercised over any member of the civilized community, against his will, is to prevent harm to others. This principle is grounded in Utilitarianism. Under the Harm Principle, individuals are free to drink, smoke, or use drugs even though this harm is self-inflicted. However, the moment that self-infliction begins to hurt others, such as drinking and driving, it must be stopped. More specifically, the only time government can interfere or suppress an individual’s complete liberty is to prevent harm to others. For example, the pizzagate scandal. a man carrying an assault rifle walked into a pizza restaurant in Washington, DC. He was intent on investigating on his own whether the restaurant, Comet Ping Pong, was the headquarters of an underground child sex ring allegedly run by the presidential candidate Hillary Clinton and her former campaign manager, John Podesta.[footnoteRef:37] The man was motivated by stories disseminated through right wing social media outlets. He entered the restaurant and fired several shots in the ceiling. This would be fake news that has caused harm. Fortunately, no one was injured by the gunshot but there was a definite probability of it happening. [37: Lopez, German. â€Å"Pizzagate, the fake news conspiracy theory that led a gunman to DC’s Comet Ping Pong, explained† Dec. 2016.] John Stuart Mill’s harm principle suggests that â€Å"the only purpose for which power can be rightfully exercised over any member of a civilized community, against his will, is to prevent harm to others.†[footnoteRef:38] As so eloquently summarized by Professor Frederick Schauer, this means â€Å"that society may proceed only against genuine harms and not against other forms of individual or social discomfort.†[footnoteRef:39] What then, in reference to Millian theology, is the â€Å"harm to others†[footnoteRef:40] caused by fake news? [38: Mill, John S. On Liberty 80 (David Bromwich George Kateb eds., Yale Univ. Press 2003).] [39: Schauer, Frederick On the Relation Between Chapters One and Two of John Stuart Mill’s On Liberty, 39 CAP. U. L. REV. 571, 574 (2011).] [40: Mill, On Liberty, note 33 pg. 80] Identifying the harm or harms that we fear fake news produces is a condition precedent or any effective corrective action, be it through legal or private channels. One important step that lawmakers seeking to regulate any speech-based phenomenon must take is to â€Å"identify, with precision and specificity, the actual problem that the speech caught in the legislative crosshairs allegedly causes.†[footnoteRef:41] In other words, when it comes to fake news, one must â€Å"pinpoint the precise harm, not just some generalized, indistinct worry.†[footnoteRef:42] Mill’s underlying argument that freedom of speech allows poor ideas to be discussed, criticized, and defeated.[footnoteRef:43] But if that were true, why are having such a difficult time discerning the truth from fake news? In short, news is no longer found on traditional forums and access to resources has increased dramatically. [41: Calvert, Clay. First Amendment Law review. Vol 16.] [42: Id. at 256] [43: M ills, J. On Liberty, Chapter 4] The Marketplace of ideas approach is not so much concerned with harm, as it understands that not everyone will be in the majority. Which is why merging this idea with the Harm Principle seems proper. The marketplace of ideas is concerned with the truth. Truth causing harm is okay as long as the truth benefits the majority. Likewise, under the Harm Principle, if understood liberally, – i.e., taking into consideration that the principle of utility is its foundation, – harm is okay so long as it brings the greatest amount of happiness to the greatest number of people.[footnoteRef:44] It is the combination of the Marketplace approach and Mill’s Harm principle that regulation is likely to succeed. Combining these concepts almost looks a bit like an intermediate scrutiny approach the concurrence discussed in Alvarez. However, there is another method that may help in regulating fake news and it concerns private entities such Facebook. [44: Nahra, Cinara. (2014). The har m principle and the greatest happiness principle: the missing link. Kriterion: Revista de Filosofia, 55(129), 99-110.] Most people today are acquiring their news from a source not deemed a forum or media corporation or outlet. Because of this, fake news has increased exponentially. Companies like FB are in a peculiar situation. Although they are indeed private companies; they are so massive that most people use its platform to engage in speech-related activities. One idea offered by Joshua Benton is that Facebook could hire editors to manage what shows up in its trending section, one of the major ways misinformation gets spread and a team of journalists and â€Å"charge them with separating at least the worst of the fake news from the stream.†[footnoteRef:45] A lot of this can be easily done with Facebook’s algorithm. Matter of fact, the outrageously fake news could be weighted a certain way in the algorithm. Facebook does have regulations and safeguards in place in reference to the freedom of expression. Facebook policies, although not all of them are known, have limitations on an individual’s freedom of expression. This all typically depends on the social movement and newsworthy content at the time. Facebook also states that it will remove content that attacks gender, age, sex, and race. Facebook has also decided to take down false information or fake news that is intended to immediately incite violence and physical harm. This is all dependent upon a user reporting the issue and the context of the issue. However, there are some issues with this. There is a possibility that by allowing social media companies to help regulate the market, you could be infringing upon the companies rights. Moreover, it may be difficult to prevent these companies from violating the First Amendment rights of individuals who wish to speak on the Internet. A possible solution would be to categorize companies like Facebook as a designated forum then the government will have more room for regulation. [ 45: Benton, Joshua. Get Serious About Getting Rid of Fake News, NIEMAN REPS., Fall 2016.] APPLICATION Although the public forum doctrine playing role, it does not solve the fake news issue. The best approach would be a combination of the marketplace of ideas approach, Harm Principle and Intermediate Scrutiny must be at the heart of restricting fake news. What does this mean? The approach I offer is one of a balancing test. Balancing the marketplace of ideas and the harm. Moreover, if the government is to intrude in this area in any way there must be some form of intermediate scrutiny. If Congress decides to put a statute in place, it must be narrowly tailored to achieve a legitimate governmental interest. If there is a less restrictive way than the statute proposes, then the statute is unconstitutional. I do not believe in punishing companies in order to achieve this goal unlike Germany. I believe hate speech is a necessary evil as long as it avoids becoming a true threat. However, we must encourage thoughtful forms of expression. One way to do so, similar to utility companies and their Energy Efficient programs in various states, is to offer an incentive. One incentive may be a capped tax break for the percentage of investment. However, unlike the Energy Efficiency programs there will not be any lost net revenues recovered because the amount of information trafficked through social media sites are innumerable. The government should first offer the incentive and if no one participates in the program the next step would be to construct a statute. On the other hand, I believe companies will be eager to participate because

What You Should Do to Find Out About Purchase Essays Before Youre Left Behind

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Embryonic Stem Cell Research - in Vitro Fertilization

In vitro fertilization and human embryonic stem cell research are two of the most popular and controversial topics that are being discussed today. Lee Silver, from the film defines in vitro fertilization as: [T]ak[ing] the process of reproduction out of the darkness of the womb, into the light of the laboratory. And all of the sudden you can do anything you want with these human embryos and eggs, which couldn t be done before (Holt). The real question regarding all of the varying opinions and controversy, is what is a human embryo, and what is human life? Other questions include the morality of embryonic stem cell research and is bearing children a right given to us by society? Further discussion of these question will entail why in†¦show more content†¦What consequences will this have on everyone involved? Everyone in the world will be involved if this actually happens. Defining what U.S. Americans feel a better baby is an irrelevant question. However is designing better babies, that will eventually age to adults any different than Nazi Germany killing people with undesirable traits? I feel that designing babies with certain desirable aspects is similar to killing people if they lack these traits. In conclusion, human embryonic research and in vitro fertilization are both ethically and morally wrong. The use of human life to conduct research in order to gain medical knowledge is an inhumane practice. Al so, no one has a guaranteed right to bear children, it is strictly a privilege. We should not go to extraordinary means to produce children who are genetically similar to their parents. This is especially selfish considering how many children are desperately waiting to be adopted by a caring family. Correcting this problem is a near impossible task. Even if embryonic stem cell research and in vitro fertilization were outlawed in the UnitedShow MoreRelatedThe Ethics of Stem Cell Research Essay741 Words   |  3 Pages Embryonic stem cell research can be easily defined. A stem is defined as something that is developed from. A cell is defined as a microscopic living organism. According to Dennis Hollinger, Embryonic stem cell research uses from the embryos inner cell mass that give rise to each of the human bodys many different tissue types(1). In our modern day society, stem cell research has become a controversial topic. Several people strongly oppose the idea of the research, but m any are struggling forRead MoreThe Debate Of Embryonic Stem Cell Research931 Words   |  4 Pages Embryonic stem cell research is the study of stem cells derived from the undifferentiated inner mass cells of a human embryo. For many years now, the ethics of embryonic stem cell research has been argued. A recent advance in this line of research is the ability to clone the embryonic stem cells, which allows for researchers to create a completely compatible embryonic stem cell to the individual’s tissue type. Though this new science may be very beneficial, not everyone can agree on the ethics ofRead MoreStem Cells And The Ethics Behind Their Use1606 Words   |  7 PagesStem Cells and the Ethics behind their Use Stem cells have the capability to become any type of cell. This process is possible because they are unspecialized and can divide to create new cells through cell division. Stem cells have the ability to become skin cells as well as organ cells (Stem Cell Information, 2015). There are two different types of stem cells which can be used in various ways. The first of the two is the embryonic stem cell which is found inside the embryo within its first few daysRead MoreThe Use Of Embryonic Stem Cells In Medicine1472 Words   |  6 Pagescure a disease? 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But what about all of the lives that these stem cells are saving, what if research contin ues and these embryonic stem cells end up beingRead MoreFederal Funds Should Be Used for Embryonic Stem Cell Research1401 Words   |  6 Pages Are embryonic stem cells the cure to many of the human body’s ailments, including defective organs and crippling diseases, or is their use a blatant disregard of human rights and the value of life?   Thanks to the rapid advancements in this field, the potential benefits of stem cells are slowly becoming reality.   However, embryonic stem cell research is an extremely divisive topic in the United States thanks to the ethical issues surrounding terminating embryos to harvest the stem cells.   In responseRead MoreEmbryonic Stem Cell Research Essay1429 Words   |  6 Pagescure a disease? 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When stem cells divide they could become specialized cells such as muscle cells, red blood cells, brain cells, and etc. their uniqueRead MorePersuasive Essay : Stem Cell Research1489 Words   |  6 PagesPersuasive Essay Stem Cell research and its funding have caused a lot of controversy throughout the past years. Stem cells are cells that are present in all living organisms. These cells have the potential to grow into any type of cell, including blood cells, nerves, muscles, and pancreatic cells. Stem cell research is essential because of the beneficial aspects it has to offer. Stem cells could potentially treat conditions such as Alzheimer s, Parkinson s, birth defects, strokes, Diabetes, cancerRead MoreA Moratorium On Federal Funding861 Words   |  4 PagesThe Department of Health and Human Services maintained a moratorium on federal funding for research on embryos and fetuses, as well as in vitro fertilization, until President Clinton issued an executive order lifting it in 1993 (Scott p.153). However, Congress banned federal funding for human embryo research by adding legislation known as the Dickey-Wicker Amendment to every appropriations bill for the National Institutes of Health since 1995, making it impossible for the President to overturn theRead MoreThe Ethics Of Stem Cell1482 Words   |  6 PagesEthic in Stem Cell We have an amazing items in our body called stem cells. Stem cells are cells that have the ability to transform into any type of tissue cell in the human body. After a sperm fertilizes an egg, the cell they form is known as a zygote or a totipotent cell. This cell goes through numerous mitotic divisions and after about four days forms a blastocyst. This blastocyst has an outer layer and an inner layer, part of which is hollow. The outer layer grows to form what will become the

Venture Projects Economics Finance Accounting †Free Samples

Question: Discuss About The Venture Projects Economics Finance Accounting? Answer: Introduction With the advent of science and technology there have been various venture projects that have been developing all over the globe in order to improve the economic and the operational structure of the world. It has been observed that there are various projects that have been constructed in order to build new buildings and artifacts that would enhance the lifestyle of the human beings living in this world(Schaper, 2016). This paper therefore is being constructed in order to undertake a fundamental analysis of on ongoing project that is functioning in Melbourne so that a clear idea about the background of the project along with its objectives can be understood. The assessment of the economic analysis and tools and techniques would even be discussed and the cost benefit analysis of the project can even be understood so that a clear cut idea about the project can be taken into consideration. This paper therefore has considered Ravenhall Prison Project that has been operating from the year 2014 and still continuing so that precise knowledge about project and the cost associated with it can be gained. Project Background The Ravenhall Prison Project is being constructed in order to provide a new medium-security prison facility in order to provide accommodations to around 1000 prisoners and this project has been predicted to be completed by the end of 2017. In the year 2014 on 15th September, the Victorian state made a contract with GEO consortium in order to build, finance, design, operate and maintain a new medium-security prison for men, which would be situated in Ravenhall, in the west of Melbourne(Treasury and Finance - Ravenhall Prison - Project Summary 2017). Ravenhall has been a key part of the prison expansion program of Victoria. The prison even has the ability to expand in future in order to accommodate around 1300 prisoners if deemed necessary. The new prison that is under construction would deliver the infrastructure and prison beds in order to aid in explaining for the correctional services that have been demanded in Victoria. The prison has been constructed on the existing Crown land at Ravenhall that is contiguous to the Metropolitan Remand Centre and the dame Phyllis Frost Centre. The land is specifically flat in nature and comprises of open paddocks that consists of vestige native grassland patches and few trees that are scattered. The required planning along with the cultural heritage and environmental approvals for this area are in place. This project has been a joint venture of the public private partnership in which the private sector is accountable for constructing, financing, operations, design and maintenance that are custodial in nature. This project would provide increased value for money with respect to the correctional services and even provide increased quality. GEO Consortium was appointed to deliver the project after the completion of a tender process and a contract was signed in the year 2014 in September. GEO Consortiu, consists of John Holland Group, Capella Capital, Honeywell and GEO Group Australia. The essential alliance partners are inclusive of the Gathering Place and Melbourne City Mission, Kangan Institute and YMCA who would deliver services and programs in both post-release and the prisoners under custody(Treasury and Finance - Ravenhall Prison - Project Summary 2017). The health services within the prison would be given by Correct Care Australasia and the forensic services of mental health at the prison would be given by Forensicare. Project Objectives and Justification The construction of the project has been undertaken in order to improve the safety of the society by humanely and securely preserving the prisoners and giving them with services and programs that have been constructed in order to decrease the extent of reoffending. This project reveals a key investment in the infrastructure and services of the prison with the help of which GEO Consortium would deliver an innovative facility that would perform a key role in the correctional system of management. This project would be influential for generating economic advantages as well as increasing employment with the establishment of 700 jobs during the period of peak construction and ongoing jobs that would be more than 600. The construction of the project would lead to development of new jobs in that area and thereby increasing the employment rate and in a way benefit the economy(Burchardt et al., 2016). The objectives of the project and the area of the focus has been explained as follows: Provide added capacity in the prison system of Victoria Provide added forensic metal health services to the prisoners Provide supplementary capability in order to lower the reoffending Encourage practices that are innovative in nature and effective operations that would assist the value for money The justification for the construction of the research project has been in order to secure and safeguard the communal harmony and to maintain the prisoners in the prison cell in an effective manner. The construction of a prison that would consist of various innovative amenities would boost the confidence of the prisoners and would help them in turning over a new leaf and start their life effectively(Gatti, 2013). The project construction is done in order to focus on various aspects like targeted approach for the prisoners who are having challenging behavior, indigenous prisoners and improved responsiveness towards the complexities of the young prisoners. Assumptions and Constraints The project has been constructed by depending on the financial capacity and the assumptions. The assumptions of the project include identifying the financial capability of the participants and the participating members in order to deliver the project within its completeness(Block et al., 2017). There are various constraints that are related to the project like the risks that are associated with the planning of the project and gathering approvals for the planning, risks in the site like the native titles and contamination of the sites, construction risks and the design risks in order to construct the prison project and lastly the operational and the financial risks that are associated with the completion of the prison project. Therefore, the risks are allocated and transferred effectively in order to reduce the level of risks and thereby helping in improving and smooth flow for the construction of the prison project. Literature Review The literature review would comprise of the various data and tools that have been used by the project on order to determine their operational activities and to undertake economic analysis and the cost benefit analysis of the Ravenhall Prison Project. This section of the paper would provide an extensive research and analysis of the cash flows, the present worth, internal rate of return along with the profitability index and business growth strategies and its best practices so that the project can be concluded precisely. The use of the MADM and MCDM financial analysis process would be influential for understanding the process that would be used in order to understand the current financial and economic position of the Ravenhall Prison Project. The project explains about the literature review and the explanation regarding the economic analysis and the cost benefit analysis of the Ravenhall Prison Project. A small overview of the risk evaluation model of Ravenhall Prison Project in Melbourne Victoria will be discussed in this section. The process of economic analysis are defined as the mathematical and statistics and graphics. The economic analysis is based on the various methods of the economic sensitivity and in order to make effective recognition of the similar input, it is essential to investigate two or more processes. Overview of Project Economical Analysis Techniques and Tools Australia is regarded as a vivacious free democracy of the market and there has been vibrant economic progress that has been possible due to absence of any sort of recessions. The effective process of the government has been beneficial for the economy and a free well-functioning legal system, bureaucracy has led to effective entrepreneurial enhancement. Australia is considered as an attractive and dynamic position for investment(Stiglitz, Rosengard 2015). In most of the scenarios, the government has decreased the investment and has influenced the private sector to undertake investments. This has been observed in the Ravenhall Prison Project where investments are undertaken mainly by the private sector. The country has been effectively competitive in the technological areas and services. The income tax rate is around 45% and the rate of corporate tax has been 30%. One of the optimistic parameters of project start up in Australia has been rate of start up being higher as they have the probability of contributing to the expansion. The new business ventures in Australia like the variations in funding sources and projects like the Ravenhall Prison Project tries to make use of the equity finance during the primary stages of the constructions. The country has been experiencing shocks and problems in the during the past few years but during the first quarter of 2017, the economy has recovered from this situation and this has led to rise in the confidence for the business and the consumers and this in way would have a positive impact on the investment of the business and spending of the investors. The Australian economy is considered to be within a solid base in spite of the various weaknesses in the investments that are non-mining in nature. With respect to Ravenhall prison project in Australia it has been observed that the project has been experienc ing growth and as this is an on-going process and this has led to rise in investments(Coates 2014). The Australian economy has remained very is strong in spite of the rise in the price of diesel and this has led to the fall in the disposable income for the consumers. The economy of the country has been developing with the rise in the rate of interest which is being used for reducing the rate of inflation. The growth of the economy has been possible as the government has been reducing the rate of taxation. This would encourage the investors of the project business to increase their investments in the Ravenhall Project Prison. This has led to the construction of the prison much more effectively. The analysis of the Ravenhall Prison has been possible by undertaking economic analysis like the construction of the variables that are available in the project and the identities, functions and the equations that have been seen in the project report of Ravenhall Prison Project. The economic assessment of the project has been possible by looking at the expenses and the total funding that has been undertaken for the completion of the project. The table below would provide an overview of the economic evaluation of the project. Particulars Amount Residual Value Non-Current Assets: Trademark 500000 0 Patent 750000 0 Property,Plant Equipment 15000000 4500000 Furniture Fittings 1000000 150000 Motor Vehicle 1500000 600000 Computer Equipment 1500000 0 Preliminary Expenses: Business Registration 100000 License Fees 150000 Deposit for Electricity 100000 100000 Deposit for Telephone Internet 50000 50000 Recruitment Cost 30000 Share Issuance Cost 35000 Bond Issuance Cost 20000 Other Miscellaneous Expenses 75000 Working Capital: Purchase of Raw Material 30000000 Wages Salaries 20000000 Manufacturing Overhead 13000000 Selling Marketing Expenses 690000 General Administrative Expenses 338250 64028250 TOTAL START UP COST 84838250 Capital Funding: Equity Capital 38177213 5 yrs. Bond 27996623 Loan From Bank 18664415 TOTAL CAPITAL EMPLOYED 84838250 The notice that has been allocated to each of the employees who are performing for the construction of the Ravenhall Prison Project has been given in the form of the table which provides a guideline of the process that would be utilized for the completion of the project within the scheduled time period. Assignment Start date Submission Duration Start up 15/09/2014 31/12/2017 3 years Activity 1- Researching the Australian markets and its economic scenario 20/09/2014 21/12/2014 3 months Activity 2- Financial evaluation of project 13/03/2015 31/12/2015 9 months Activity 3- Determining the financial viability of project by selecting the best alternative 31/03/2017 09/04/2017 2 weeks Equivalent Uniform Annual Cash Flow The equivalent uniform cash flow of Ravenhall Prison Project has comprises of the outflow and the inflow of the cash flow(Dopp et al., 2014). The cash flow from the operating expenses refers to the payments made to the suppliers, direct labor cost. The annual cash flow for the organization has been given below: Particulars Year 1 Year 2 Year 3 Cash Flow from Operating Activities: Cash Sales $56,000,000 $61,418,000 $67,360,192 Collection from Debtors $77,000,000 $91,449,750 $100,297,513 Cash Purchase ($24,000,000) ($26,322,000) ($28,868,654) Payment to Suppliers ($30,000,000) ($38,902,500) ($42,666,317) Direct Labor Cost ($36,666,667) ($43,547,500) ($47,760,721) Manufacturing Expenses ($26,000,000) ($28,515,500) ($31,274,375) Insurance ($12,000) ($12,300) ($12,608) Rates Taxes ($6,500) ($6,663) ($6,829) Salary of Office Staffs ($91,667) ($102,292) ($104,849) Cleaning Charges ($5,000) ($5,125) ($5,253) Electricity for Office ($13,750) ($15,344) ($15,727) Telephone Internet ($7,333) ($8,183) ($8,388) Salary of Marketing Staffs ($137,500) ($153,438) ($157,273) Sales Commissions @1.5% on Sales ($700,000) ($767,725) ($842,002) Travelling charges @2% on Sales ($350,000) ($383,863) ($421,001) Income Tax Expenses ($1,833,185) ($2,222,795) ($2,646,860) Cash Inflow/(Outflow) from Operating Activities $13,176,398 $11,902,524 $12,866,848 Cash Flow from Investing Activities: Purchase of Non-Current Assets ($20,250,000) Preliminary Expenses ($560,000) Sale of Assets Return on Deposits Cash Inflow/(Outflow) from Investing Activities ($20,810,000) $0 $0 Cash Flow from Financing Activities: Share Issue $38,177,213 Bonds Issue $27,996,623 Loan From Bank $18,664,415 Interest Payment ($3,732,883) ($3,732,883) ($3,732,883) Dividend Payment ($1,497,101) ($1,815,283) ($2,161,602) Repayment of Bond Repayment of Loan from Bank Cash Inflow/(Outflow) from Financing Activities $79,608,266 ($5,548,166) ($5,894,485) Net Cash Increase/(Decrease) for the period $71,974,664 $6,354,358 $6,972,363 Add: Opening Cash Balance $0 $71,974,664 $78,329,022 Closing Cash Balance $71,974,664 $78,329,022 $85,301,385 Present worth (Net Present Value) The net present value for the project has been given below with respect to the variable inflation rate, growth rate and the WACC. The Net Present value at 25 inflation rate has been 3418865, ta 2.50% has been 358505005 and at 3.50% has been 36484023. It has been observed that with respect to the current position of the project, the Net Present Value has been 38505005 as the rate of inflation has been 2.505, the growth rate has been 7% and the WACC has been 8.71%. Internal Rate of Return The Internal Rate of Return for Ravenhall Prison project has amounted to 10.04% suggesting that the project has a positive effect and the project can be viable for further investments(Welsh et al., 2015). The IRR would rise and fall with respect to the changes in the inflation rate, growth rate and WACC. The IRR has indicated that investments can be an effective in the prison project as government has interference on this project and therefore return on investment would be fruitful for the investors. Modified IRR The IRR can get modified with respect to the changes in the rate of inflation, growth rate and the WACC of the economy and the project. It is seen that the IRR has been 9.64% at 2% inflation rate and 10.22% at 3.50%. IRR would have a value of 9.10% at 5% growth and 10.58% at 9% growth. With respect to the WACC at 6.50% the percentage will be 12.11% and 8.05% at 10.50%. Cost-Benefit Analysis The cost benefit analysis has been discovered to be the process with the help of which the business decisions are evaluated. The advantages of the stipulated condition or the actions related to the business are summed and then the expenditures related undertaking that action is evaluated(Hardin, 2015). The cost benefit analysis of Ravenhall Prison Project has been analyzing the overall costs that are related to the project and the funds that are generated with the help of the various financial institutions and the capitals invested by GEO Consortium. The overall analysis of the cost is given in the table below: Particulars Year 1 Year 2 Year 3 Inflation Rate 2.50% 2.50% Sales Growth Rate 7% 7% Sales Volume 40000 42800 45796 Selling Price Per Unit $3,500 $3,588 $3,677 Total Sales Revenue $140,000,000 $153,545,000 $168,400,479 Cost of Good Sold per unit: Raw Material Consumed ($1,500) ($1,538) ($1,576) Direct Labor Cost ($1,000) ($1,025) ($1,051) Total Cost of Goods Sold p.u. ($2,500) ($2,563) ($2,627) Total Cost of Goods Sold ($100,000,000) ($109,675,000) ($120,286,056) GROSS PROFIT $40,000,000 $43,870,000 $48,114,423 Variable Manufacturing Overhead p.u ($650) ($666) ($683) Total Variable Manufacturing Overhead ($26,000,000) ($28,515,500) ($31,274,375) Depreciation on Property,Plant Equipment ($2,100,000) ($2,100,000) ($2,100,000) Total Manufacturing Overhead ($28,100,000) ($30,615,500) ($33,374,375) General Administrative Expenses: Depreciation on Furniture Fixtures ($100,000) ($90,000) ($81,000) Depreciation on Computer Equipment ($180,000) ($158,400) ($139,392) Amortization of Patent ($100,000) ($100,000) ($100,000) Amortization of Trademark ($150,000) ($150,000) ($150,000) Insurance ($12,000) ($12,300) ($12,608) Rates Taxes ($6,500) ($6,663) ($6,829) Salary of Office Staffs ($100,000) ($102,500) ($105,063) Cleaning Charges ($5,000) ($5,125) ($5,253) Electricity for Office ($15,000) ($15,375) ($15,759) Telephone Internet ($8,000) ($8,200) ($8,405) Total General Administrative Expenses ($676,500) ($648,563) ($624,309) Selling Marketing Expenses: Depreciation on Motor Vehicle ($180,000) ($158,400) ($139,392) Salary of Marketing Staffs ($150,000) ($153,750) ($157,594) Sales Commissions @0.5% on Sales ($700,000) ($767,725) ($842,002) Travelling charges @0.25% on Sales ($350,000) ($383,863) ($421,001) Total Selling Marketing Expenses ($1,380,000) ($1,463,738) ($1,559,989) Net Operating Profit/(Loss) $9,843,500 $11,142,200 $12,555,750 Interest Expenses: Interest on Bond ($1,959,764) ($1,959,764) ($1,959,764) Interest on Loan From Bank ($1,773,119) ($1,773,119) ($1,773,119) Total Interest Expenses ($3,732,883) ($3,732,883) ($3,732,883) Net Profit before Tax $6,110,617 $7,409,317 $8,822,867 Income Tax Expenses ($1,833,185) ($2,222,795) ($2,646,860) Net Profit after Tax $4,277,432 $5,186,522 $6,176,007 Gross Profit Margin 28.57% 28.57% 28.57% Net Profit Margin 3.06% 3.38% 3.67% Return on Equity 11.20% 13.59% 16.18% Other Decision Making Models - Multi-Attribute Decision-Making Model There are are various other decision making models that are available to the management of the project in order to evaluate the activities of the project and undertake decisions accordingly. The use of the decision model is dependent on the management and the management makes proper utilization according to their needs in the prison project. There are various models include the Multi-Attribute Decision Making Model, Multi-Criteria Decision making Model, Analytical Hierarchy Process etc. These models can be used in an effective manner for the Ravenhall Prison Project and better decisions with respect to the operational activities can be constructed, which would lead to the completion of the project before the assigned deadline. MCDM in Financial Decision Making for Projects The MCDM process makes use of equipment and tools that contributes in the quality of the financial process of economic decision making and to the quality of the resulting decisions. MCDM considers problems related to financial decisions as a multiple criteria as financial decision problem occurs due to the issues in different accounting figures which could have an effect on the financial report of the prison project(Medina et al., 2014). These problems mainly arise due to the effective assignment of the scarce capital and the alternate uses of the resources. Hence, it is essential for the management of the prison project looks to allocate the resources in an effective manner by taking help of this model as this would be influential for using the resources required for the project in the areas were these resources require more significance so that the project can be completed within the stipulated time limit and the each and every aspect of the project receives equal importance accord ing to the priority. MADM The multi attribute decision making model is a significant part of innovative decision of science. It anticipates that there are various set of substitutes for the various attributes, which the management undertaking the decision requires to assess and evaluate. The goal of this model has been to discover the demanded substitute for assisting the process of decision making. The problems that have been associated with the MADM has been rectified by taking help of the traditional processes like the simple additive weighing method, analytical hierarchy process and TOPSIS process. The MADM process looks into the different attributes related to the project rather than the price. In this scenario, it has been observed that Ravenhall Prison Project has looked in to the attributes of providing a safe restoration place for the prisoners in Australia and to accommodate a larger number of prisoners at one place(Wang et al., 2014). It is even seen that looking after the primary needs of the pris oners by providing proper beds and primary benefits are even considered overlooking the price involved. The project has even been constructed in order to provide safety and security to the citizens of Australia. Analytical Hierarchy Process (AHP) The analytical hierarchy process is a technique that is structured for evaluating and organizing the decisions that are complex in nature and this has been done by depending on the mathematical process. With respect to the Ravenhall Prison Project, the main objective has been to construct the prison at the lowest cost with the help of proper quality material and within the stipulated time. It is seen that various criteria are constructed by looking at the cost, safety and capacity(Gabay et al., 2014). These aspects would be taken into in choosing the best alternate strategy that would be used by the management in order to complete the prison project effectively. Hence, it can be said that making use of the strategy would be influential for the development of the prison project effectively. Best Practices for Business Growth One of the biggest challenges in business growth is sustainable growth. The short term as well as the long term gains both need to be kept in mind while implementing the procedures for business growth. Different businesses have different reasons for the purpose of sustainability but the main fundamental concepts are the same. The Authenticity of the business purposes need to be maintained. The authorities concerned must repeatedly examine their sense of purpose as well as ensure that the organisation serves the purpose of the project properly. There should also be a constant as well as consistent sense of growth. It also should involve continuous pragmatic innovation. The authentic purpose of a company contributes to its USP. It is better for an organisation to have a clear value and an aim for the purpose of the business growth. The prison project needs to utilise the practices of safety as well as security which is one of the features it aims to achieve (Cooke Williams, 2013). Partnership as well as collaboration is also an extremely important factor for the successful establishment of the business growth. Though the idea of achieving everything singularly in case of a business project is tempting and logical in case of not much availability of funds, the best thing to do is to find the best possible partners for the prison project. The collaboration with the suitable partners in case of the prison project will help in the expansion and proper growth and will also be sustainable. It is necessary to know exactly what to do at a particular time because the needs of different projects are different (Thompson, 2012, October). The project should be done in such a way that the prison expansion concept is deemed successful and helps in the establishment of the successful steps in the business growth. The prison should have proper facilities along with the concept of improvement as well as rehabilitation options (Vaara Whittington, 2012). A business ecosystem is a financial community of organisations as well as individuals which operate in different ways. It is necessary to understand the needs of the prison project are different from other commercialisation projects like malls or shopping centres or other places. The business ecosystems encourage the companies undertaking the innovative as well as difficult projects by fulfilment of their competitive capabilities (Sherman, 2014). In order to ensure that the business needs of any particular project is met, it should be maintained that the leaders or the authorities under whom the project is taking place, need to be aware at every particular stage of growth. Retrospection, self-awareness, as well as a keen sense of strategy is necessary which is both for the short as well as the long term (HealyPalepu, 2012). The authorities in charge of the prison project should adopt an adaptive as well as a flexible nature of leadership. By being mindful as well as understanding the business strategies give the best results for any given project. The continual investment in the capabilities of individual workers as well as organisations helps in the benefit of the organisations (Goodstein MacKenzie, 2013). Business Growth Strategies The business growth strategies should focus on the nature of the project at hand. It should be understood that the nature of the prison is different. The expansion of the prison needs to be the main focus of the organisation which is engaged in the construction project (La Vigne Samuels, 2012). The expansion projects need to be properly undertaken and the details need to be stated in advance as well (Crawley, 2013). The prisons should not be built in a morose or a depressive way so that the residents or the inhabitants of the place should not be de-motivated. It should not happen that the people who are prisoners find it difficult to move back to normalcy. There should not be any dark corners or dark places which might cause the prisoners to move to a dark part of their conscience. The prison architecture should in no way be linked with the levels of violence as well as drug use. There should be an openness as well as connectivity to the prisons as the closed, dark as well as the privacy of the prisons are bound to affect the mindsets of the prisoners and they might engage in fighting, assault, self-harm, consumption of drugs. It might also cause escapes from the prisons. In other words it can be said that the prison projects should correspond or comply with the rehabilitation revolution in order to be a positive impact on the prisoners to facilitate their stay with good experiences and positivity. The cost efficiency needs to be kept in mind while implementation of the project. The cost of prisons is considerable and they also cause the drainage of the vital resources from the segments of health-care, education, housing as well as the other social programs. The de-funding of the prison sector and ensuring the good environment does not lack the resources that need to be taken care of. The exposure of the impact of the public-private finance initiatives show that the cost savings are never delivered. The reduction of the quality of services and the facilities should not be done in a way to actually harm the people. The prisons are never cost efficient. Since the prisons and their buildings waste money as well as the vital resources, the business strategies should revolve around the quality of the prison and the money as well. The private prisons do not always form a clear advantage of the public sector counterparts. The nature of the prison market as well as their proper management need to be done to explain the findings carefully. The cost as well as the quality needs to be uncompromised as the prison projects are huge and influential to the companys reputation. The quality of the prison, the provided facilities should constitute the business strategies of the prison project. Profitability Index Profitability Index is even known as the profit investment and value investment ratio for any developing project and this has been a mechanism for ranking the projects as it permits to quantify the amount of the value developed due to the investment per unit. With respect to the current profitability index of Ravenhall Prison Project, it can be observed that profitability index has been 0.42 or 42.20% and hence it can be said that the project is an effective one and undertaking investment in this project would lead to effective construction of the project within the stipulated timeline. Recommendations for case project financial model or plan The project has been established by undertaking numerous researches of the Australian market and evaluation of the financial statements and the project background and the scope of the project. The country has been regarded as the democratic market that is vibrant and has been functioning like this for over 25 years and this development has been possible due to the limited level of recessions. The effective process of the government has benefited the Ravenhall Prison Project due to an effective and well-functioned legal system. The presence of such an effective legal system and government regulations has revealed an effective economic system and this has motivated the private sector to undertake investments in such projects. Hence it is seen that GEO Consortium has undertaken investment in the prison project and this in way would improve the revenue for the organization and even complete the project in an effective manner. According to the financial estimations of the Ravenhall Prison Project, it has been observed that this project would be enormouslyachievable to make sure the growth and stability in the Australian region. It has been recommended that the project should undertake the activities that they have been performing currently as this has been an effective process and sustainable use of the project would lead to the proper return on investment for GEO Consortium and completion of the project in a timely manner with effective facilities available within the prison. Reference Anderson, J. E. 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Overview of Project Economical Analysis Techniques and Tools

Rappaccinis Daughter Essays - Rappaccinis Daughter,

Interestingly to me, Hawthorne attended college and when he graduated he moved back home with his mother (his father died when he was only four). He had started writing some in college and soon published his first work after graduation. He said this was a lonely and difficult time for him because he earned little money, but did learn a lot. The first thing he published was Fanshawe (1828). Soon after he did, he learned that publication of his work was a mistake and he wanted all copies destroyed. He disposed of all the ones that he could get his hands on and asked his family and friends to do the same. A fire at the local bookstore destroyed all of the rest of the unsold copies. This must have been a sad time for him. To be able to actually write something and publish it and then deliberately trash all of them. On the ninth day of July in 1842, Hawthorne married Sophia Peabody. He wanted to marry her long before this time, but was not making very much money and was afraid he would not be able to support. He did slow down writing for a while and worked at a farm to try to earn some money so he could have the money that he wanted. He learned fast that manual labor left little energy for anything else (DLB 153). Edgar Allan Poe described Hawthorne as a man of "truest genius". Others said he was a "truly American literary voice". Mosses from an Old Manse" was Hawthorne's last collection in writing short stories. He would still work on small works, but this would be his last big one. Many of Hawthorne's books are science fiction fantasies. The conflict in values between the conservative tradition in science that relied on authority is illustrated in "Rappaccini's Daughter" with the conflict between Professor Baglioni and Doctor Rappaccini. Baglioni defines Hawthorne's sense of the Faustian quest when he says of his rival, "he cares infinitely more for science than for mankind...He would sacrifice human life, his own among the rest, or whatever else was dearest to him, for the sake of adding so much as a grain of mustard seed to the great heap of his accumulated knowledge" (DLB 158). Rappaccini's laboratory is the garden and the plants seem to threaten him. When he has to touch a flower he calls for his daughter, Beatrice because she is "better with them". She herself is a poisonous "plant". Anything that she breathes on will die. This is scary that a father would treat his daughter the way he did. His patients were only good for one thing he thought - being a sub ject for an experiment. Some scholars say that "Rappaccini's Daughter" is probably the most complex of all of Hawthorne's short stories. Rappaccini is an evil man that is extremely smart, but he is also a loving and protective father. Beatrice is a person of purity and also a little evil too. Giovanni is a student at the University of Padua and his room overlooks the garden. When he sees Beatrice he immediately falls in love with her. He was so attracted to her that sometimes when he watched from the window he thought he could be dreaming. "He was struck by its expression of simplicity and sweetness; qualities that had not entered into his idea of her character, and which made him ask anew, what manner of mortal she might be" (Lauter 2242). Beatrice was so powerful that she could have anything in her reach to die in a second. For example, when she went to the flower and asked for "thy breath". The stem broke from the flower and a few drops of the moisture fell onto a lizard's head a nd killed him. " Beatrice observed this remarkable phenomenon, and crossed herself, sadly, but without surprise; nor did she therefore hesitate to arrange the fatal flower in her bosom" ( Lauter 2242). I do not think Beatrice enjoyed killing these innocent flowers and animals, but she had to for her father and for her to live. Giovanni witnessed this incident and he couldn't believe what he saw. he really thought