Encyclopedia of Global Resources part 130 docx

Second, oil prices crashed. The commercial feasi - bility of synthetic fuels rested on the assumption that the price of oil would continue to increase. Instead, the global recession that was ignited by the rising cost of OPEC oil resulted in a steep drop in the demand for oil and a crash in oil’s price—to a low of approxi- mately $7 a barrel in the mid-1980’s. Finally,while oil prices were falling, tax cutting and enhanced military spending by the Reagan adminis- tration were producing high budgetary deficits. The SFC’s multibillion-dollar budget became an inviting target for budget cutters. In 1984, Congress rescinded $7.2 billion of the SFC’s initial $20 billion authoriza- tion. The following year Congress voted to close the corporation altogether and rescinded its remaining funds. On April 18, 1986, the SFC closed its doors for the last time. Joseph R. Rudolph, Jr. Web Site National Archives Executive Order 12346—Synthetic Fuels http://www.archives.gov/federal-register/ codification/executive-order/12346.html See also: Coal gasification and liquefaction; Energy economics; Energy politics; Oil embargo and energy crises of 1973 and 1979; Oil shale and tar sands. 1196 • Synthetic Fuels Corporation Global Resources T Taiwan Categories: Countries; government and resources Few natural resources of significant economic value re- main in Taiwan. After many decades of mining, al- most all metallic minerals, coal, and talc have been de- pleted. Most of the country’s oil, gas, and power needs must be met through importing, although Taiwan is developing renewable energy using wind and solar power. Taiwan’s export-oriented economy depends on the world global economy for growth. The Country Taiwan is an island in East Asia located in the western Pacific. In 2007, Taiwan’s gross domestic product ex- ceeded $383 billion, representing real growth of 5.7 percent and the world’s twenty-fourth largest econ- omy among 181 countries that were ranked. The island of Taiwan is long and narrow, and a central mountain range, the Chung-yang, travels its length from north to south, covering about one-half the total land area. The most rugged land is found in the eastern part of the island. Becauseofthemoun- tainous terrain, there are few natural harbors. In the west, a broad plain with connected basins slopes toward the TaiwanStrait. Foothills, with sloping table- lands terraced for rice cultivation, surround the Chung-yang Range and account for nearly 50 percent of Taiwan’s surface area. Taiwan has few natural resources and depends heavily on foreign trade. More than twenty types of minerals are mined in Taiwan, mainly marble, lime- stone, serpentine, and gravel. Petroleum and natural gas reserves are located in the northwest. The eastern area has marble deposits. Taiwan’s riverbeds provide sand, gravel, and rock forconstruction. Because of ex- ploitation, Taiwan’s mineral resources have been es- sentially depleted. Marble Taiwan’s marble resources are relatively abundant, and the eastern side of Taiwan has marble deposits near the town of Hua-lien. This marble is used mainly in building materials. The term “marble” refers to a variety of limestones and/or dolomites that have un- dergone metamorphism and are capable of taking on a high polish. Marble is used in sculpture, in building materials, and in many other applications. Pure white marble is the result of metamorphism of very pure limestone. Thecharacteristicswirlsand veins of many- colored marble varieties generally result from min- eral impurities such as clay, silt, sand, or iron oxides that were originally present as grains or layers in lime- stone. Green, for example, signals the presence of ser- pentine, resulting from high-magnesium limestone with silica impurities. Years of collecting have takentheir toll on Taiwan’s supply of natural stone,resulting inmore than 95 per- cent of the marble processed in Hua-lien being im- ported. Heightened environmental awareness has in- creased restrictions on marble harvesting. In 1961, the government opened a factory that employed Chinese Civil War veterans to process the abundant marble. The business was successful, and stone processing in the area expanded quickly, with companies focusing mainly on cutting huge chunks of marble into shapes and sizes suitable for construction materials. The in- dustry reached its peak in 1994, when Taiwan was one of the largest producers of processed marble in the world, second only to Italy. Afterward, labor-cost com- petitors pushed the island’s industry into decline, re- ducing marble processing in Hua-lien by 50 percent. As limestone resources approached depletion after forty years of exploitation, the source of mineral raw material for the cement industry shifted to marble. The area surrounding Hua-lien, on the east coast of southern Taiwan, is situated on the line of conver- gence of the Philippine and Eurasian tectonic plates; therefore, stone of beautiful complexity can be found there. Rhodonite is a type of highly valued pink mar- ble stone found mainly in Taiwan, although there is some in Russia andChina. The Taiwanese variety is es- pecially attractive because of its unique color and veining. Agriculture Taiwan’s most important natural resource is its land. Approximately one-fourth of Taiwan’s land is suitable 1198 • Taiwan Global Resources Taiwan: Resources at a Glance Official name: Taiwan Government: Multiparty democracy Capital city: Taipei Area: 13,893 mi 2 ; 35,980 km 2 Population (2009 est.): 22,974,347 Languages: Mandarin Chinese and Taiwanese Monetary unit: New Taiwan dollar Economic summary: GDP composition by sector (2008 est.): agriculture, 1.7%; industry, 25.1%; services, 73.2% Natural resources: small deposits of coal, natural gas, limestone, marble, sand and gravel, asbestos Land use (2001): arable land, 24%; permanent crops, 1%; other, 75% Industries: electronics, petroleum refining, armaments, chemicals, textiles, iron and steel, machinery, cement, food processing, vehicles, consumer products, pharmaceuticals Agricultural products: rice, corn, vegetables, fruit, tea, pigs, poultry, beef, milk, fish Exports (2008 est.): $254.9 billion Commodities exported (2008): electronics, flat panels, machinery, metals, textiles, plastics, chemicals, auto parts Imports (2008 est.): $236.7 billion Commodities imported (2008): electronics, machinery, petroleum, precision instruments, organic chemicals, metals Labor force (2008 est.): 10.85 million Labor force by occupation (2008 est.): agriculture, 5.1%; industry, 36.8%; services, 58% Energy resources: Electricity production (2008 est.): 225.3 billion kWh Electricity consumption (2008 est.): 233 billion kWh Electricity exports (2008): 0 kWh Electricity imports (2008 est.): 0 kWh Natural gas production (2007): 416 million m 3 Natural gas consumption (2007): 13.6 billion m 3 Natural gas exports (2008 est.): 0 m 3 Natural gas imports (2007): 10.9 billion m 3 Natural gas proved reserves ( Jan. 2008): 6.229 billion m 3 Oil production (2007 est.): 1,306 bbl/day Oil imports (2007): 660,400 bbl/day Oil proved reserves ( Jan. 2008 est.): 3 million bbl Source: Data from The World Factbook 2009. Washington, D.C.: Central Intelligence Agency, 2009. Notes: Data are the most recent tracked by the CIA. Values are given in U.S. dollars. Abbreviations: bbl/day = barrels per day; GDP = gross domestic product; km 2 = square kilometers; kWh = kilowatt-hours; m 3 = cubic meters; mi 2 = square miles. Taipei China Philippines J a p a n Taiwa n East China Sea South China Sea Pacific Ocean for cultivation of agricultural crops. Taiwan’s main ag - ricultural products include rice, corn, fruit, vegeta- bles, tea, pigs,poultry, beef,milk,andfish.The princi- pal food crop is rice,which is grown along the western plain and inthesouthern areaofthecountry.There is an overabundance of rice, however, and farmers have been encouraged to grow other, more profitable, crops, such as mushrooms or some hydroponic crops that requireonlya small amount ofspaceand little ini- tial investment. Other food crops include sweet pota- toes, bananas, peanuts, soybeans, and wheat. Agricul- ture in Taiwan is characterized by high yields, use of irrigation, terracing, and multiple cropping to maxi- mize yields. Taiwanese farmers also use fertilizers ex- tensively. Although still important for generating revenue through export and as a domestic food source for the Taiwanese population, agriculture has dropped from its predominant role in the economy of Taiwan. Sugar, pineapples, citrus fruits, crude tea, and aspara- gus are grown on plantations and are primary export and cash crops of Taiwan. Oolong tea, which is fa- mous worldwide for reported health benefits, is pro- duced in Taiwan. Small amounts of cotton, tobacco, jute, and sisal are also produced. Other agricultural exports include fish and other marine products. Wind Power Taiwan has limited energy resources and meets 99 percent of its energy needs through imports. Conse- quently, the Taiwanese government has encouraged use of renewable energy resources. Taiwan’s goal is to have 10 percent of its energy needs met through re- newable resources by 2010. The potential for wind energy as a renewable re- source in Taiwan is high, as Taiwan is rich in both on- shore and offshore wind energy resources. An island off the coast of Taiwan, called P’eng-hu, has some of the best available wind resources in the world. Al- though Taiwan has potential for both onshore and offshore wind farming, the limited landarea on the is- land favors use of offshore wind resources. Taiwan’s per-capita carbon dioxide emissions are higher than any other Asian country and rank third worldwide; only the United States and Australia have greater per- capita emissions. Based on the current emission fac- tors in Taiwan, wind energy has the potential to re- duce carbon dioxide emissions by approximately 90 million metric tons per year. The use of wind energy may help decrease the use of coal and natural gas, which currently provide energy for about one-third of Taiwan’s power generators. Coal Taiwan has limited coal resources. From the early years of the country to the 1980’s, coal production played a significant role in Taiwan’s economy, with much ac- tive mining of coal in the northern area of Taiwan near the Tatu River. During the initial stages of Tai- wan’s economic development, coal was the primary energy source. The power that fueled early industrial development relied mostly on the coal produced do- mestically in Taiwan. In 1986, coal production was as high as 4.5 million metric tons per year. After this time, coal output decreased progressively each year because of depletion of shallow coal resources, increase in the cost of mining, and difficulties related to the mining operation. Some mines were closed for environmental reasons.Productionofdomestic coal stoppedin2000. Coal is used in Taiwan for generating electric power and in the steel, cement, and petrochemical indus- tries. Around 77 percent of the coal Taiwanconsumes is used for generating power. Coal accounts for about 45 percent of Taiwan’s power production. In 2004, Taiwan consumed more than 54 million metric tons of coal, an amount that increased 27 percent after do- mestic coal production ceased. Because coalis no lon- ger mined domestically,Taiwan meets its demands for coal consumption through imports, mainly from In- donesia, Australia, and China. Petroleum and Natural Gas Petroleum and natural gas reserves of Taiwan are lo- cated in the northwest near the small city of Hsin-chu and the town of Miaoli. Petroleum and natural gas are produced mainly from land-based oil wells. In 2009, there were eighty-four oil- and gas-producing wells in Taiwan, all of which were concentrated in the western part of Taiwan. These wells, mostly gas-producing, were mainly located in Tiezhenshan, Chinshui, Chu- huangkeng, Yougheshan, and nearby areas. Offshore oil production began in 1980, in the oil-gas field of Changkan off the coast of Hsin-chu. Most of Taiwan’s crude-oil imports come from the Persian Gulf. West African countries are also impor- tant suppliers. To ensure against a disruption in sup- ply, Taiwan’s oil refiner regulations require mainte- nance ofstocksthatrepresent no fewerthan60 days of consumption. Refiner-held strategic petroleum stocks are common in Asia, and Taiwan’s policy is similar to Global Resources Taiwan • 1199 those of other Asian countries, namely Japan and South Korea. Most of the exploring, producing, im- porting, refining, and marketing of petroleum and natural gas is conducted by the Chinese Petroleum Corporation. Since 1987, however, privately owned and operated gas stations for marketing gasoline and diesel oilhavebeenallowed.Offshore areasintheTai- wan Strait have been explored for developing off- shore petroleum and gas operations. Sand and Gravel Taiwan has many riverbeds that provide sand, gravel, and rock for the construction industry. Approximately 90 percent of Taiwan’s sand and gravel comes from rivers. Sand-gravel is the most important raw mineral of Taiwan, and it ranks first in terms of output value of mineral raw material. Sand and gravel resources are classified into four groups: fluvial sand-gravel, terres- trial sand-gravel, rock fragments, and marine sand- gravel. Sand-gravel is produced in all sixteen counties of Taiwan. Sand and gravel yields the highest output value in Taiwan’s mineral industry. Taiwanhasagreat demand for sand and gravel. Ini- tially, exploitation was focused on the sand and gravel from rivers; this was expanded to sand and gravel and rock fragments from land and later sea resources. Rivers are dredged to collect sand and gravel. Tai- wan’s construction industry needs about 70 million cubic meters of sand and gravel per year. In 2000, Tai- wan began to import sand and gravel from China to meet its needs; almost one-third of market needs were met byimportsfrom China. In2006,export bansfrom China caused a shortage of sand andgravel in Taiwan, with an increase in costs up to 37 percent. Water Taiwan has many rivers, with origins in the mountain- ous central part of the island. There are 129 rivers in 1200 • Taiwan Global Resources A Taiwaneseuniversity student stands adjacent to her solar-powered car that can generate up to 1,800 watts. Taiwanhas become a leader in the solar-power industry. (AFP/Getty Images) Taiwan, all of which are short and steep, with small drainage basins and rapid water flow. Many of the rivers are tapped for hydroelectric power. The Cho- shui River, more than 160 kilometers long and the longest river in Taiwan, is the most heavily tapped for hydroelectricity. In one form or another, Taiwan is inundated with fresh water over the course of a year.Rainfallssteadilythroughout winter,followedby spring downpours and typhoons in summer. Approxi- mately 2,500 millimeters of rainfall are recorded an- nually. However, the geography of Taiwan, with its spectacular mountain ranges over a relatively small area of land, complicates water collection and stor- age. As severe climate change becomes a reality and begins to disrupt traditional weather patterns, it may affect water availability. Taiwan has water-intensive industries and farming. Of the 90 billion metric tons of water Taiwan receives as rain each year, about 65.6 billion become surface water,the majority of which quickly flows straight into the sea. About 14 billion metric tons of rainwater re- main on the island long enough to be used. More than 90 percent ofTaiwan’senergymustbeimported. The only domestic source of energy is hydroelectric- ity. Among the major hydroelectric facilities are those tapping the Choshui, Shihmen, and Taiwan rivers. Other Resources The Chung-yang Range and the eastern coastal range contain deposits of gold and copper. The Chinkua- shih gold mine in northern Taiwan was successful in the 1940’s, but mining operations were halted in 1988. Fongtian jade is a semiprecious stone that was once abundant in Taiwan and mined in the 1960’s and 1970’s. In early 1970’s, almost every Fongtian household was involved in mining or processing of Taiwan jade, making the area one of the richest places in Taiwan. Carelessness and indiscriminate blasting in search of quicker profits damaged the jade mines irreparably, and the industry went into decline in the mid-1970’s. About one-half of Taiwan is forested, but timber production is insufficient to meet domestic demand. The main timbers are oak, cedar, hemlock, bamboo, and rattan. Onshore and deep-sea fishing yield about 80 per- cent of total catch; the remainder comes from along the coast and from cultivated ponds. Mackerel and various types of tuna are the leading marine species caught. Limestone is also an important resource in Taiwan. More than 90 percent of limestone is used to make ce- ment; at one time, Taiwan ranked first in the world in cement production. C. J. Walsh Further Reading Copper, John F. Taiwan: State or Province? Boulder, Colo.: Westview Press, 2009. Edmonds, Richard Louis, and Steven M. Goldstein. Taiwan in the Twentieth Century: A Retrospective View. New York: Cambridge University Press, 2001. Harris, Paul G. Confronting Environmental Change in East and Southeast Asia: Eco-Politics, Foreign Policy, and Sustainable Development. London: Earthscan, 2005. Rubinstein, Murray A. Taiwan: A New History.Ex- panded ed. Armonk, N.Y.: M. E. Sharpe, 2007. Williams, Jack. Taiwan’s Environmental Struggle: Green Silicon Island. New York: Routledge, 2008. See also: Agricultural products; Agriculture indus- try; China; Coal; Hydroenergy; Marble; Sand and gravel; Wind energy. Takings law and eminent domain Categories: Government and resources; social, economic, and political issues Takings law refers to government appropriation of pri- vate property for public purposes through eminent do- main condemnation and regulatory takings, known as inverse condemnation. In the twenty-first century, takings law and eminent domain havebecomeincreas- ingly complex, and courts must grapple with how far governments can go in taking private property to achieve public purposes, which include natural re- source conservation. Background Governments are able to take full or partial title to, or permanently or temporarily occupy or control, pri- vate property for a public purpose by exercising the power of eminent domain, but this power is not un- limited. As early as the Magna Carta, private property owners in democratic societies enjoyed a bundle of property interests that wereprotected from unreason - Global Resources Takings law and eminent domain • 1201 able governmental interference. These protections appeared in the Fifth Amendment to the U.S. Consti- tution and in many state constitutions. One protec- tion requires the government to compensate prop- erty owners financially for lost property rights when exercising the power of eminent domain. In addition to appropriating property outright through condemnation and eminent domain taking, the government can affect private property rights through its police powers, such as zoning, subdivision regulations, and wetlands laws. The police powers allow the government to enact and impose laws, or- dinances, and regulations that limit the use of private property without just compensation, so long as these restrictions protect the public health, safety, and wel- fare. Historically, as the U.S. Supreme Court explained in the case of Village of Euclid v. Ambler Realty Co. (1926), police power restrictions may diminish the value of private property and are not considered “takings,” as long as they fall short of actual expropria- tion and there is no physical invasion of the property. However, during the twentieth century governments adopted and imposed more innovative regulations in order to preserve communities, protect the environ- ment, and limit growth. Because someoftheseregula- tions seriously infringed on private property owners’ ability to use and enjoy theirproperty,courts began to rule in inverse condemnation cases that the govern- mental regulations amount to a taking of private property rights for a public purpose without a formal governmental condemnation and that justcompensa- tion should be paid. Provisions One of the pivotal U.S. Supreme Court cases concern- ing takings law is Pennsylvania Coal v. Mahon (1922). The Court ruled that a regulation could impose a burden on a property owner that was onerous and comparable to the burden the property owner would face if eminent domain had been used. However, the court went on to state that a government regulation may no longer be deemed a legitimate exercise of the police power if it “goes too far.” The Mahon case applied a “beneficial use” standard in making its de- termination thatthe regulation in question destroyed previously existing beneficial rights, such that it be- came commercially impractical to continue mining coal. Although the Mahon decision determined that the regulation was a taking in violation of the Fifth Amendment, it did not require just compensation, as would have been required under an actual eminent domain taking, but instead granted equitable relief that prohibited the government from continuing to impose the law as written. The question of when a regulatory taking has oc- curred—and whether it is onerous to the property owner—has been a gray area in takings law. Several Supreme Court cases illustrate how determinations have been made. One of the earliest cases was Nectow v. City of Cambridge (1928). The Supreme Court, in ap- plying the Fifth Amendment takings clause to the city of Cambridge through the Fourteenth Amendment, ruled that when no practical use of property remains after imposition of a land-use regulation there is an unconstitutional infringement of property rights or a taking. The Court applied an economic value test in Penn Central Transportation Co. v. City of New York (1978) in which it decided that although a landmark regulation applied to the Penn Central building may have thwarted the developer’s maximum profit, the building still had economic value as offices and was not a regulatory taking. In Kaiser Aetna v. United States (1979), the Court stated that fundamentalrights asso- ciated with property ownership could not be dis- missed and ruled that a requirement for property owners to provide public access to a privatepond took away their property rights and constituted a taking. Nearly fifty years after the Mahon decision, prop- erty owners beganto seek monetary relief or just com- pensation in regulatory takings cases. Although both federal and state courts had ruled in many of the ear- lier cases that there had been regulatory takings, none of the decisions required just compensation. The Supreme Court entered the monetary relief de- bate, as to whether the appropriate remedy in regula- tory takings cases was just compensation or invalida- tion and rescissionoftheunconstitutional regulation, in the case of Agins v.City of Tiburon (1980). Moreover, the Agins decision adopted a new standard to deter- mine if imposition of a land-use regulation resulted in a taking. The Court ruled that there was a taking in the Agins case because the regulation in question did not “substantially advance legitimate state interests.” The Court ordered invalidation of the offending reg- ulation on the basis it did not want to “chill” govern- ment experimentation with innovative land-use regu- lations because oflegalactionthreats. In addition, the Court was reluctant to impose a monetary require - ment on a local government that might be lacking fis - cal resources to pay just compensation. 1202 • Takings law and eminent domain Global Resources In the Supreme Court case of San Diego Gas & Elec. Co. v. City of San Diego (1981) four dis- senters and one justice who concurred with portions of the dissent set forth a basic rule that would be applied in later regulatory tak- ing cases, requiring governments to pay just compensation for the takings. The Court dis- missed theSanDiegoGas case forlackofjurisdic- tion, but the five justices stated that, although the government could rescind an unconstitu- tional regulation, it should compensate the private property owner for any damages in- curred during the period that the regulation was in effect, thus establishing the concept of a compensable temporary taking. Moreover, the justices averred that if the regulation was not rescinded, thus resulting in a permanent regu- latory taking, the government should pay com- pensation just as it would for an eminent do- main taking. In Nollan v. California Coastal Commission (1987) the Supreme Court ruled that an exaction—a requirement imposed on a land- owner to provide a public access easement as a condition of receiving a rebuilding permit— was not related to a legitimate public purpose. The Court admonished the Commission for its overreaching regulation and stated that if it wanted to carry out its policy of making beaches publicly accessible through easements, it should exercise its eminent domain powers and pay just compensation. This was the first case in which the Supreme Court stated explicitly that just compensa- tion was an appropriate remedy in a regulatory takings case that would result in a permanent restriction on private-property rights. Two additional cases soon followed Nollan, and the Court continued to express its changed view regard- ing the appropriate remedy in a regulatory takings case. In 1988, the South Carolina legislature passed the Beachfront Management Act to limit construc- tion within critical coast-dune system areas that in- cluded David H. Lucas’s property. Lucas sued the commission and claimed that the restrictions denied him any “economically viable use of his land,” and thus made him deserving of compensation. Although Lucas won $1.2 million in compensation in a trial court, the South Carolina Supreme Court, on appeal, ruled that because the act was established to prevent serious public harm, the restrictions were not a regu - latory taking. Lucas appealed to the U.S. Supreme Court, which ruled that regulations restricting “all economically viable use” form a discrete category of takings that always require compensation. A case that had greater impact on regulations af- fecting natural resources was Dolan v. City of Tigard (1994). The Dolans petitioned for a building permit to increase the size of their business and parking. The city granted the permit but imposed an exaction that part of the Dolans’ property be dedicated to flood control and a pedestrian walkway. The Dolans sued, forcing the issue of whether government must dem- onstrate that the restrictions it was enforcing were di- rectly related to the problems they were supposed to address. The Court, ruling in favor of the Dolans, in- dicated that government must show that the restric- tions actually correct the problems created by devel- opment. This ruling created a criterion for regulatory takings that was much more stringent than had been applied in the previous thirty years. Global Resources Takings law and eminent domain • 1203 In this 1958 photograph, members of the Tuscarora American Indian tribe protest the proposed seizure of the tribe’s land by the government. (AP/Wide World Photos) As courts continued to struggle with making regu - latory takings determinations, the Supreme Court in Lingle v. Chevron U.S.A. (2005) modified the “substan- tially advances” test it had applied in past cases begin- ning with Agins. The Hawaii Supreme Court had ap- plied the Agins standard in the Lingle case and ruled that a gas station rent-control law constituted an un- constitutional taking. The U.S. Supreme Court stated that the appropriate standard was no longer the “sub- stantially advances” theory, but that takings should be considered based on several tests, including an ac- tual physical invasion, a Penn Central standard based on investment-backed expectations, a totalregulatory taking as in Lucas, or exactions as required in Nollan and Dolan. Again in 2005, the Supreme Court added another complication to takings and eminent domain law when it issued a controversial decision in the case of Kelo v. City of New London and ruled that government could use eminent domain powers to take private property for sale to a private developer as part of an urban renewal program. Susette Kelo and other pri- vate property owners refused to sell their property to the city of New London for an urban renewal and eco- nomic revitalization project. When the city exercised eminent domain andtooktheprivateowners’ proper- ties, the owners sued the city and claimed that the takings clause was violated because the sale of private property to a private developer did not constitute “public use” under the Fifth Amendment. The Su- preme Court was split 5-4 in its decision, but the ma- jority ruled that the city’s actions served a public pur- pose, and that the city was not attempting to benefit the private developers but, rather, the entire citizenry through implementation of its economic development plan, which would generate increased employment, tax revenues, and enhanced aesthetics. Although the condemned property was not developed for public use per se, the majority stated that the city’s plan for eco- nomic rejuvenation deserved deference. While the four dissenting justices strongly disagreed that taking private property for private economic development comported with the meaning of the “public use” com- ponent of the takingsclause,anewterm in the takings lexicon was born—“economic development taking.” Impact on Resource Use The changes in takings law and eminent domain in the United States have a global impact. The decisions in the Dolan and Lucas cases have direct ramifications for natural resource conservation and management, because many land-use restrictions are intended to promote improved environmental quality. At a time when environmental protection and conservation have become significant global issues, governing bod- ies in the United States face the dilemma of deciding whether to protect natural resources through strict regulations or forgo such restrictions to avoid costly litigation that does not necessarily have a predictable outcome. Moreover, takings law and eminent domain con- tinue to become more complex for those involved in making land-use planning decisions, as evidenced by the Kelo decision. The Kelo decision did not result in the city’s planned urban revitalization, as the private developer was not financially able to go forward with the development. In response to the Kelo decision, President George W. Bush issued an executive order in 2006 applicable to the federal government, and Congress proposed legislation applicable to states, us- ing federal funds that limited the use of eminent do- main by disallowing economic development takings that would transfer condemned property to private parties who might gain economically through such a transfer. In addition, in response to the Kelo decision, several states have made constitutional amendments and passed laws that place limits on the power of emi- nent domain and prohibit its use for private eco- nomic development. State courts have also decided economic development takings cases under state con- stitutional law in favor of the private property owners and against the private developers, including the Ohio Supreme Court decision in City of Norwood v. Horney (2005). To further complicate matters with respect to takings law, the case of Stop the Beach Renourishment v. Florida was argued before the U.S. Supreme Court on December 2, 2009. At issue was whether Florida’s plans to restore beaches along shorelines, which would result in changing the boundaries of private property, violated due process or amounted to a taking. Based on its Beach and Shore Preservation Act, the state of Florida planned to restore eroded beaches damaged by hurricanes by adding new sand to create public beaches. A Florida trial court held that the creation of the public beaches through restoration constituted an unconstitutional taking that required just compen- sation, as it prevented the private property owners from maintaining their own private beachfronts and took their rights to accreted land—land that is gradu - 1204 • Takings law and eminent domain Global Resources ally deposited by natural forces onto the private prop - erty. The Florida Supreme Court reversed the trial court and ruled that private property owners do not have property rights in accreted land and that the state could restore the beaches, thus modifying pri- vate property lines. The private property owners in the Stop the Beach Renourishment case requested the U.S. Supreme Court rule that the Florida Supreme Court made an uncompensated judicial taking of pri- vate property.IftheU.S.Supreme Court rules in favor of the private owners, thus deciding that the judicial branch of government can make judicial takings, courts may be more reluctant to uphold local and state decisions that attempt to preserve and restore natural resources. Carol A. Rolf Further Reading American Planning Association. Four Supreme Court Land-Use Decisions of 2005. Chicago: American Planning Association, 2005. Corace, Don. Government Pirates: The Assault on Private Property Rights and How We Can Fight It. New York: Harper, 2008. Epstein, Richard A. Supreme Neglect: How to Revive Con- stitutional Protection for Private Property. New York: Oxford University Press, 2008. Main, Carla. Bulldozed: “Kelo” Eminent Domain and the American Lust for Land. New York: Encounter Books, 2007. Malloy, Robin Paul. Private Property, Community Devel- opment, andEminentDomain.Williston, Vt.: Ashgate, 2008. Merriam, Dwight H. Eminent Domain Use and Abuse: “Kelo” in Context. Chicago: American Bar Associa- tion Section of State and Government Law, 2007. Paul, Ellen Frankel. Property Rights and Eminent Do- main. Piscataway, N.J.: Transaction, 2008. Porter, Douglas R. Eminent Domain: An Important Tool for Community Revitalization. Washington, D.C.: Ur- ban Land Institute, 2007. Ryskamp, John. The Eminent Domain Revolt: Changing Perceptions in a New Constitutional Epoch. New York: Algora, 2007. Schultz, David. Evicted! Property Rights and Eminent Do- main in America. Westport, Conn.: Praeger, 2009. See also: Conservation; Conservation biology; Eco - system services; Mineral resource ownership; Wet - lands. Talc Category: Mineral and other nonliving resources Where Found Talc is a metamorphic rock that occurs in foliated masses as well as in a massive form called soapstone. Major producers include China, South Korea, India, the United States (with Montana, Texas, Vermont, New York, and California the leading states), Finland, Brazil, and Japan. Primary Uses Talc is a widely used raw material. The primary uses for talc are in ceramics, paper, paint, roofing, plas- tics, rubber,refractory applications, cosmetics, house- insulating materials, insecticides, and lubricants. A similar mineral, pyrophyllite, is used in refratories, paint, and ceramics. Technical Definition Talc is a common, very soft, hydrous magnesium sili- cate mineral. The mineral is typically pale green, white, or grayish, with a greasy feel and pearly luster. The presence of iron turns it reddish or brown. Its specific gravity is 2.82. The related mineral pyrophyl- lite is a hydrous aluminum silicate and occurs in compact masses or foliated form. Description, Distribution, and Forms Talcisametamorphicrock that belongs to the layered silicate group of minerals in which continuous sheets of silicon dioxide molecules are linked together by magnesium atoms to form well-defined electrically neutral layers. The layers are held together by rela- tively weak forces, so the mineral is extremely soft mechanically. In fact, talc is the standard for softness at the bottom of the Mohs hardness scale; its hardness is one on a scale from one to ten, and it is easily scratched by a fingernail. The foliated appearance of talc is a direct consequence of the basic layered struc- ture of the mineral. The impure form of talc is known as steatite, or soapstone, the common name coming from the greasy or soapy feeling imparted when it is rubbed between the fingers. Soapstones are composed of talc, serpen- tine, and carbonates, representing original perido - tites that were altered at low temperatures by hydro - thermal solutions. When water and silica or carbon Global Resources Talc • 1205 . energy crises of 1973 and 1979; Oil shale and tar sands. 1196 • Synthetic Fuels Corporation Global Resources T Taiwan Categories: Countries; government and resources Few natural resources of significant. Taiwan is rich in both on- shore and offshore wind energy resources. An island off the coast of Taiwan, called P’eng-hu, has some of the best available wind resources in the world. Al- though Taiwan. coast of southern Taiwan, is situated on the line of conver- gence of the Philippine and Eurasian tectonic plates; therefore, stone of beautiful complexity can be found there. Rhodonite is a type of