Rainy Sky Research Articles

Incorporating theoretical and practical approaches to assess the amount of sunlight captured by a tilted surface in a tropical climate

Global solar radiation can theoretically be approximated in terms of tilt and azimuth of the surface regarding the impossibility of simultaneous measurement of solar radiation at various surface tilt and azimuth angles. Moreover, the random and anisotropic nature of diffuse radiation in a tropical climate makes it extremely difficult to estimate global solar radiation accurately as a function of surface tilt and azimuth angles. This study aims to develop a novel experimental and theoretical approach in the form of a computational network in order to determine a precise combined model integrated with global horizontal solar radiation to evaluate global tilted solar radiation in a tropical climate. Obtained results revealed that precisely estimation of the global tilted solar radiation was possible, by combining geometric factors for the tilted beam solar radiation, a combination of Gueymard and Louche models for the tilted diffuse solar radiation, and isotropic ground reflectance model for the ground reflected radiation, along with global horizontal solar radiation. It was observed that the accuracy of the model developed was higher for the partly sunny sky compared to the cloudy and rainy sky, estimates were more accurate on south-facing surfaces, and the model's accuracy declined with the increasing tilt angle of the surface. The statistical analysis exhibited excellent agreement between the measured data and simulation results, considering the value of normalized mean absolute error (nMAE %), normalized root mean squared error (nRMSE %), and mean absolute percentage error (MAPE %), which were in the ranges 0.22–0.94, 0.27–1.11, and 0.23–1.02, respectively for estimating global tilted solar radiation in various regions of Peninsular Malaysia, and they were respectively found in the range of 10.2–27.5%, 16.1–38.9%, and 6.0–17.8%, for evaluating the monthly optimum tilt angle towards the south, that leads to a loss of solar energy from 1.3 to 5.4 kWh/m2/year in Peninsular Malaysia. This search revealed that the experimental and theoretical approach employed in this study can be extended to more climatic regions.

Comparative Study of the 60 GHz and 118 GHz Oxygen Absorption Bands for Sounding Sea Surface Barometric Pressure

The 60 GHz and 118 GHz oxygen absorption bands are prominent in the passive microwave remote sensing of atmospheric temperature, and also can be used for sounding sea surface barometric pressure (SSP). Microwave Temperature Sounder II (MWTS-II) has 13 channels in the 60 GHz band, and Microwave Humidity and Temperature Sounder (MWHTS) has 8 channels in the 118 GHz band. They are both carried on Fengyun-3C Satellite (FY-3C) and Fengyun-3D Satellite (FY-3D), which provide measurements for comparing the retrieval accuracies of SSP using 60 GHz and 118 GHz bands. In this study, based on the weighting functions for MWHTS and MWTS-II, the 60 GHz and 118 GHz channel combinations representing 60 GHz and 118 GHz are established, respectively, and the retrieval accuracies of SSP from these two channel combinations are compared in different weather conditions. The experimental results show that the retrieval accuracy of SSP at 60 GHz is higher than that of 118 GHz in clear, cloudy, and rainy sky conditions. In addition, the retrieval experiments of SSP from MWTS-II and MWHTS are also carried out, and the experimental results show that the retrieval accuracy of SSP from MWTS-II is higher. The comparative study of the 60 GHz and 118 GHz for sounding SSP can provide support for the theoretical study of microwave remote sensing of SSP with practical measurements, and further contribute to understand the performance of 60 GHz and 118 GHz in atmospheric sounding.

Determination of sky status by ground based radiometric data analysis

Objectives: To predict meteorological phenomena such as rain events from sky status during rainy and non-rainy periods. Methods: The method used here is based on brightness temperature ratio measurement at two different frequencies, namely 23.8 GHz and 30 GHz respectively, using ground based dual frequency radiometric data. The ratios of brightness temperature readings obtained by the dual-frequency radiometer at the two above mentioned frequencies are calculated for each simultaneously-taken pair of measurements. Data obtained by the authors for the year 2009 at Cachoeira Paulista in Brazil has been used for analysis. Findings: The major results obtained from the analysis of data collected over a continuous period of seven months are used to construct corresponding histograms and cumulative count graphs of brightness temperature ratios. The histograms and graphs clearly show three peak values that could be interpreted as thresholds between clear sky, cloudy sky and rainy sky conditions respectively. Novelty: The study implements detection of rain events from sky status during rainy and non-rainy periods using peak brightness temperature values obtained from graphs generated using the observation data. The outlined technique can therefore be used to clearly determine sky conditions and accurately predict rain phenomena. The ratio of brightness temperatures at the two frequencies is a unique parameter which is critical to the successful estimation of rain from sky status. The results agree well with multi-channel radiometric data obtained by other researchers at lower frequencies. Keywords: sky status; microwave; millimeter wave; dual frequency radiometer; brightness temperature; rainfall

Developing a relational law of contracts: striking a balance between abstraction and contextualism

AbstractRelational contract theory holds that the interpretation of a contract must take full account of the context and surrounding circumstances of the parties’ bargain so as to give effect to their respective intentions. This paper argues that if a relational treatment of contracts is to be institutionalised, in the sense of being utilised in a contract dispute to determine and give effect to the parties’ intentions, then it must operate at an abstract level. That is to say, rather than using relevant context to determine what the actual parties intended in the circumstances at hand, the contextualist enquiry should ascertain the relevant context by reference to what the parties would have agreed to in the circumstances, had they properly reflected on what their self-interest requires. I discuss the merits of this proposition by reference to a number of appellate judgments, which already endorse contextualism as a response to contractual ambiguity, and I ultimately apply it to the Supreme Court's judgment in Rainy Sky SA v Kookmin Bank.

A Sea Change in the Law of Contract Interpretation?

This article challenges the recent extrajudicial argument of Sir Geoffrey Vos, Chancellor of the High Court of England and Wales, that there has been a "distinct sea change" in the law of contract interpretation as a result of the United Kingdom Supreme Court's decisions in Rainy Sky SA v Kookmin Bank, Arnold v Britton and Wood v Capita Insurance Services Ltd. He suggests that these decisions have the effect that Lord Hoffmann's well-known restatement of the law in Investors Compensation Scheme Ltd v West Bromwich Building Society, particularly his Lordship's fourth and fifth principles, no longer represent the law. In his view, the position now is that a court must give the words of a contract their plain meaning except "in a most exceptional case or a case of obvious absurdity". However, Professor McLauchlan argues that Sir Geoffrey reads more into the decisions than is warranted by the Supreme Court's reasoning and that Lord Hoffmann's restatement has survived largely unscathed. In substance, the reasoning spelt out what was either explicit or implicit in the restatement in the first place.

A Sea Change in the Law of Contract Interpretation?

This article challenges the recent extra-judicial argument of Sir Geoffrey Vos, Chancellor of the High Court of England and Wales, that there has been a “distinct sea change” in the law of contract interpretation as a result of the UK Supreme Court’s decisions in Rainy Sky SA v Kookmin Bank, Arnold v Britton and Wood v Capita Insurance Services Ltd. He suggests that these decisions have the effect that Lord Hoffmann’s well-known restatement of the law in Investors Compensation Scheme Ltd v West Bromwich Building Society, particularly his Lordship’s fourth and fifth principles, no longer represent the law. In his view, the position now is that a court must give the words of a contract their plain meaning except “in a most exceptional case or a case of obvious absurdity”. However, Professor McLauchlan argues that Sir Geoffrey reads more into the decisions than is warranted by the Supreme Court’s reasoning and that Lord Hoffmann’s restatement has survived largely unscathed. In substance, the reasoning spelt out what was either explicit or implicit in the restatement in the first place.

Optimal joint subcarrier and power allocation for MISO-NOMA satellite networks

In this paper, we propose a novel MISO multi-spot-beam satellite system design based on jointly optimizing subcarrier and power allocation for the downlink of a power domain non-orthogonal multiple access (PD-NOMA) network. The proposed non-convex NP-hard optimization problem minimizes the total transmit power taking into account subcarrier and transmit power constraints. An alternating method is used to solve this problem. For a fixed power allocation, we update the integer nonlinear programming (INLP) subcarrier allocation by using NOMAD toolbox. For a given subcarrier assignment, in order to update the transmit power values, we use the successive convex approximation approach (SCA). In addition, the proposed problem is solved by using the optimal method called “Monotonic Optimization” in order to find the optimality gap of the alternating method. Simulation results show that the total transmit power by applying the alternating method is close to the total transmit power by applying the monotonic approach. Moreover, we observe that the MISO and PD-NOMA techniques reduce the total transmit power of the MISO multi-spot-beam satellite system by approximately 20% with respect to the SISO and OMA techniques and the effectiveness of the proposed scenario and methods is considered in clear and rainy sky situations.

Good Death

Good Death

A Versatile Solar and Electric Water Distiller

Abstract— The present paper discusses the feasibility and the features of a newly designed portable water desalinator/distiller. The goal is to design a small unit for desalinating or distilling brackish or soiled water. The proposed desalinator/distiller is a hybrid system that uses two sources of energy, namely: solar and electrical. It relies on solar energy when being used at locations where electricity is expensive or inaccessible. On the other hand, it uses electric energy when sunshine is unavailable for considerable periods of time, such as under rainy or cloudy skies, or during winter seasons when the sun radiation is weak or not enough to evaporate water. This innovative project is aimed to benefit communities in rural villages, long journey travelers in deserts and arid mountains, people living alongside polluted rivers and lakes, and people living in refugees’ camps. It can also benefit people with hard water supplies. The paper investigates and discusses the proposed hybrid desalinator/distiller (HDD). The work presented is based entirely on the work carried out by final year electrical engineering students, during their capstone design project. The project work, presented, is a manifestation of the students learning during previous semesters. It puts into practice the application of thermal and heat transfer principles, that the student learned in earlier courses.
 
 Index Terms—Desalination,desalinator,distiller,solar still,solar energy.

OFF-GRID TINY HOUSE SMART RESIDENTIAL ENERGY MANAGEMENT SYSTEM

INTRODUCTION Students at California State University (CSU), Chico designed, built, and tested an off-grid solar powered tiny house and competed in the 2016 Sacramento Municipal Utility District's (SMUD) Tiny House Competition. Top tier research institutions, predominantly undergraduate universities, and community colleges from all over California competed against one another in a variety of performance and aesthetic events in SMUD's first ever competition. One of the main goals of the CSU, Chico's Tiny House was to design and implement an autonomous energy management system to maximize energy capture, use, and efficiency and provide a seamless, comfortable, and uninterrupted indoor living environment. This system, smart residential energy management system (SREMS), was designed to monitor and sense solar energy collected and stored, indoor heating and cooling loads, occupant cooking and personal water heating needs, and electrical outlets and to determine and allow energy related activities given the amount of stored energy. Thermodynamic and heat transfer models were developed to predict heating, cooling, and appliance requirements. These models were used to size the solar array, battery storage, and appliances. SREMS was installed in the tiny house and its performance was tested and validated during the week long SMUD Tiny House competition. Results showed close correlation with the predicted energy requirements of the models, and the tiny house maintained net-zero energy use even during overcast and rainy skies throughout the three-day event. The CSU, Chico team won best control system and best technology at the statewide event. This paper describes the design, installation and testing results of CSU, Chico's Tiny House SREMS.

Has the Rainy Sky Dried Up? Arnold v Britton and Commercial Interpretation

Has the Rainy Sky Dried Up? <i>Arnold v Britton</i> and Commercial Interpretation

Rent review 2014

Purpose – The purpose of this legal update is to examine the recent case law relating to rent review in England and Wales. The paper argues that as rent terms have reduced in length, and as market conditions have tended to produce nil-uplifts, there have been relatively few review cases before the court. Cases that reach court tend to fall into two broad categories: contractual interpretation and challenges to third-party determination. Design/methodology/approach – Review and analysis of case law in England and Wales. Findings – There are no special rules for interpreting rent review clauses. The court's approach to contractual interpretation follows House of Lords and Supreme Court rulings culminating in Rainy Sky SA v Kookmin Bank (2011). There are also very limited circumstances in which the court will set aside an arbitrator's award, informed by a policy that favours upholding arbitration awards as a quick and cost-effective way to settle rent review disputes. Practical implications – Rent review clauses must be interpreted in accordance with the normal rules of contractual interpretation. The court is unlikely to be swayed by submissions asserting the “general purpose” of rent review. Originality/value – This is an original analysis of case law.

Belgian Perspective on Rainy Sky S.A. and Others (Appellants) v. Kookmin Bank (Respondent)

Abstract: In Belgian law, a subjective interpretation of contracts prevails: the common intention of the parties is the vital criterion that governs the construction of agreements. In England the system is more objective, which means the meaning which the document would convey to a reasonable person predominates in matters of contractual interpretation. However, an in-depth analysis of the case Rainy Sky S. A. and others v. Kookmin Bank shows that, in practice, the two systems are more alike than might seem at first sight.

Is the Plain Meaning Approach to Construction of “Unambiguous Words” in Contracts Still Alive in the English Courts?

Several pronouncements from all the three reasoned judgments in the recent appeals of Rainy Sky SA v. Kookmin Bank have essentially answered the question raised above in the affirmative. Two of the judgments take the view that clear and unambiguous language of contracts means what it says, and must be applied accordingly. For the third, however, the court should apply the language unless the application will produce an extremely unreasonable result. This article seeks to evaluate the soundness of these plain meaning approaches to construction in the light of Investors Compensation Scheme Ltd v. West Bromwich Society and selected subsequent decisions.

Overview: Economic and Safety Regulation

The Supreme Court decided 15 cases involving economic and safety regulation in the 2011-12 legal year. Two cases involved commercial disputes. In Rainy Sky SA and others v Kookmin Bank,1 the Supreme Court reviewed principles of contract interpretation. In weighing two possible constructions of an ambiguous provision in a commercial contract, the SupremeCourt reinforced the principle that it is generally appropriate to choose the interpretation that is consistent with `business common sense'. Thus, to determine what the parties intended contract language to mean, courts may look to the commercial purpose of the agreement. In SerVaas Incorporated v Rafidian Bank and others,2 the Supreme Court addressed the scope of the commercial activity exception to sovereign immunity. According to a UK-wide statute, judgments may be enforced against state property that is `in use or intended for use for commercial purposes'.3 SerVaas obtained a default judgment in France against the Iraqi government in connection with a commercial contract and sought to enforce the judgment in England through a third party debt order over funds Rafidian Bank owed to Iraq. The Iraqi government argued successfully that the funds did not fall into the commercial activity exception because it did not intend to use Rafidian's funds for any commercial purpose. The Supreme Court observed that the origins of the underlying debt were irrelevant in determining whether the funds were `in use' for commercial purposes. The Supreme Court issued six decisions related to employment law, including three regarding workplace discrimination. In Russell and others v Transocean International Resources Limited and others,4 the Supreme Court examined whether the Working Time Regulations 1998 required that offshore workers in the oil and gas industry receive additional paid leave. Offshore employees generally alternate between two weeks working offshore and two weeks of onshore leave and

More Construction Controversy

This article discusses two important developments in the law of contract interpretation since the authors’ earlier article in (2011) 28 JCL 101. The first is the decision of the High Court of Australia to decline special leave to appeal from the decision of the NSW Court of Appeal in Jireh International Pty Ltd v Western Export Services Inc and also to take the unusual step of publishing the reasons for doing so. The second is the decision of the United Kingdom Supreme Court in Rainy Sky SA v Kookmin Bank. While at first sight the two cases seem to be at opposing ends of the literal-contextual spectrum of approaches to contract interpretation, closer analysis reveals that they both affirm principles that are inconsistent with Lord Hoffmann’s well-known restatement in the ICS case insofar as they employ the concept of ambiguity as a gateway or limiting device: in Jireh to limit regard to evidence of surrounding circumstances; in Rainy Sky, to limit regard to considerations of business common sense.

A Case Study on Repayment Guarantee for Export of Ships - Rainy Sky SA v. Kookmin Bank Case -

A Case Study on Repayment Guarantee for Export of Ships - Rainy Sky SA v. Kookmin Bank Case -

Commercial Purpose and Business Common Sense in Contractual Interpretation

What is the role to be played by considerations of business common sense in determining what the parties meant? In a pithy and unanimous judgment, Lord Clarke writing for the Supreme Court in Rainy Sky SA v Kookmin Bank1 held that where a term of a contract is open to more than one interpretation, one should adopt the interpretation that is most consistent with business common sense. This case is significant: not only does it shed light on when and how business common sense can be deployed by the courts, the dicta can be read as an important qualification of the circumstances in which courts can depart from the clear and unambiguous meaning of the words in a contract in order to give effect to its commercial purpose or to make the contract more commercially sensible. Thus, the fifth principle of interpretation enunciated by Lord Hoffmann in Investors Compensation Scheme Ltd v West Bromwich Building Society2 ('ICS') may have to be carefully applied in light of the qualified approach in Rainy Sky.

The Role of ‘Business Common Sense’ in the Construction of Commercial Contracts

The Supreme Court's decision in Rainy Sky SA &amp; Ors v Kookmin Bank re-emphasises that the ultimate aim of construing a contractual provision is to ascertain what the parties meant by the language used, based on what a reasonable person would have understood the parties to have meant; and that the courts can adopt the construction which is most consistent with commercial common sense. This article examines whether the judgment means that, where there is an ambiguous term, the court can apply the ''commercially sensible'' test before (or instead of) the ''reasonable person'' test.

Identification of rainy periods from ground based microwave radiometry

In this paper the authors present the results of a study aiming at detecting rainy data in measurements collected by a dual band ground-based radiometer.The proposed criterion is based on the ratio of the brightness temperatures observed in the 20–30 GHz band without need of any ancillary information. A major result obtained from the probability density of the ratio computed over one month of data is the identification of threshold values between clear sky, cloudy sky and rainy sky, respectively. A linear fit performed by using radiometric data and concurrent rain gauge measurements shows a correlation coefficient equal to 0.56 between the temperature ratio and the observed precipitation.