• The Korean Journal of Air & Space Law and Policy
• /
• v.33 no.2
• /
• pp.345-366
• /
• 2018

Article 37 of the International Convention on Civil Aviation requires that rules should be adopted to keep in compliance with international standards and recommended practices established by ICAO. As SARPs are revised annually, each ICAO Member State needs to reflect the new content in its national aviation Acts in a timely manner. In recent years, data-driven international standards have been developed because of the important roles of aviation safety data and information-based legislation in accident prevention based on human factors. The Safety Management System and crew Fatigue Risk Management Systems were reviewed as examples of the result of data-driven rulemaking. The safety management system was adopted in 2013 with the introduction of Annex 19 and Chapter 5 of the relevant manual describes safety data collection and analysis systems. Through analysis of safety data and information, decision makers can make informed data-driven decisions. The Republic of Korea introduced Safety Management System in accordance with Article 58 of the Aviation Safety Act for all airlines, maintenance companies, and airport corporations. To support the SMS, both mandatory reporting and voluntary safety reporting systems need to be in place. Up until now, the standard of administrative penal dispensation for violations of the safety management system has been very weak. Various regulations have been developed and implemented in the United States and Europe for the proper legislation of the safety management system. In the wake of the crash of the Colgan aircraft, the US Aviation Safety Committee recommended the US Federal Aviation Administration to establish a system that can identify and manage pilot fatigue hazards. In 2010, a notice of proposed rulemaking was issued by the Federal Aviation Administration and in 2011, the final rule was passed. The legislation was applied to help differentiate risk based on flight according to factors such as the pilot's duty starting time, the availability of the auxiliary crew, and the class of the rest facility. Numerous amounts data and information were analyzed during the rulemaking process, and reflected in the resultant regulations. A cost-benefit analysis, based on the data of the previous 10 year period, was conducted before the final legislation was reached and it was concluded that the cost benefits are positive. The Republic of Korea also currently has a clause on aviation safety legislation related to crew fatigue risk, where an airline can choose either to conform to the traditional flight time limitation standard or fatigue risk management system. In the United States, specifically for the purpose of data-driven rulemaking, the Airline Rulemaking Committee was formed, and operates in this capacity. Considering the advantageous results of the ARC in the US, and the D4S in Europe, this is a system that should definitely be introduced in Korea as well. A cost-benefit analysis is necessary, and can serve to strengthen the resulting legislation. In order to improve the effectiveness of data-based legislation, it is necessary to have reinforcement of experts and through them prepare a more detailed checklist of relevant variables.

• The Korean Journal of Air & Space Law and Policy
• /
• v.27 no.1
• /
• pp.29-73
• /
• 2012

Aviation safety is the State and industry's top priority and more scientific approaches for fatigue management should be needed. There are lately various studies and regulation changes for crew fatigue management with ICAO, FAA and EASA. ICAO issued the provisions of fatigue management for flight crew since 1st edition, 1969, of Annex 6 operation of aircraft as a Standards and Recommended practice(SARPs). Unfortunately, there have been few changes and improvement to fatigue management provisions since the time they were first introduced. However the SARPs have been big changed lately. ICAO published guidance materials for development of prescriptive fatigue regulations through amendment 33A of Annex 6 Part 1 as applicable November 19th 2009. And then ICAO introduced additional amendment for using Fatigue Risk Management System (FRMS) with $35^{th}$ amendment in 2011. According to the Annex 6, the State of the operator shall establish a) regulations for flight time, flight duty period, duty period and rest period limitations and b) FRMS regulations. The Operator shall implement one of following 3 provisions a) flight time, flight duty period, duty period and rest period limitations within the prescriptive fatigue management regulations established by the State of the Operator; or b) a FRMS; or c) a combination of a) and b). U.S. FAA recently published several kinds of Advisory Circular about flightcrew fatigue. U.S. passed "Airline Safety and FAA Extension Act of 2010" into law on August 1st, 2010. This mandates all commercial air carriers to develop a FAA-acceptable Fatigue Risk Management Plan(FRMP) by October 31st, 2010. Also, on May 16, 2012, the FAA published a final rule(correction) entitled 'Flightcrew Member Duty and Rest Requirements; correction to amend its existing prescriptive regulations. The new requirements are required to implement same regulations for domestic, flag and supplemental operations from January 4, 2014. EASA introduced a Notice of Proposed Amendment (NPA) 2010-14 entitled "Draft opinion of the European Aviation Safety Agency for a Commission Regulation establishing the implementing rules on Flight and Duty Time Limitations and Rest Requirements for Commercial Air Transport with aeroplanes" on December 10, 2010. The purpose of this NPA is to develop and implement fatigue management for commercial air transport operations. Comparing with Korean and foreign regulations regarding fatigue management, the provisions of ICAO, FAA, EASA are more considering various fatigue factors and conditions. Korea regulations should be needed for some development of insufficiency points. In this thesis, I present the results of the comparative study between domestic and foreign regulations in respect of fatigue management crew member. Also, I suggest legal proposals for amendment of Korea Aviation act and Enforcement Regulations concerning fatigue management for crew members. I hope that this paper is helpful to change korea fatigue regulations, to enhance aviation safety, and to reduce the number of accidents relating to fatigue. Fatigue should be managed at all level such as regulators, experts, operators and pilots. Authority should change surveillance mind-set from regulatory auditor to expert adviser. Operators should identify various fatigue factors and consider to crew scheduling them. Crews should strongly manage both individual and duty-oriented fatigue issues.

• The Korean Journal of Air & Space Law and Policy
• /
• v.30 no.1
• /
• pp.31-64
• /
• 2015

The Chicago Convention and Annexes have become the basis of aviation safety regulations for every contracting state. Generally, aviation safety regulations refer to the SARPs provided in the Annexes of the Chicago Convention. In order to properly reflect international aviation safety regulations, constant studies of the aviation fields are of paramount importance. Treaties duly concluded and promulgated under the Constitution and the generally recognized rules of international law shall have the same effect as the domestic laws of the Republic of Korea. Each contracting state to the Chicago Convention should meet ICAO SARPs about AOC and FAOC. According to ICAO SARPs, Civil Aviation Authorities shall issue AOC to air carriers of the state, but don't require to issue for foreign air carrier. However some contracting states of the Chicago Convention issue FAOC and/or Operations Specifications for the foreign operators. This FAOC is being expanded from USA to the other contracting states. Foreign operators have doubly burden to implement AOC of the ICAO SARPs because FAOC is an additional requirement other than that prescribed by the ICAO SARPs In Article 33, the Chicago Convention stipulates that each contracting state shall recognize the validity of the certificates of airworthiness and licenses issued by other contracting states as long as they are equal to or above the minimum standards of the ICAO. In ICAO Annex 6, each contracting state shall recognize as valid an air operator certificate issued by another contracting state, provided that the requirements under which the certificate was issued are at least equal to the applicable Standards specified in this Annex. States shall establish a programme with procedures for the surveillance of operations in their territory by a foreign operator and for taking appropriate action when necessary to preserve safety. Consequently, it is submitted that the unilateral action of the states issuing the FAOC to the foreign air carriers of other states is against the Convention. Hence, I make some proposals on the FAOC as an example of comprehensive problem solving after comparative study with ICAO SARPs and the contracting state's regulations. Some issues must be improved and I have made amendment proposals to meet ICAO SARPs and to strengthen aviation development. Operators should be approved by FAOC at most 190 if all states require FAOC. Hence, it is highly recommended to eliminate the FAOC or reduce the restrictions it imposes. In certain compliance-related issues, delayed process shall not be permitted to flight operations. In addition, it is necessary for the ICAO to provide more unified and standardized guidelines in order to avoid confusion or bias regarding the arbitrary expansion of the FAOC. For all the issue mentioned above, I have studied the ICAO SARPs and some state's regulation regarding FAOC, and suggested some proposals on the FAOC as an example of comprehensive problem solving. I hope that this paper is 1) to help understanding about the international issue, 2) to help the improvement of korean aviation regulations, 3) to help compliance with international standards and to contribute to the promotion of aviation safety, in addition.

• The Korean Journal of Air & Space Law and Policy
• /
• v.31 no.2
• /
• pp.145-176
• /
• 2016

Aviation safety can be secured through regulations and policies of various areas and thorough execution of them on the field. Recently, for aviation safety management Korea is making efforts to prevent aviation accidents by taking various measures: such as selecting and promoting major strategic goals for each sector; establishing National Aviation Safety Program, including the Second Basic Plan for Aviation Policy; and improving aviation related legislations. Obstacle limitation surface is to be established and publicly notified to ensure safe take-off and landing as well as aviation safety during the circling of aircraft around airports. This study intends to review current aviation obstacle management system which was designed to make sure that buildings and structures do not exceed the height of obstacle limitation surface and identify its operating problems based on my field experience. Also, in this study, I would like to propose ways to improve the system in legal and regulatory aspects. Nowadays, due to the request of residents in the vicinity of airports, discussions and studies on aviational review are being actively carried out. Also, related ordinance and specific procedures will be established soon. However, in addition to this, I would like to propose the ways to improve shortcomings of current system caused by the lack of regulations and legislations for obstacle management. In order to execute obstacle limitation surface regulation, there has to be limits on constructing new buildings, causing real restriction for the residents living in the vicinity of airports on exercising their property rights. In this sense, it is regarded as a sensitive issue since a number of related civil complaints are filed and swift but accurate decision making is required. According to Aviation Act, currently airport operators are handling this task under the cooperation with local governments. Thus, administrative activities of local governments that have the authority to give permits for installation of buildings and structures are critically important. The law requires to carry out precise surveying of vast area and to report the outcome to the government every five years. However, there can be many problems, such as changes in the number of obstacles due to the error in the survey, or failure to apply for consultation with local governments on the exercise of construction permission. However, there is neither standards for allowable errors, preventive measures, nor penalty for the violation of appropriate procedures. As such, only follow-up measures can be taken. Nevertheless, once construction of a building is completed violating the obstacle limitation surface, practically it is difficult to take any measures, including the elimination of the building, because the owner of the building would have been following legal process for the construction by getting permit from the government. In order to address this problem, I believe penalty provision for the violation of Aviation Act needs to be added. Also, it is required to apply the same standards of allowable error stipulated in Building Act to precise surveying in the aviation field. Hence, I would like to propose the ways to improve current system in an effective manner.

• The Korean Journal of Air & Space Law and Policy
• /
• v.30 no.2
• /
• pp.201-248
• /
• 2015

In Korea the number of unlawful interference act on board aircrafts has been increased continuously according to the growth of aviation demand, and there were 55 incidents in 2000, followed by 354 incidents in 2014, and an average of 211 incidents a year over the past five years. In 1963, a number of states adopted the Convention on Offences and Certain Other Acts Committed on Board Aircraft (the Tokyo Convention 1963) as the first worldwide international legal instrument on aviation security. The Tokyo Convention took effect in 1969 and, shortly afterward, in 1970 the Convention for the Suppression of Unlawful Seizure of Aircraft(the Hague Convention 1970) was adopted, and the Convention for the Suppression of Unlawful Acts Against the Safety of Civil Aviation(the Montreal Convention 1971) was adopted in 1971. After 9/11 incidents in 2001, to amend and supplement the Montreal Convention 1971, the Convention on the Suppression of Unlawful Acts Relating to International Civil Aviation(the Beijing Convention 2010) was adopted in 2010, and to supplement the Hague Convention 1970, the Protocol Supplementary to the Convention for the Suppression of Unlawful Seizure of Aircraft(the Beijing Protocol 2010) was adopted in 2010. Since then, in response to increased cases of unruly behavior on board aircrafts which escalated in both severity and frequency,, the Montreal Protocol which is seen as an amendment to the Convention on Offences and Certain Other Acts Committed on Board Aircraft(the Tokyo Convention 1963) was adopted in 2014. Korea ratified the Tokyo Convention 1963, the Hague Convention 1970, the Montreal Convention 1971, the Montreal Supplementary Protocol 1988, and the Convention on the Marking of Plastic Explosive 1991 which have proven to be effective. Under the Tokyo Convention ratified in 1970, Korea further enacted the Aircraft Navigation Safety Act in 1974, as well as the Aviation Safety and Security Act that replaced the Aircraft Navigation Safety Act in August 2002. Meanwhile, the title of the Aviation Safety and Security Act was changed to the Aviation Security Act in April 2014. The Aviation Security Act is essentially an implementing legislation of the Tokyo Convention and Hague Convention. Also the language of the Aviation Security Act is generally broader than the unruly and disruptive behavior in Sections 1-3 of the model legislation in ICAO Circular 288. The Aviation Security Act has reflected the considerable parts of the implementation of national legislation under the Beijing Convention and Beijing Protocol 2010, and the Montreal Protocol 2014 that are the modernized international conventions relating to aviation security. However, in future, when these international conventions would come into effect and Korea would ratify them, the national legislation that should be amended or provided newly in the Aviation Security Act are as followings : The jurisdiction, the definition of 'in flight', the immunity from the actions against the aircraft commander, etc., the compulsory delivery of the offender by the aircraft commander, etc., the strengthening of penalty on the person breaking the law, the enlargement of application to the accomplice, and the observance of international convention. Among them, particularly the Korean legislation is silent on the scope of the jurisdiction. Therefore, in order for jurisdiction to be extended to the extra-territorial cases of unruly and disruptive offences, it is desirable that either the Aviation Security Act or the general Crime Codes should be revised. In conclusion, in order to meet the intelligent and diverse aviation threats, the Korean government should review closely the contents of international conventions relating to aviation security and the current ratification status of international conventions by each state, and make effort to improve the legislation relating to aviation security and the aviation security system for the ratification of international conventions and the implementation of national legislation under international conventions.

• The Korean Journal of Air & Space Law and Policy
• /
• v.29 no.1
• /
• pp.67-95
• /
• 2014

Some Contracting States of the Chicago Convention issue FAOC(Foreign Air Operator Certificate) and conduct various safety assessments for the safety of the foreign operators which operate to their state. These FAOC and safety audits on the foreign operators are being expanded to other parts of the world. While this trend is the strengthening measure of aviation safety resulting in the reduction of aircraft accident. FAOC also burdens the other contracting States to the Chicago Convention due to additional requirements and late permission. EASA(European Aviation Safety Agency) is a body governed by European Basic Regulation. EASA was set up in 2003 and conduct specific regulatory and executive tasks in the field of civil aviation safety and environmental protection. EASA's mission is to promote the highest common standards of safety and environmental protection in civil aviation. The task of the EASA has been expanded from airworthiness to air operations and currently includes the rulemaking and standardization of airworthiness, air crew, air operations, TCO, ATM/ANS safety oversight, aerodromes, etc. According to Implementing Rule, Commission Regulation(EU) No 452/2014, EASA has the mandate to issue safety authorizations to commercial air carriers from outside the EU as from 26 May 2014. Third country operators (TCO) flying to any of the 28 EU Member States and/or to 4 EFTA States (Iceland, Norway, Liechtenstein, Switzerland) must apply to EASA for a so called TCO authorization. EASA will only take over the safety-related part of foreign operator assessment. Operating permits will continue to be issued by the national authorities. A 30-month transition period ensures smooth implementation without interrupting international air operations of foreign air carriers to the EU/EASA. Operators who are currently flying to Europe can continue to do so, but must submit an application for a TCO authorization before 26 November 2014. After the transition period, which lasts until 26 November 2016, a valid TCO authorization will be a mandatory prerequisite, in the absence of which an operating permit cannot be issued by a Member State. The European TCO authorization regime does not differentiate between scheduled and non-scheduled commercial air transport operations in principle. All TCO with commercial air transport need to apply for a TCO authorization. Operators with a potential need of operating to the EU at some time in the near future are advised to apply for a TCO authorization in due course, even when the date of operations is unknown. For all the issue mentioned above, I have studied the function of EASA and EU Regulation including TCO Implementing Rule newly introduced, and suggested some proposals. I hope that this paper is 1) to help preparation of TCO authorization, 2) to help understanding about the international issue, 3) to help the improvement of korean aviation regulations and government organizations, 4) to help compliance with international standards and to contribute to the promotion of aviation safety, in addition.

• The Korean Journal of Air & Space Law and Policy
• /
• v.33 no.2
• /
• pp.225-266
• /
• 2018

In 2017, 1,252 cases of damages relief related to air passenger transport service were received by the Korea Consumer Agency, a 0.8% drop from 1,262 cases in 2016, the first decline since 2013. In 2017, 444 cases (35.4%) out of received cases of damages relief in the field of air passenger service received by the Korea Consumer Agency were agreed on, and out of cases that were not agreed on, the most number of 588 cases (47.0%) were concluded due to information provision and counseling, and 186 cases (14.9%) were applied to the mediation of the Consumer Dispute Mediation Committee. Major legislations that contain regulations for the damages relief and disputes resolution of air service consumers include the Aviation Business Act and the Consumer Fundamental Act, etc. The Aviation Business Act provides the establishment and implementation of damage relief procedure and handling plan, and the receiving and handling of request of damage relief by air transport businessman, and the notice of protection standard for air traffic users. The Consumer Fundamental Act provides the establishment and management of the consumer counseling organization, the damage relief by the Korea Consumer Agency, the consumer dispute mediation, and the enactment of the criteria for resolving consumer disputes. The procedures for damages relief of air service consumers include the receiving and handling of damages relief by air transport businessman, the counseling, and receiving and handling of damages relief by the Consumer Counseling Center, the advice of mutual agreement by the Korea Consumer Agency, and the dispute mediation system by the Consumer Dispute Mediation Committee. The current system of damage relief and dispute mediation for air service consumer have the problem in the exemption from obligation of establishment and implementation of damage relief plan by air transport businessman under the Aviation Business Act, the problem in the exemption from liability in case of nonfulfillment and delay of transport by aviation businessman under the criteria for resolving consumer disputes in the aviation sector, and the uppermost limit in procedure progress and completion of consumer dispute mediation under the Consumer Fundamental Act. Therefore, the improvement measurements of the relevant system for proper damage relief and smooth dispute mediation for air service consumer are to be suggested as follows: First is the maintenance of the relevant laws for damage relief of air service consumer. The exemption regulation from obligation of establishment and implementation of damage relief plan by air transport businessman under the Aviation Business Act shall be revised. To enhance the structualization and expertise of the relevant regulation for protection and damage relief of air service consumer, it will be necessary to prepare the separate legislation similar to the US Federal Regulation 14 CFR and EU Regulation EC Regulation 261/2004. Second is the improvement of criteria for resolving air service consumer disputes. For this, it will be necessary to investigate whether the cause of occurrence of exemption reason was force majeure, and distinguish the exemption from liability in case of nonfulfillment and delay of transport by aviation businessman under the criteria for resolving consumer disputes in the aviation sector, and revise the same as exemption reasons regulated under the air transport chapter of the Commercial Act and Montreal Convention 1999, and unify the compensation criteria for the nonfulfillment of transport that the substitute flight was provided and the delay of transport. Third is the reinforcement of information provision for damage relief of air service consumer. Aviation-related government agencies and concerned agencies should cooperate with airlines and airports to provide rapidly and clearly diverse information to the air traffic users, including laws and policies for damages relief of air service consumers. Fourth is the supplement to the effectiveness, etc. of consumer dispute mediation. If there is no sign of acceptance for dispute mediation, it is not fair to regard it as acceptance, therefore it will be necessary to add objection system. And if a dispute resolution is requested to another dispute settlement agency in addition to the Consumer Dispute Mediation Committee, it is excluded from the damage relief package, but it should be allowed for the party to choose a mediation agency. It will be necessary to devise the institutional measures to increase the completion rate of mediation so that the consumer dispute can be resolved efficiently through the mediation. Fifth is the introduction of the air service consumer arbitration system. A measure to supplement the limitations of the consumer dispute mediation system is to introduce the consumer arbitration system, but there are two measurements which are the introduction of the consumer arbitration under the Consumer Fundamental Act and the introduction of the consumer arbitration under the Arbitration Act. The latter measurement is considered to be appropriate. In conclusion, as a policy task, the government should prepare laws and system to enhance the prevention and relief of damages and protection of the rights and interests of air service consumers, and establish and implement the consumer-centric policy for the advancement of air service.

• Journal of the Korean Society of Radiology
• /
• v.9 no.4
• /
• pp.197-203
• /
• 2015

The Study on the patient is in a clinical researcher is not necessarily pose before after before after dwichim (Pronation) pose with neck-in-law (RAO, LAO) to chwalyoungbeop subjective evaluation experiment looked at objectively. Overview evaluation is a result of measuring the angle of the space between the vertebrae in PACS image $C_2{\sim}C_3$, $C_3{\sim}C_4$, $C_4{\sim}C_5$, $C_5{\sim}C_6$, $C_6{\sim}C_7$, in the angle of the $C_7{\sim}T_1$ $47.4^{\circ}{\pm}3.3$, $50.5^{\circ}{\pm}2.3$, $52.7^{\circ}{\pm}4.2$, $53.2^{\circ}{\pm}1.9$, $53.2^{\circ}{\pm}2.3$, $55.2^{\circ}{\pm}2.3$ was found to show increasing the angle between the ball and the median nerve in the lower neck sagittal grows. In a comparison of the measured angles in foraminal image was not significantly different (P>0.01). Subjective evaluation Recever Operation characteristic to the top, the upper neck hole (foramen) C2 ~ C3-up than conventional $45^{\circ}$ angle of the lower neck, $C_3{\sim}C_4$, were observed in the well $50^{\circ}$ $C_5{\sim}C_6$, $C_6{\sim}C_7$, the $C_7{\sim}T_1$ was observed at $55^{\circ}$ well observed experimental results video recession neck vertebrae son-in-law, son-in-law taken place in an objective evaluation, subjective evaluation of the upper neck after case could be observed at $50^{\circ}$, well in the lower neck $55^{\circ}$.

• Journal of the Korean Society of Surveying, Geodesy, Photogrammetry and Cartography
• /
• v.27 no.3
• /
• pp.311-321
• /
• 2009

The Nation Geodetic Reference System which presents a consistent location standard used in creating a map or developing national land is defined and managed by the law in a nation. Each nation had used its own geodetic system created by astronomical surveying until recently, when Geodetic Reference System(World Geodetic Reference System) has been developed and used to progress in space and satellite geodetic technologies. Korea also amended its geodetic law in December 2001, converting its national geodetic system whose reference an oval figure is Bessel ellipsoid into the World Geodetic Reference System which uses GRS80 ellipsoid as reference ellipsoid. Accordingly, the National Geography Information Institute improved law and systems related to the change for the effective conversion from its national geodetic system into the World Geodetic Reference System. In addition National geographic information institute of the results of various studies is drawn to the World Geodetic Reference System for switching technology-met some of the institutional foundation Despite of accordance with formalities, National geographic information institute, Ministry of Land, Transport and Maritime Affairs and some local government of the World Geodetic Reference System, and local government has or has not spread in public institutions. Therefore, in order to promote the switch to the World Geodetic Reference System, it is required to analyze current technical and institutional problems and obstacles of the switch to the World Geodetic Reference System and to present the resolutions and to establish policy to achieve them. Accordingly, for the promotion of the switch to the World Geodetic Reference System, this study analyzed the results of previous studies, the current state of the switch to the World Geodetic Reference System and the problems of the switch, and then offered technological and institutional supplements. Furthermore, it standardized the subject and type of the conversion, defined the scope of the tasks of the National Geographic Information Institute and its related organizations, and presented the policy direction for the overall use of the World Geodetic Reference System by 2010.

• Journal of the Korean Institute of Landscape Architecture
• /
• v.40 no.2
• /
• pp.86-96
• /
• 2012

Recently parks and green spaces contribute not only as a place of leisure but also for environmental welfare, social education, new jobs and $CO_2$ Emissions Reduction. Parks and green spaces are understood as urban infrastructures like roads and rivers. They are also included in social infrastructures like education, culture, and welfare facilities. These changes are applied to policies for parks and green spaces, many governments and local authorities make investments on them. The modification of policies for parks and green spaces in England is a good example about this trend From this view point, this study now deals with the changing process of policies, results, and evaluation. Some implications have been deducted. The first is the inducement in participation in policies and implementation of practices through policy papers. They are more practical than written laws which are composed of abstract sentences and generalizations. Secondly, the status of parks and green spaces is highly raised with the establishment of CABE Space and so on. This organization controls many different policies and programs related to parks and green spaces. Third is the funding for the improvement of parks and green spaces. Fourth, are the short-term measures, such as funding and management, and the long-term measures such as pursuing building of partnership and training. Fifth, the government strives to establish its partnership with the local authorities and communities through a spectrum of support in terms of information, monitoring, and developing good practices among networks. Finally, parks and green spaces are being addressed from multiple directions through the participation of numerous agents like voluntary groups, development companies, communities and so on. Recently, in Korea, the influences of the Sunset Law for Park Site, Landscape Architecture Law, Urban Forest Law, and other related ordinances have encouraged the review on the policies on parks and green spaces needed. However, there are not many studies about them. Owing to these reasons, the cases of England will he helpful.