Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
Spikes K

Their obfuscation and the use of spikes is antiethical to the ethic of intellectual integrity, 

TORSON 13
“Debate and the Virtue of Intellectual Integrity by Adam Torson” March 25th, 2013.  By Victory Briefs. http://vbriefly.com/2013/03/25/20133debate-and-the-virtue-of-intellectual-integrity-by-adam-torson/NB
Against Purposeful Obfuscation Too often in debate, strategy devolves into sophistry. Debaters utilize
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as a very strange outcome in any debate event worthy of the name.

Intellectual integrity is the biggest impact- it’s the point of debate. 

TORSON 13
“Debate and the Virtue of Intellectual Integrity by Adam Torson” March 25th, 2013.  By Victory Briefs. http://vbriefly.com/2013/03/25/20133debate-and-the-virtue-of-intellectual-integrity-by-adam-torson/NB
Intellectual integrity denotes a commitment to the honest pursuit of truth through openness to evidence
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I encourage the examination of those practices through the lens of intellectual integrity.

Reject the 1AC’s use of spikes to embrace argumentative responsibility- you know what you did wrong and know you better own up to it. 

TORSON 13
“Debate and the Virtue of Intellectual Integrity by Adam Torson” March 25th, 2013.  By Victory Briefs. http://vbriefly.com/2013/03/25/20133debate-and-the-virtue-of-intellectual-integrity-by-adam-torson/NB
What We Can Do About It¶ Students¶ I encourage debaters to embrace the
AND

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
A. INTERPRETATION: Debaters must disclose all broken cases (ACs, NCs, DAs, CPs, and kritiks) on the NDCA wiki under their own name at least 1 hour before the round. In this disclosure, they must post cites, tags, and first three and last three words of all cards read. Debaters may begin disclosing at any point during the season, but they must disclose all broken cases at least an hour before this round in order to meet my interp. They must disclose regardless of whether the tournament requires disclosure. 

B. VIOLATION: They don’t disclose. They didn’t disclose an hour before this round. I have screenshots from before the round.

C. STANDARDS: 

Clash

Strat Skew: 

Academic Integrity

D. VOTERS:

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
A) INTERPRETATION- All debate positions must only contain secular arguments, or arguments that are not warranted by religious beliefs, UNLESS the debater presenting the position receives consent from the audience, judge(s), and opponent before the round. Standards clarify the spirit of the interp – don’t let them make dumb I meets like “Buddhism is an idea, not a religious figure” because theory establishes precedent by excluding actual abuse on a case-by-case basis, not by establishing on textual rule for every round.

B) VIOLATION- 

C) STANDARDS-

1. Judge Impartiality-  

Empirics prove – arguments appealing to religion trade off with rational evaluation of arguments. This effect is so widespread that some courts have even banned religious appeals

MILLER 06
 Miller and Bornstein 6 (Monica Miller University of Nevada, Reno; Brian H. Bornstein, University of Nebraska-Lincoln)“The Use of Religion in Death Penalty Sentencing Trials” University of Nebraska - Lincoln DigitalCommons@University of Nebraska - Lincoln Faculty Publications, Department of Psychology 10/21 AT
Attorneys who use religious appeals and testimony believe they will be influential, and much
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is key to fairness since it takes debate out of the debaters’ hands.

2. Resolvability 

D) VOTERS

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
A. INTERPRETATION: Debaters must not make their opponent ask in cross-ex for theory violations and deny the neg one conditional route to the ballot and claim that the theory on affirmative spikes is drop the argument and claim that the aff may re-evaluate offense on T under their interp. 

B. VIOLATION: 

C. STANDARDS: 

a. Advocacy shift
b. Theoretical Ground
c. Value of CX
d. norms setting
e. reciprocity
D. VOTERS:

Tournament: Harvard | Round: 2 | Opponent: Harrison MZ | Judge: Chris Vincent
The standard is minimizing existential risk.

1. Extinction is a prior issue to any alternative framework – Bostrom 11.
   Nick Bostrom Professor, Faculty of Philosophy, Oxford University www.nickbostrom.com Published in the Journal of Evolution and Technology, Vol. 9, No. 1 (2002). (First version: 2001)
   These reflections on moral uncertainty suggest an alternative, complementary way of looking at existential
   AND
   of value. To do this, we must prevent any existential catastrophe.

2. Adopt a parliamentary model to account for moral uncertainty. This entails minimizing existential risks –even if their framework is true – Bostrom 9.
Bostrom, Nick (Existentialist of a different sort). “Moral uncertainty – toward a solution?” 1 January 2009. http://www.overcomingbias.com/2009/01/moral-uncertainty-towards-a-solution.htmlVR
It seems people are overconfident about their moral beliefs. But how should one reason
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don’t infringe too much on what other major moral theories deem centrally important.

3. Rational capacity connects people across time and makes willing extinction contradictory. Humanity has a right to exist— anything else excludes infinite future generations, which outweighs their impacts on scope. Prefer this evidence – it establishes our standard as a meta-framing issue and takes their entire framework into account – Cerutti 14.
Furio, Professor of Political Philosophy emeritus at the University of Florence and Adjunct Professor at the Scuola superiore Sant’Anna, Pisa. In the last fifteen years, Cerutti has been aVisiting Professor at Harvard, the Universit´e de Paris 8, the Humboldt Universit ¨at zu Berlin, the London School of Economics and Political Science,(China Foreign Affairs University), Beijing, and Stanford University in Florence. Beyond the publications quoted in this article, Cerutti has written widely on the political identity of the Europeans and the legitimacy of the European Union (last publication: Debating Political Identity and Legitimacy in the European Union, ed. with S. Lucarelli and V. Schmidt, Routledge: London 2011), “Humankind’s First Fundamental Right: Survival,” Constellations, 2014
I have explained elsewhere9 why survival rather than justice is the leading category of a
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everybody, not just to the practitioners of academic philosophy Schulphilosophie.

4. Pain provides a metric for why oppression is bad. 

Gray 09
 Gray, James W. "An Argument for Moral Realism." Ethical Realism. N.p., 07 Oct. 2009. Web. 04 Sept. 2015. https://ethicalrealism.wordpress.com/2009/10/07/an-argument-for-moral-realism/. MA in philosophy from San Jose State University (2008)
If we have evidence that anything in particular has intrinsic value, then we also
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attempt to show that the alternatives are less justified in the next section.

5. Talking about extinction scenarios – allows us to resist the biopolitical power of the state and unites us. 

Schatz 12  
JL, Binghamton U, "The Importance of Apocalypse: The Value of End-­‐Of-­‐ The-­‐World Politics While Advancing Ecocriticism," The Journal of Ecocriticism: Vol 4, No 2 (2012) KB
Any hesitancy to deploy images of apocalypse out of the risk of acting in a
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where multitudes, and not governments, guide the fate of the planet.

Tournament: Harvard | Round: 2 | Opponent: Harrison MZ | Judge: Chris Vincent
Public colleges and universities in the United States ought not restrict any constitutionally protected free speech except speech that denies the existence and or threat of human made climate change.

Lavik 16
 Lavik, Trygve. “Climate change denial, freedom of speech and global justice”. Nordic Journal of Applied Ethics. Department of Philosophy, University of Bergen. http://www.ntnu.no/ojs/index.php/etikk_i_praksis/article/view/1923/1928. 2016 LBE
In this paper I claim that there are moral reasons for making climate denialism illegal
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and that this is an argument for a statutory ban on climate denialism.

Universities are key - students are unable to become members of society who actively combat the harms of climate change. The counterplan solves.

Valentine 14
 Valentine, Katie. “Parents Blast Climate Denial in Schools: ‘You Have To Teach Real Science’”. ThinkProgress.com. https://thinkprogress.org/parents-blast-climate-denial-in-schools-you-have-to-teach-real-science-86b390e7fa86#.qe7r80iyj. 7/10/14 LBE
But several groups that are concerned about the future of climate science education in the
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scientists think global warming is happening,” compared to 17 percent of adults.

Climate change denial is constitutionally protected speech regardless of its falsity

Olsen 15
 “SHOULD CLIMATE CHANGE DENIERS BE PROSECUTED?”, Walter Olsen 10/1/15 AT 5:17 PM,  A senior fellow at the Cato Institute ’s Center for Constitutional Studies, Newsweek OR
In June, I took note of Senator Sheldon Whitehouse’s (D-R.
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) a dangerous power to stifle advocacy in debates that it considers settled.

Climate change denial is preventing tangible change.

Lavik 2
 Lavik, Trygve. “Climate change denial, freedom of speech and global justice”. Nordic Journal of Applied Ethics. Department of Philosophy, University of Bergen. http://www.ntnu.no/ojs/index.php/etikk_i_praksis/article/view/1923/1928. 2016 LBE
George Monbiot (a recognized environmentalist and author) writes that “the professional denial
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act. However, there are many objections to this line of reasoning. 

University’s have a uniquely key role in fighting climate change.

Snibbe 15
 Kris Snibbe, "Colleges have ‘special’ role in fighting climate change," Harvard Gazette, 3/17/2015
In an address to faculty and students at Tsinghua University today, Harvard President Drew
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answer the big questions ultimately will yield substantive solutions to this global challenge.

Proliferation of fake news such as climate change is a hoax leads to authoritarianism and provides a pretext for violence – turns the AC.

Liasson 16
(Mara Liasson, National political correspondent for NPR, “Donald Trump: Strong Leader Or Dangerous Authoritarian?” 12-12-16, http://www.npr.org/2016/12/12/505205197/is-donald-trump-a-threat-to-democracy)
Then there's the ongoing debate about Trump's constant stream of statements that have no basis
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for example, in elections, that strengthens the hand of the authoritarian."

Corporations fund efforts to sow doubt and lies with tobacco smoke and climate change.

Lavik 16
 Lavik, Trygve. “Climate change denial, freedom of speech and global justice”. Nordic Journal of Applied Ethics. Department of Philosophy, University of Bergen. http://www.ntnu.no/ojs/index.php/etikk_i_praksis/article/view/1923/1928. 2016 LBE
This dinner party is an analogy to the climate debate in the public. And
AND
newspapers, or participates in the climate denial blogosphere, and so on.

Turns the aff – Giroux literally says neoliberalism is a tool used to cause oppression since corporations prefer profit over morals – and this is a classic example, 

Climate change outweighs on structural certainty of extinction –if we ignore climate change it is certain to permanently destroy civilization – experts agree it outweighs and turns every other impact

Scranton 13
(Roy Scranton's scholarship and essays have been published in Contemporary Literature, Theory and Event, the New York Times, Boston Review; co-editor of Fire and Forget: Short Stories from the Long War, an anthology of literary fiction by veterans of Iraq and Afghanistan; PhD candidate in English at Princeton University.) “Learning How to Die in the Anthropocene” NYT November 10, 2013 OR
This March, Admiral Samuel J. Locklear III, the commander of the United
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be survival in a world unrecognizably different from the one we have inhabited.

Prefer it – only this explicitly compares each risk with in-depth probability analysis, expert input, and comprehensive consideration of all risks, which impact comparison in a debate round can’t do

And probability outweighs timeframe – constant focus on short term crises means we ignore structural problems that guarantee extinction. Other risks resolve themselves – if they don’t happen now, they don’t happen at all – but warming will only get worse, so it’s the most structurally certain impact

Warming causes structural violence

Cuomo 11
(Chris Professor of Philosophy and Women's Studies, and an affiliate faculty member of the Environmental Ethics Certificate Program and the Institute for African-American Studies. The author and editor of many articles and several books in feminist, postcolonial, and environmental philosophy, Cuomo served as Director of the Institute for Women's Studies from 2006-2009. Her book, The Philosopher Queen, a reflection on post-9/11 anti-war feminist politics, was nominated for a Lambda Award and an APA book award, and her work in ecofeminist philosophy and creative interdiciplinary practice has been influential among those seeking to bring together social justice and environmental concerns, as well as theory and practice. She has been a recipient of research grants from the Rockefeller Foundation, the National Science Foundation, the Ms. Foundation, the National Council for Research on Women, and the Institute for Sustainability and Technology Policy, and she has been a visiting faculty member at Cornell University, Amherst College, and Murdoch University in Perth, Australia, “Climate Change, Vulnerability, and Responsibility,” Hypatia 26 no4 Fall 2011 p. 690-714, AM)
The aftermath of Hurricane Katrina made it plain that structural inequalities produced by racism can
AND
surprisingly, their vulnerabilities are also shaped by norms of sex and gender. 

Climate change denial bans are empirically successful in catalyzing productive discussion. Reddit science forum bans prove
Allen 13
 Allen, Nathan. “Reddit’s science forum banned climate deniers. Why don’t all newspapers do the same?”. Grist.com. http://grist.org/climate-energy/reddits-science-forum-banned-climate-deniers-why-dont-all-newspapers-do-the-same/. 12/16/13 LBE
Negating the ability of this misguided group to post to the forum quickly resulted in
AND
r/science is perfect, users seem happy with the changes made.

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
Humans are grounded in material conditions that create all thought – trying to abstract from material reality (i.e, not defending consequentialist turns) is another link to the K. 

Eagleton 11
Eagleton, Terry (Is a prominent British literary theorist, critic and public intellectual. He is currently Distinguished Professor of English Literature at Lancaster University). Why Marx was right. Yale University Press, 2011
In this sense, Marx was more of an antiphilosopher than a philosopher. In
AND
can fall victim to the illusion that it is thought which creates reality.

The affirmative’s legalistic approach to police violence brings us further away from recognizing the economic forces at work that makes police violence inevitable. Lane 7/21.
Alycee Lane (Alycee J. Lane is a former professor who taught African American literature and culture at UC Santa Barbara.), 7-21-16 “Violence, Death and Our Neoliberal Police,” CounterPunch, http://www.counterpunch.org/2016/07/21/violence-death-and-our-neoliberal-police/
If what we are witnessing in these violent encounters with police is neoliberalism in action
AND
and training of police – that we absolutely have the power to change.

Civil suits put an asking price on people’s suffering. 

Abel 81
Richard L. Abel, Prof of Law @ UCLA, ’81 (British Journal of Law and Society 8:1, “A Critique of American Tort Law,” jstor)
Finally, tort law responds to intangible injury by extending that fundamental concept of capitalism
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the compensation system is working well if anything, too well. 116

Tort law commodifies suffering as loss of earning power – kills value to life.

 Abel 81
Richard L. Abel, Prof of Law @ UCLA, ’81 (British Journal of Law and Society 8:1, “A Critique of American Tort Law,” jstor)
Capitalism also shapes the experience of injury. First (and this enumeration is not
AND
, care, emotional and physical integrity, and ultimately love with money.

Commodification is the worst impact under Levinas – we treat the other as equivilant to currency, which denies its value and opens it to infinite violence.

This turns the aff – police violence is a direct result of neoliberalism. A failure to recognize that makes violence inevitable.

Lane 7/21
Alycee Lane (Alycee J. Lane is a former professor who taught African American literature and culture at UC Santa Barbara.), 7-21-16 “Violence, Death and Our Neoliberal Police,” CounterPunch, http://www.counterpunch.org/2016/07/21/violence-death-and-our-neoliberal-police/
If we examine through the prism of neoliberalism the killing of Philando Castile – that
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this was true as well for Officer Darren Wilson of Ferguson, Missouri.

Lane outweighs the aff – we allow the other to be violently subjugated.

Tort law and neolib’s commodification of life anonymizes suffering, which kills our ability to recognize the other.

ZIZEK AND DALY 04
Slavoj Zizek and Glyn Daly, Conversations with Zizek, 2004 page 14-16.
For Zizek it is imperative that we cut through this Gordian knot of postmodern protocol
AND
) social antagonisms and to absorb them within a culture of differential affirmation.

The alternative is an embrace of class-consciousness as a method of critiquing neoliberalism’s grip on policing. 

LaVenia 15
Peter A. LaVenia PhD in Political Science from the University at Albany, SUNY. He is the Secretary of the NY State Green Party and manages Matt Funiciello’s campaign for Congress. JANUARY 16, 2015 “Police Behavior and Neoliberalism” http://www.counterpunch.org/2015/01/16/police-behavior-and-neoliberalism/
The cause of impotence on the part of elected officials even in the face of
AND
likely to see nothing but equivocation by local officials and big city mayors.

The role of the judge is to be a critical analyst testing whether the underlying assumptions of the AFF are valid. This is a question of the whether the AFF scholarship is good – not the passage of the plan. 

Neoliberalism sustains itself by operating by propagating a narrow lens of what it means to be ‘political.’ We situate the judge as a critical educator who steps back to evaluate the frames through which we view policy first.  Reps prior.

Blalock, 2015
(Corinne (Graduate Student. Studies Critical Theory, Legal Theory, and Law, has a JD), “NEOLIBERALISM AND THE CRISIS OF LEGAL THEORY”, Duke University, LAW AND CONTEMPORARY PROBLEMS Vol. 77:71)
RECOVERING LEGAL THEORY’S RELEVANCE? The lens of neoliberalism not only allows one to see
AND
they are in a world that constantly insists that there is no alternative.

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
T – Consequentialism

Interpretation- The affirmative must defend act or rule util. 

Violation: His aff says “generic util turns do not apply”

1. Ground

A. Turn Ground-  If only intent/phil based offense links to the standard then no negative ground links to the aff because they can always say that consequences don’t matter. Abstract ideals are incontestable goods- literature reviews that implementation difficulties are the only arguments to debate about 

B. Stable Ground- the 1AR can defend material consequences or defend intentions/philosophical implications of their affs against Ks, they can also skirt out of generic turns and DAs which also inherently prove that they are bad. 

Ground key to fairness- ensures both debaters have equal access to args

2. Topic Literature

Qualified immunity doesn't exist independent of empirical legislative decisions and police officer conduct- empirical actual focus is key

TLR 4 2004 Texas Law Review "NOTE: The Paradox Of Qualified Immunity: How A Mechanical Application Of The Objective Legal Reasonableness
Damage suits against government officials raise a number of competing interests. On the one hand, these suits deter unlawful conduct and offer the only realistic avenue for vindication of constitutional guarantees. 1 On the other hand, frivolous claims against government officials result in costs both to the defendants themselves and to society as a whole, including the expenses of litigation, the diversion of energy from pressing public matters, and the danger that fear of suit will dampen the ardor with which officials discharge their duties. 2 Qualified immunity is a judicially created doctrine designed to balance these competing interests. The primary purpose of qualified immunity is to shield government officials from "undue interference with their duties and from potentially disabling threats of liability." 3 A federal official may raise the affirmative defense of qualified immunity in response to a civil rights suit brought directly under the Constitution. 4 Likewise, a state or local official may interpose the defense when faced with a 1983 action. 5 Since qualified immunity constitutes an immunity from suit rather than a mere defense to liability, it protects government officials not only from the ordeal of protracted litigation, but also from the burdens of pretrial concerns. 6 Unlike absolute immunity, however, in theory qualified immunity does not provide officials absolute exemption from personal liability for unconstitutional conduct. 7 Rather, as its name suggests, qualified immunity was designed to protect government officials only in limited situations. 8

Focused topic education outweighs

A. Reading a framework and policy solves phil ground- our interpretation allows for negative frameworks to be read 

B. LD is a values debate isn’t responsive- 1. That commits the is-ought fallcy, just because it is a values debate, doesn't mean it ought to be, 2. That makes an empirical claim without an empirical warrant 

C. Timeframe- we have 2 months to discuss the topic- but we can always get phi led from other places

D. Debate’s strategic incentives bastardize phil debate
Nebel et Al 13 Teaching Philosophy 36:3, September 2013 271 Teaching Philosophy through Lincoln-Douglas Debate JACOB NEBEL Wolfson College, Oxford University RYAN W. DAVIS Harvard University PETER VAN ELSWYK Rutgers University BEN HOLGUIN New York University
Another cause of poorly justified relativism and skepticism in LD debate comes from judge expectations
AND
inclined to accept a controversial philosophical view about morality for the wrong reasons.

E. Phil debate creates unrealistic phil decisions
Nebel et Al 13 Teaching Philosophy 36:3, September 2013 271 Teaching Philosophy through Lincoln-Douglas Debate JACOB NEBEL Wolfson College, Oxford University RYAN W. DAVIS Harvard University PETER VAN ELSWYK Rutgers University BEN HOLGUIN New York University
The LD debate community is on the hyper-methodist end of the spectrum.
AND
Holocaust wasn’t morally wrong if the debater in question is defending moral nihilism.

F. Comparitive ethics debates are useless- in the real world people argue how actions apply under ethics

G. philosophy is structured in a way that it is responsive in one direction i.e. Hegel is written in response to Kant, but not vice versa, smart negs will pick responsive fw’s without ground against them, only util allows answers from both sides.

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
INTERPRETATION: Debaters must specify a single country in which to ban nuclear power.

VIOLATION: Case specific violation

Standards

Topic Literature

World Nuclear Association 16
World Nuclear Association, 7/16, N.P, http://www.world-nuclear.org/information-library/country-profiles/others/emerging-nuclear-energy-countries.aspx
In different countries,
AND
are likely, including public-private partnerships.

Ground

VOTER:

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
CP Generic

The aff actor should approve Thorcon reactors and purchase them to replace existing nuclear reactors

Thorcon 16 (#1)
Jack Devanney et al. 2015, “ThorCon the Do-able Molten Salt Reactor Executive Summary,” Martingale, Inc, http://thorconpower.com/docs/exec_summary.pdf(Team includes: Jack Devany has MS in naval architecture and a PhD in management science from MIT. There he served on the faculty of Ocean Engineering for ten years. Ralph Moir is a fellow of the American Nuclear Society. He holds BSc and PhD degrees in nuclear engineering from MIT. Chris Uhlik has PhD in Electrical Engineering from Stanford University))VR
Currently mankind consumes electricity at a rate of about 2,500 GWe. This
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within four years Each of these requirements has important implications for the ThorCon design

Thorcon reactors use already established tech, and hundreds of commercial level reactors can be built.

Thorcon 16 (#2)
Jack Devanney et al. 2016, “Cheap, Reliable, CO2-free Electricity, Now,” Thorcon, http://thorconpower.com/(Team includes: Jack Devany has MS in naval architecture and a PhD in management science from MIT. There he served on the faculty of Ocean Engineering for ten years. Ralph Moir is a fellow of the American Nuclear Society. He holds BSc and PhD degrees in nuclear engineering from MIT. Chris Uhlik has PhD in Electrical Engineering from Stanford University)VR
No New Technology ThorCon is all about NOW. ThorCon requires no new technology.
AND
is little more than pulling out but not replacing all the replacable parts.

Tournament: Any | Round: 1 | Opponent: Any | Judge: Any
Warming DA

Uniqueness
Nuclear power is combating warming – a prohibition is catastrophic
Harvey 12
Fiona Harvey - award-winning environment journalist for the Guardian, used to work for financial times. “Nuclear power is only solution to climate change, says Jeffrey Sachs.” The Guardian. May 3, 2012. https://www.theguardian.com/environment/2012/may/03/nuclear-power-solution-climate-chang
Combating climate change
AND
scientists," he said.

Link
A prohibition causes a shift to fossil fuels – Japan proves
Chameides 12
 Chameides, Bill (Dean of Nicholas School of the Environment 2007-2014, Professor Emeritus at Duke University). "The Nuclear Power Conundrum." Nicholas School of the Environment. Duke University, 5 July 2012. Web. http3A2F2Fblogs.nicholas.duke.edu2Fthegreengrok2Fnuke-conundrum2F

What to do when
AND
or the other.”

Internal Link
Fossil fuels increase CO2 emissions - strongest link to warming
NWF 15
National Wildlife Federation, 2015. “Global Warming is human caused”. National Wildlife Federation. https://www.nwf.org/Wildlife/Threats-to-Wildlife/Global-Warming/Global-Warming-is-Human-Caused.aspx.
Scientists have concluded
AND
recent warming trends.

Impact

Warming causes extinction
Flournoy 12
Don Flournoy 12, Citing Feng Hsu, PhD NASA Scientist @ the Goddard Space Flight Center and Don is a PhD and MA from UT, former Dean of the University College @ Ohio University, former Associate Dean at SUNY and Case Institute of Technology, Former Manager for University/Industry Experiments for the NASA ACTS Satellite, currently Professor of Telecommunications @ Scripps College of Communications, Ohio University, “Solar Power Satellites,” January 2012, Springer Briefs in Space Development, p. 10-11
In the Online Journal of Space Communication , Dr. Feng Hsu, a  NASA
AND
is simply too high for us to take any chances” (Hsu 2010