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61-460: An executive order in 1913 declared Hog Island a national preserve for the benefit of native birds. Plum and Pilot Island were transferred from the U.S. Coast Guard to the U.S. Fish and Wildlife Service in 2007. The Green Bay National Wildlife Refuge became the second National Wildlife Refuge in Great Lakes area and the 28th overall. Gravel Island National Wildlife Refuge was created under

122-1085: A "bird of ill omen", perhaps an owl. The word was used by the Swiss naturalist Conrad Gessner in 1555 and then by subsequent authors for a black-crowned night heron. Four subspecies are accepted: In the Falkland Islands , the bird is called quark , which is an onomatopoeia similar to its name in many other languages, like qua-bird in English, kwak in Dutch and West Frisian , kvakoš noční in Czech , квак in Ukrainian , кваква in Russian, vạc in Vietnamese , kowak-malam in Indonesian , and waqwa in Quechua . Adults have

183-541: A Congressional override of an executive order is a nearly impossible event, because of the supermajority vote required, and the fact that such a vote leaves individual lawmakers vulnerable to political criticism. On July 30, 2014, the US House of Representatives approved a resolution authorizing Speaker of the House John Boehner to sue President Obama over claims that he exceeded his executive authority in changing

244-584: A President of the United States of America." Sections   2 and   3 describe the various powers and duties of the president, including "He shall take care that the Laws be faithfully executed". The U.S. Supreme Court has held that all executive orders from the president of the United States must be supported by the Constitution, whether from a clause granting specific power, or by Congress delegating such to

305-455: A bird which was thought to have been the Eurasian whimbrel or glossy ibis , which has now been shown to refer to the black-crowned night heron, derived from the medieval French Bihoreau . Black-crowned night heron may have bred in the far wetter and wider landscape of pre-modern Britain. They were certainly imported for the table so the bone specimens themselves do not prove they were part of

366-403: A black crown and back with the remainder of the body white or grey, red eyes, and short yellow legs. They have pale grey wings and white under parts. One to eight (mostly two to four) long slender white plumes, erected in greeting and courtship displays, extend from the back of the head. The sexes are similar in appearance although the males are slightly larger. Black-crowned night herons do not fit

427-506: A group of trees, or on the ground in protected locations such as islands or reedbeds. Three to eight eggs are laid. This heron is migratory in the northern parts of its range, but is otherwise resident (even in the cold Patagonia ). European birds winter in Africa (with a few staying in southern Spain), central and east Asian birds winter in southern Asia, and North American birds winters in Mexico,

488-509: A key provision of the Affordable Care Act ("Obamacare") on his own and over what Republicans claimed had been "inadequate enforcement of the health care law", which Republican lawmakers opposed. In particular, Republicans "objected that the Obama administration delayed some parts of the law, particularly the mandate on employers who do not provide health care coverage". The suit was filed in

549-408: A later fiscal year . The governor may also call the legislature into special session . There are also other uses for gubernatorial executive orders. In 2007, for example, Sonny Perdue , the governor of Georgia, issued an executive order for all its state agencies to reduce water use during a major drought . The same was demanded of its counties ' water systems as well, but it was unclear whether

610-464: A law put forth by the Congress or the Constitution. Presidents since that decision have generally been careful to cite the specific laws under which they act when they issue new executive orders; likewise, when presidents believe that their authority for issuing an executive order stems from within the powers outlined in the Constitution, the order instead simply proclaims "under the authority vested in me by

671-476: A particular matter of controversy; it requires cost-benefit analysis for certain regulatory actions. Executive orders issued by state governors are not the same as statutes passed by state legislatures. State executive orders are usually based on existing constitutional or statutory powers of the governor and do not require any action by the state legislature to take effect. Executive orders may, for example, demand budget cuts from state government when

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732-530: A practical presidential tool for policy making because of the perception that proclamations are largely ceremonial or symbolic in nature. However, the legal weight of presidential proclamations suggests their importance to presidential governance. Black-crowned night heron Ardea nycticorax Linnaeus, 1758 The black-crowned night heron ( Nycticorax nycticorax ) [or black-capped night heron ], commonly shortened to just night heron in Eurasia ,

793-663: A sequential number, after receipt of the signed original from the White House and printing the text of the executive order in the daily Federal Register and eventually in Title   3 of the Code of Federal Regulations . With the exception of William Henry Harrison , all presidents since George Washington in 1789 have issued orders that in general terms can be described as executive orders. Initially, they took no set form and so they varied as to form and substance. The first executive order

854-466: A variety of plants native to the area. Hog Island has an abundance of Canada yew . This plant was functionally extirpated on St. Martin's Island because of the introduction of white-tailed deer and their appetite for this shrub. The rare dwarf lake iris ( Iris lacustris ) can be found along the shoreline of Plum Island. Plum Island is most well known for having large forests of basswood , sugar maple , and white cedar . These trees are associated with

915-538: Is a medium-sized heron found throughout a large part of the world, including parts of Europe, Asia, and North and South America. In Australasia it is replaced by the closely related Nankeen night heron ( N. caledonicus ), with which it has hybridised in the area of contact. The black-crowned night heron was formally described by the Swedish naturalist Carl Linnaeus in 1758 in the tenth edition of his Systema Naturae . He placed it with herons, cranes and egrets in

976-527: Is fresh and salt-water wetlands throughout much of the world. The nominate subspecies N. n. nycticorax breeds in Europe, Asia and Africa, subspecies N. n. hoactli in North and South America from Canada as far south as northern Argentina and Chile , N. n. obscurus in southernmost South America, and N. n. falklandicus in the Falkland Islands . Black-crowned night herons nest in colonies on platforms of sticks in

1037-569: Is intermediate, with both paler and darker individuals occurring. Immature birds have dull grey-brown plumage on their heads, wings, and backs, with numerous pale "teardrop" spots. Their underparts are paler and streaked with brown. Second and third year birds attain plumages increasingly similar to adults, but lacking the white head plumes. The young birds have orange eyes and duller yellowish-green legs. They are very noisy birds in their nesting colonies, with calls that are commonly transcribed as quok or woc . Measurements : The breeding habitat

1098-554: Is open to public use. The local flora provides habitat for birds. Pilot Island provides a safe haven for approximately 3,600 double-crested cormorant nests and about 650 herring gull nests. Black-crowned night herons also find nesting habitat there. Smallmouth bass are commonly found in the waters northwest of Plum and Pilot Islands. In 1964, the United States Congress passed the Wilderness Act of 1964 , which created

1159-677: Is still in use today, but Coast Guard employees no longer remain on the island to operate it. The Plum Island Range Lights and the Pilot Island Light are listed in the National Register of Historic Places . On October 17, 2007, Pilot and Plum Islands were officially added to the Green Bay National Wildlife Refuge. Previously under the control of the United States Coast Guard, they are now managed by

1220-614: Is the first proven breeding record of wild black-crowned night herons in Great Britain. These birds stand still at the water's edge and wait to ambush prey, mainly at night, early morning or evening. They primarily eat small fish , leeches , earthworms , mussels , squid , crustaceans (such as crayfish ), frogs , other amphibians , aquatic insects , terrestrial insects, lizards , snakes , small mammals (such as rodents ), small birds , eggs , carrion , plant material, and garbage and refuse at landfills . They are among

1281-662: The National Wilderness Preservation System . This bill declared almost 9 million acres (36,000 km) of land across the United States federal wilderness. In 1970, Hog Island and Gravel Island became one of the smallest areas of land protected by the Wilderness Act, and thus became known as the Wisconsin Islands Wilderness Area. [REDACTED]  This article incorporates public domain material from websites or documents of

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1342-531: The US Department of State instituted a numbering scheme in 1907, starting retroactively with United States Executive Order 1, issued on October 20, 1862, by President Lincoln. The documents that later came to be known as "executive orders" apparently gained their name from that order issued by Lincoln, which was captioned "Executive Order Establishing a Provisional Court in Louisiana". That court functioned during

1403-612: The United States Fish and Wildlife Service . Executive order (United States) In the United States, an executive order is a directive by the president of the United States that manages operations of the federal government . The legal or constitutional basis for executive orders has multiple sources. Article Two of the United States Constitution gives presidents broad executive and enforcement authority to use their discretion to determine how to enforce

1464-452: The genus Ardea and coined the binomial name Ardea nycticorax , based on specimens from southern Europe. It is now placed in the genus Nycticorax that was described in 1817 by the English naturalist Thomas Forster for this species. The epithet nycticorax is from Ancient Greek and combines nux , nuktos meaning "night" and korax meaning "raven". The word was used by authors such as Aristotle and Hesychius of Miletus for

1525-558: The racial integration of the armed forces under President Truman. Two extreme examples of an executive order are Franklin Roosevelt's Executive Order 6102 "forbidding the hoarding of gold coin, gold bullion, and gold certificates within the continental United States", and Executive Order 9066 , which delegated military authority to remove any or all people in a military zone (used to target Japanese Americans , non-citizen Germans , and non-citizen Italians in certain regions). The order

1586-427: The state legislature is not in session, and economic conditions take a downturn , thereby decreasing tax revenue below what was forecast when the budget was approved. Depending on the state constitution , a governor may specify by what percentage each government agency must reduce and may exempt those that are already particularly underfunded or cannot put long-term expenses (such as capital expenditures ) off until

1647-520: The Army, the Navy, and other Executive departments: The Emancipation Proclamation was an executive order, itself a rather unusual thing in those days. Executive orders are simply presidential directives issued to agents of the executive department by its boss. Until the early 1900s, executive orders were mostly unannounced and undocumented, and seen only by the agencies to which they were directed. That changed when

1708-565: The British avifauna. In modern times the black-crowned night heron is a vagrant (excluding the feral breeding colonies that were established at Edinburgh Zoo from 1950 into the start of the 21st century and at Great Witchingham in Norfolk, where there were 8 pairs in 2003 but breeding was not repeated subsequently ). A pair of adults were seen with two recently fledged juveniles in Somerset in 2017, which

1769-491: The Constitution". Wars have been fought upon executive order, including the 1999 Kosovo War during President Bill Clinton 's second term in office; however, all such wars have also had authorizing resolutions from Congress. The extent to which the president may exercise military power independently of Congress and the scope of the War Powers Resolution remain unresolved constitutional issues, but all presidents since

1830-543: The Supreme Court overturned five of Franklin Roosevelt's executive orders (6199, 6204, 6256, 6284a and 6855). Executive Order 12954 , issued by President Bill Clinton in 1995, attempted to prevent the federal government from contracting with organizations that had strike-breakers on the payroll: a federal appeals court ruled that the order conflicted with the National Labor Relations Act and overturned

1891-442: The Supreme Court with people more in line with his views: Hugo Black , Stanley Reed , Felix Frankfurter , William O. Douglas , Frank Murphy , Robert H. Jackson and James F. Byrnes . Historically, only George Washington has had equal or greater influence over Supreme Court appointments (as he chose all its original members). Justices Frankfurter, Douglas, Black, and Jackson dramatically checked presidential power by invalidating

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1952-613: The US District Court for the District of Columbia on November 21, 2014. Part of President Donald Trump 's executive order Protecting the Nation from Foreign Terrorist Entry into the United States , which temporarily banned entry to the US of citizens of seven Muslim-majority countries, including for permanent residents, was stayed by a federal court on January 28, 2017. However, on June 26, 2018,

2013-515: The US Supreme Court overturned the lower court order in Trump v. Hawaii and affirmed that the executive order was within the president's constitutional authority. The degree to which the president has the power to use executive orders to set policy for independent federal agencies is disputed. Many orders specifically exempt independent agencies, but some do not. Executive Order 12866 has been

2074-694: The United States Fish and Wildlife Service. Hog Island covers 2 acres (8,100 m) of land, Plum Island 325 acres (1.32 km), and Pilot Island approximately 3.7 acres (15,000 m). The islands are part of the Niagara Escarpment as opposed to the Black River or Magnesian escarpments. The underlying bedrock is dolomite . The area was sculpted by glaciers. The islands have been eroded, inundated, and re-shaped over many years by changing water levels. Green Bay National Wildlife Refuge contains

2135-663: The authority vested in me by the Constitution", thereby creating the National Labor Relations Board . In 1934, while Charles Evans Hughes was Chief Justice of the United States (the period being known as the Hughes Court ), the Court found that the National Industrial Recovery Act (NIRA) was unconstitutional. The president then issued Executive Order 7073 "by virtue of the authority vested in me under

2196-479: The bare skin around the eyes blue. The subspecies differ little; nominate N. n. nycticorax and N. n. hoactli are particularly similar in plumage (some authors have considered N. n. hoactli a synonym of the nominate ), but the latter is on average slightly larger. N. n obscurus is the most distinctive subspecies, clearly darker than N. n. hoactli from further north in South America, but N. n. falklandicus

2257-562: The dolomite geology of the area. The Green Bay National Wildlife Refuge provides habitat for many kinds of wildlife, especially birds. The refuge was established first for the purpose of conserving native birds of the Great Lakes Basin. Great blue herons, red-breasted mergansers , and herring gulls are common. Migratory birds breed undisturbed by human presence on the islands. No development has occurred on Hog Island due to its small size, remoteness, and landing difficulties. Plum Island

2318-575: The executive branch. Specifically, such orders must be rooted in Article II of the US Constitution or enacted by the Congress in statutes . Attempts to block such orders have been successful at times, when such orders either exceeded the authority of the president or could be better handled through legislation. The Office of the Federal Register is responsible for assigning the executive order

2379-628: The executive order at issue in Youngstown Sheet & Tube Co. v. Sawyer : in that case Roosevelt's successor, Harry S. Truman , had ordered private steel production facilities seized in Executive Order 10340 to support the Korean War effort: the Court held that the executive order was not within the power granted to the president by the Constitution. Large policy changes with wide-ranging effects have been implemented by executive order, including

2440-464: The first 100 days of his presidency, more than any other president since Harry Truman. Before 1932, uncontested executive orders had determined such issues as national mourning on the death of a president and the lowering of flags to half-staff. President Franklin Roosevelt issued the first of his 3,522 executive orders on March 6, 1933, declaring a bank holiday , and forbidding banks to release gold coin or bullion . Executive Order 6102 forbade

2501-572: The general public. Lighthouse facilities were constructed on Plum Island and Pilot Island. By 1939, the Coast Guard had taken control of Plum Island, and acquired control of the lighthouse on the island. The old wooden lighthouse was eventually replaced with a steel structure in 1964, and workers were moved to the island in order to oversee the operations of the lighthouse. At this time the lighthouse used range lights . By 1969, these lights were replaced with an automatic lighting system. The lighthouse

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2562-589: The hoarding of gold coin, bullion and gold certificates . A further executive order required all newly mined domestic gold be delivered to the Treasury. By Executive Order 6581, the president created the Export-Import Bank of the United States . On March 7, 1934, he established the National Recovery Review Board (Executive Order 6632). On June 29, the president issued Executive Order 6763 "under

2623-550: The implementation of broad statutes. As the head of state and head of government of the United States, as well as commander-in-chief of the United States Armed Forces, only the president of the United States can issue an executive order. Presidential executive orders, once issued, remain in force until they are canceled, revoked, adjudicated unlawful, or expire on their terms. At any time, the president may revoke, modify or make exceptions from any executive order, whether

2684-579: The land is prohibited on the islands which are located in the wilderness area, contrary to the testimony given before a joint meeting of several U.S. House subcommittees in preparation for the establishment of the Wilderness Area. In 1969, the U.S. Representatives present at the subcommittee meeting were told that out of a group of six lake islands including the islands in the proposed Wisconsin Islands Wilderness, five out of six of them would be open to

2745-409: The law or to otherwise manage the resources and staff of the executive branch. The ability to make such orders is also based on expressed or implied Acts of Congress that delegate to the president some degree of discretionary power ( delegated legislation ). The vast majority of executive orders are proposed by federal agencies before being issued by the president. Like both legislative statutes and

2806-606: The military occupation of Louisiana during the American Civil War , and Lincoln also used Executive Order   1 to appoint Charles A. Peabody as judge and designate the salaries of the court's officers. President Harry Truman 's Executive Order 10340 placed all the country's steel mills under federal control, which was found invalid in Youngstown Sheet & Tube Co. v. Sawyer , 343 US 579 (1952), because it attempted to make law, rather than to clarify or to further

2867-402: The order was made by the current president or a predecessor. Typically, a new president reviews in-force executive orders in the first few weeks in office. The United States Constitution does not have a provision that explicitly permits the use of executive orders. Article   II , Section   1, Clause   1 of the Constitution simply states: "The executive Power shall be vested in

2928-420: The order would have the force of law. According to political expert Phillip J. Cooper, a presidential proclamation "states a condition, declares a law and requires obedience, recognizes an event or triggers the implementation of a law (by recognizing that the circumstances in law have been realized)". Presidents define situations or conditions on situations that become legal or economic truth. Such orders carry

2989-458: The order. Congress has the power to overturn an executive order by passing legislation that invalidates it, and can also refuse to provide funding necessary to carry out certain policy measures contained with the order or legitimize policy mechanisms. In the case of the former, the president retains the power to veto such a decision; however, Congress may override a veto with a two-thirds majority to end an executive order. It has been argued that

3050-517: The passage of the resolution have complied with its terms, while also maintaining that they are not constitutionally required to do so. Harry S. Truman issued 907 executive orders, with 1,081 orders made by Theodore Roosevelt , 1,203 orders made by Calvin Coolidge , and 1,803 orders made by Woodrow Wilson . Franklin D. Roosevelt has the distinction of making a record 3,522 executive orders. In 2021, President Joseph Biden issued 42 executive orders in

3111-485: The regulations promulgated by government agencies, executive orders are subject to judicial review and may be overturned if the orders lack support by statute or the Constitution. Some policy initiatives require approval by the legislative branch, but executive orders have significant influence over the internal affairs of government, deciding how and to what degree legislation will be enforced, dealing with emergencies, waging wars, and in general fine-tuning policy choices in

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3172-769: The said Emergency Relief Appropriation Act of 1935 ", re-establishing the National Emergency Council to administer the functions of the NIRA in carrying out the provisions of the Emergency Relief Appropriations Act. On June 15, he issued Executive Order 7075, which terminated the NIRA and replaced it with the Office of Administration of the National Recovery Administration . In the years that followed, Roosevelt replaced outgoing justices of

3233-613: The same executive order. In 1970, the islands which at the time where included in the Green Bay National Wildlife Refuge and Gravel Island National Wildlife Refuge were declared part of the Wisconsin Islands Wilderness Area . This wilderness area is one of the smallest in the entire United States. The refuge is managed by staff at the Horicon National Wildlife Refuge , in Mayville, Wisconsin . Public use of

3294-415: The same force of law as executive orders, the difference between being that executive orders are aimed at those inside government, but proclamations are aimed at those outside government. The administrative weight of those proclamations is upheld because they are often specifically authorized by congressional statute, making them "delegated unilateral powers". Presidential proclamations are often dismissed as

3355-416: The seven heron species observed to engage in bait fishing; luring or distracting fish by tossing edible or inedible buoyant objects into water within their striking range – a rare example of tool use among birds. During the day they rest in dense trees or bushes. N. n. hoactli is more gregarious outside the breeding season than the nominate race . A thorough study performed by J. Sitko and P. Heneberg in

3416-700: The southern United States, Central America, and the West Indies. A colony of the herons has regularly summered at the National Zoo in Washington, D.C. for more than a century. The birds also prominently live year-round in the shores around the San Francisco Bay , with the largest rookery in Oakland . Their ever presence at Oakland's Lake Merritt and throughout the city's downtown area, as well as their resilience to

3477-569: The spirit and letter of existing U.S. law on access to presidential papers as clearly laid down in 44 USC 2201–07", and adding that the order "potentially threatens to undermine one of the very foundations of our nation". President Barack Obama subsequently revoked Executive Order 13233 in January 2009. The Heritage Foundation has accused presidents of abusing executive orders by using them to make laws without Congressional approval and moving existing laws away from their original mandates. In 1935,

3538-419: The typical body form of the heron family. They are relatively stocky with shorter bills, legs, and necks than their more familiar cousins, the egrets and "day" herons. Their resting posture is normally somewhat hunched but when hunting they extend their necks and look more like other wading birds. For a short period during courtship at the start of the nesting season, the legs of adults turn bright salmon-pink, and

3599-718: The urban environment and displacement efforts, have led to them being named Oakland's official city bird. There are two archaeological specimens of the black-crowned night heron in Great Britain . The oldest is from the Roman London Wall and the more recent from the Royal Navy 's late medieval victualling yards in Greenwich . It appears in the London poulterers ' price lists as the Brewe,

3660-468: Was issued by Washington on June 8, 1789; addressed to the heads of the federal departments, it instructed them "to impress [him] with a full, precise, and distinct general idea of the affairs of the United States" in their fields. According to political scientist Brian R. Dirck, the most famous executive order was by President Abraham Lincoln when he issued the Emancipation Proclamation on September 22, 1862, which in part contained explicit directions to

3721-444: Was then delegated to General John L. DeWitt , and it subsequently paved the way for all Japanese-Americans on the West Coast to be sent to internment camps for the duration of World War II . President George W. Bush issued Executive Order 13233 in 2001, which restricted public access to the papers of former presidents. The order was criticized by the Society of American Archivists and other groups, who say it "violates both

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