Choose Your Laws Carefully: Executive Authority to Unilaterally Withdraw the United States Outer Continental Shelf from Leasing Disposition

Congress enacted the Outer Continental Shelf Lands Act (OCSLA) to both exert federal jurisdiction over the submerged lands of the U.S. Outer Continental Shelf and establish the legal framework for America’s offshore energy production regime. Section 12(a) of OCSLA is a short yet potent provision that grants a president the authority to withdraw unleased offshore lands from leasing disposition, effectively banning any form of energy exploration or production. In recent decades, presidents have embraced section 12(a) not only to ban offshore energy production, but also to protect the marine environment itself. Presidents have also utilized a different federal law, the Antiquities Act of 1906 (Antiquities Act), to create marine national monuments, providing general protection for areas of rich biodiversity, scientific interest, and cultural heritage. Interestingly, both OCSLA and the Antiquities Act achieve the same end results: offshore energy production is prohibited and the marine environment is protected. The crucial distinction between the two laws, though, is the ability to provide permanent protection. A close study of these laws reveals that only one indeed provides the intended lasting protection that presidents have sought: the Antiquities Act. This Note probes the theory of executive authority to unilaterally remove America’s submerged lands from leasing disposition. Specifically, it centers on President Barack Obama’s twin December 2017 offshore withdrawals in the Atlantic and Arctic Oceans. President Obama utilized OCSLA to ban offshore energy production, but he framed the withdrawals as a way to permanently protect each area’s unique marine biodiversity, scientific value, and cultural significance to indigenous inhabitants. This Note concludes that a president seeking such lasting protection must use the Antiquities Act in lieu of OCSLA. The Note examines the relevant statutory histories, judicial inquiries, and precedential usage of these laws and argues that OCSLA’s protection falls incredibly short. This Note is particularly relevant given the Trump administration’s effort to roll back the Obama administration’s bans on offshore energy production. President Donald Trump’s recent executive actions will surely test the conclusions of this Note

It Is Not Always May

When asked what an ideal high school girl should be, a member of one of my classes wrote the following: I think an ideal high school girl is one who is polite to everyone; who applies the talents she has been blessed with, to the best of her ability; who is diligent in the pursuit of her studies; who feels herself joined to her fellow-students by a common bond of sportsmanship, school spirit, and general good-fellowship; who at home, is thoughtful of others, takes her part in the family duties, joys, sorrows, and sacrifices, and makes for herself such a place in the simple routine of home life that, if she were ever called upon to leave that home, the only memories left behind her would be those of merry smiles, kind words, and a genial kindliness for all. This seems, to me, to be the very essence of all that the school and the home have a right to expect of the girl of high school age; and, coming as it does, from the pen of a high school girl, its genuineness should make a strong appeal to other teen-age girls

Shuttle/spacelab contamination environment and effects handbook

This handbook is intended to assist users of the Spacelab/Space Transportation System by providing contamination environments and effects information that may be of value in planning, designing, manufacturing, and operating a space flight experiment. A summary of available molecular and particulate contamination data on the Space Transportation System and its facilities is presented. Contamination models, contamination effects, and protection methods information are also presented. In addition to contamination, the effects of the space environments at STS altitudes on spacecraft materials are included. Extensive references, bibliographies, and contacts are provided

A National Dialogue on Health Information Technology and Privacy

Increasingly, government leaders recognize that solving the complex problems facing America today will require more than simply keeping citizens informed. Meeting challenges like rising health care costs, climate change and energy independence requires increased level of collaboration. Traditionally, government agencies have operated in silos -- separated not only from citizens, but from each other, as well. Nevertheless, some have begun to reach across and outside of government to access the collective brainpower of organizations, stakeholders and individuals.The National Dialogue on Health Information Technology and Privacy was one such initiative. It was conceived by leaders in government who sought to demonstrate that it is not only possible, but beneficial and economical, to engage openly and broadly on an issue that is both national in scope and deeply relevant to the everyday lives of citizens. The results of this first-of-its-kind online event are captured in this report, together with important lessons learned along the way.This report served as a call to action. On his first full day in office, President Obama put government on notice that this new, more collaborative model can no longer be confined to the efforts of early adopters. He called upon every executive department and agency to "harness new technology" and make government "transparent, participatory, and collaborative." Government is quickly transitioning to a new generation of managers and leaders, for whom online collaboration is not a new frontier but a fact of everyday life. We owe it to them -- and the citizens we serve -- to recognize and embrace the myriad tools available to fulfill the promise of good government in the 21st Century.Key FindingsThe Panel recommended that the Administration give stakeholders the opportunity to further participate in the discussion of heath IT and privacy through broader outreach and by helping the public to understand the value of a person-centered view of healthcare information technology

MODELLING THE COEFFICIENT OF VARIATION IN FACTORIAL EXPERIMENTS

The coefficient of variation (CV) has long been used as a measure of the relative consistency of sample data. However, little attention has been paid to using the CV to make conclusions about the relative consistency of the population(s) from which the data are drawn, particularly when the data are observed in the context of a designed factorial experiment. This research focused on using three approximations to the exact distribution of the sample CV of normally distributed data (McKay\u27s, David\u27s, and Iglewicz and Myers\u27) in the context of the generalized linear model to develop a method for detecting main effects and interactions among factors when the population characteristic of interest is the CV

Novel cell adhesion/migration pathways are predictive markers of HDAC inhibitor resistance in cutaneous T cell lymphoma

BACKGROUND: Treatment for Cutaneous T Cell Lymphoma (CTCL) is generally not curative. Therefore, selecting therapy that is effective and tolerable is critical to clinical decision-making. Histone deacetylase inhibitors (HDACi), epigenetic modifier drugs, are commonly used but effective in only ~30% of patients. There are no predictive markers of HDACi response and the CTCL histone acetylation landscape remains unmapped. We sought to identify pre-treatment molecular markers of resistance in CTCL that progressed on HDACi therapy. METHODS: Purified T cells from 39 pre/post-treatment peripheral blood samples and skin biopsies from 20 patients were subjected to RNA-seq and ChIP-seq for histone acetylation marks (H3K14/9 ac, H3K27ac). We correlated significant differences in histone acetylation with gene expression in HDACi-resistant/sensitive CTCL. We extended these findings in additional CTCL patient cohorts (RNA-seq, microarray) and using ELISA in matched CTCL patient plasma. FINDINGS: Resistant CTCL exhibited high levels of histone acetylation, which correlated with increased expression of 338 genes (FDR \u3c 0·05), including some novel to CTCL: BIRC5 (anti-apoptotic); RRM2 (cell cycle); TXNDC5, GSTM1 (redox); and CXCR4, LAIR2 (cell adhesion/migration). Several of these, including LAIR2, were elevated pre-treatment in HDACi-resistant CTCL. In CTCL patient plasma (n = 6), LAIR2 protein was also elevated (p \u3c 0·01) compared to controls. INTERPRETATION: This study is the first to connect genome-wide differences in chromatin acetylation and gene expression to HDACi-resistance in primary CTCL. Our results identify novel markers with high pre-treatment expression, such as LAIR2, as potential prognostic and/or predictors of HDACi-resistance in CTCL. FUNDING: NIH:CA156690, CA188286; NCATS: WU-ICTS UL1 TR000448; Siteman Cancer Center: CA091842

A Permutation Test for Compound Symmetry with Application to Gene Expression Data

The development and application of a permutation test for compound symmetry is described. In a simulation study the permutation test appears to be a level-α test and is robust to non-normality. However, it exhibits poor power, particularly for small samples

Front crawl arm stroke trajectories of physically impaired swimmers: A preliminary study

© 2019 Elsevier Masson SAS. Introduction: This study evaluated three-dimensional kinematic parameters of the front crawl stroke in physically impaired swimmers across a range of functional classification levels. Facts and Results: Eight highly-trained competitive swimmers (5 male and 3 female) from IPC classes S5 to S9 performed 50 m maximal front crawl trials while being video-taped by six cameras (four under- and two above water). The most distal point of the right upper limb was manually digitised at 50 Hz to allow three-dimensional reconstruction of the limb's trajectory through the water. Conclusion: The stroke presented large inter-swimmer variability, reflecting individual characteristics and severity of the impairment. The swimmers who combined shallow and narrow stroke movements produced a shorter trajectory. This study provides swimmers and coaches with an overview of the kinematic characteristics of a range of physically impaired swimmers