The Water Is On Fire: Current Circuit Approaches to Fee-Shifting in Citizen-Suits Under the Clean Water Act and the Need for Clearer and More Uniform Standards

This Note will start by providing a short explanation of the origins of and congressional goals for the fee-shifting provision in the CWA [Clean Water Act]. It will then offer a brief summary of how Supreme Court precedent has both clarified and confused this issue. Then, it will dive into an examination of how the different circuits and their district courts have interpreted the CWA’s fee-shifting provision and how these interpretations have struggled with past Supreme Court decisions. Finally, this Note will explore the costs and benefits associated with these fee-shifting standards and offer a potential solution to this problem. Ultimately, this Note will argue that, in the absence of Supreme Court guidance, the circuits must adopt clearer, more uniform standards in order to fulfill congressional objectives, bolster the viability of CWA citizen-suits, and ensure that citizens do not pay the price for their public service. This abstract has been adapted from the author\u27s introduction

Effectiveness of appropriately trained nurses in preoperative assessment: randomised controlled equivalence/non-inferiority trial

Objective To determine whether preoperative assessments carried out by appropriately trained nurses are inferior in quality to those carried out by preregistration house officers. Design Randomised controlled equivalence/non-inferiority trial. Setting Four NHS hospitals in three trusts. Three of the four were teaching hospitals. Participants All patients attending for assessment before general anaesthesia for general, vascular, urological, or breast surgery between April 1998 and March 1999. Intervention Assessment by one of three appropriately trained nurses or by one of several preregistration house officers. Main outcome measures History taken, physical examination, and investigations ordered. Measures evaluated by a specialist registrar in anaesthetics and placed in four categories: correct, overassessment, underassessment not affecting management, and underassessment possibly affecting management (primary outcome). Results 1907 patients were randomised, and 1874 completed the study; 926 were assessed by house officers and 948 by nurses. Overall 121/948 (13%) assessments carried out by nurses were judged to have possibly affected management compared with 138/926 (15%) of those performed by house officers. Nurses were judged to be non-inferior to house officers in assessment, although there was variation among them in terms of the quality of history taking. The house officers ordered considerably more unnecessary tests than the nurses (218/926 (24%) v 129/948 (14%). Conclusions There is no reason to inhibit the development of nurse led preoperative assessment provided that the nurses involved receive adequate training. However, house officers will continue to require experience in preoperative assessment

Benefits and risks of including the bromoform containing seaweed Asparagopsis in feed for the reduction of methane production from ruminants

The agricultural production of ruminants is responsible for 24% of global methane emissions, contributing 39% of emissions of this greenhouse gas from the agricultural sector. Strategies to mitigate ruminant methanogenesis include the use of methanogen inhibitors. For example, the seaweeds Asparagopsis taxiformis and Asparagopsis armata included at low levels in the feed of cattle and sheep inhibit methanogenesis by up to 98%, with evidence of improvements in feed utilisation efficiency. This has resulted in an increasing interest in and demand for these seaweeds globally. In response, research is progressing rapidly to facilitate Asparagopsis cultivation at large scale, and to develop aquaculture production systems to enable a high quality and consistent supply chain. In addition to developing robust strategies for sustainable production, it is important to consider and evaluate the benefits and risks associated with its production and subsequent use as an antimethanogenic feed ingredient for ruminant livestock. This review focuses on the relevant ruminal biochemical pathways, degradation, and toxicological risks associated with bromoform (CHBr3), the major active ingredient for inhibition of methanogenesis in Asparagopsis, and the effects that production of Asparagopsis and its use as a ruminant feed ingredient might have on atmospheric chemistry

COVID-19 Vaccine Hesitancy and Determinants of Acceptance among Healthcare Workers, Academics and Tertiary Students in Nigeria

The COVID-19 pandemic has resulted in millions of human deaths, prompting the rapid development and regulatory approval of several vaccines. Although Nigeria implemented a COVID-19 vaccination program on 15 March 2021, low vaccine acceptance remains a major chal-lenge. To provide insight on factors associated with COVID-19 vaccine hesitancy (VH), we conducted a national survey among healthcare workers, academics, and tertiary students, between 1 September 2021 and 31 December 2021. We fitted a logistic regression model to the data and exam-ined factors associated with VH to support targeted health awareness campaigns to address public

The Water Is On Fire: Current Circuit Approaches to Fee-Shifting in Citizen-Suits Under the Clean Water Act and the Need for Clearer and More Uniform Standards

This Note will start by providing a short explanation of the origins of and congressional goals for the fee-shifting provision in the CWA [Clean Water Act]. It will then offer a brief summary of how Supreme Court precedent has both clarified and confused this issue. Then, it will dive into an examination of how the different circuits and their district courts have interpreted the CWA’s fee-shifting provision and how these interpretations have struggled with past Supreme Court decisions. Finally, this Note will explore the costs and benefits associated with these fee-shifting standards and offer a potential solution to this problem. Ultimately, this Note will argue that, in the absence of Supreme Court guidance, the circuits must adopt clearer, more uniform standards in order to fulfill congressional objectives, bolster the viability of CWA citizen-suits, and ensure that citizens do not pay the price for their public service. This abstract has been adapted from the author\u27s introduction

A Bayesian Spatio-Temporal Analysis of Malaria in the Greater Accra Region of Ghana from 2015 to 2019

The Greater Accra Region is the smallest of the 16 administrative regions in Ghana. It is highly populated and characterized by tropical climatic conditions. Although efforts towards malaria control in Ghana have had positive impacts, malaria remains in the top five diseases reported at healthcare facilities within the Greater Accra Region. To further accelerate progress, analysis of regionally generated data is needed to inform control and management measures at this level. This study aimed to examine the climatic drivers of malaria transmission in the Greater Accra Region and identify inter-district variation in malaria burden. Monthly malaria cases for the Greater Accra Region were obtained from the Ghanaian District Health Information and Management System. Malaria cases were decomposed using seasonal-trend decomposition, based on locally weighted regression to analyze seasonality. A negative binomial regression model with a conditional autoregressive prior structure was used to quantify associations between climatic variables and malaria risk and spatial dependence. Posterior parameters were estimated using Bayesian Markov chain Monte Carlo simulation with Gibbs sampling. A total of 1,105,370 malaria cases were recorded in the region from 2015 to 2019. The overall malaria incidence for the region was approximately 47 per 1000 population. Malaria transmission was highly seasonal with an irregular inter-annual pattern. Monthly malaria case incidence was found to decrease by 2.3% (95% credible interval: 0.7-4.2%) for each 1 °C increase in monthly minimum temperature. Only five districts located in the south-central part of the region had a malaria incidence rate lower than the regional average at &gt;95% probability level. The distribution of malaria cases was heterogeneous, seasonal, and significantly associated with climatic variables. Targeted malaria control and prevention in high-risk districts at the appropriate time points could result in a significant reduction in malaria transmission in the Greater Accra Region.</p

Effect of the macroalgae Asparagopsis taxiformis on methane production and rumen microbiome assemblage.

BackgroundRecent studies using batch-fermentation suggest that the red macroalgae Asparagopsis taxiformis has the potential to reduce methane (CH4) production from beef cattle by up to ~ 99% when added to Rhodes grass hay; a common feed in the Australian beef industry. These experiments have shown significant reductions in CH4 without compromising other fermentation parameters (i.e. volatile fatty acid production) with A. taxiformis organic matter (OM) inclusion rates of up to 5%. In the study presented here, A. taxiformis was evaluated for its ability to reduce methane production from dairy cattle fed a mixed ration widely utilized in California, the largest milk producing state in the US.ResultsFermentation in a semi-continuous in-vitro rumen system suggests that A. taxiformis can reduce methane production from enteric fermentation in dairy cattle by 95% when added at a 5% OM inclusion rate without any obvious negative impacts on volatile fatty acid production. High-throughput 16S ribosomal RNA (rRNA) gene amplicon sequencing showed that seaweed amendment effects rumen microbiome consistent with the Anna Karenina hypothesis, with increased β-diversity, over time scales of approximately 3 days. The relative abundance of methanogens in the fermentation vessels amended with A. taxiformis decreased significantly compared to control vessels, but this reduction in methanogen abundance was only significant when averaged over the course of the experiment. Alternatively, significant reductions of CH4 in the A. taxiformis amended vessels was measured in the early stages of the experiment. This suggests that A. taxiformis has an immediate effect on the metabolic functionality of rumen methanogens whereas its impact on microbiome assemblage, specifically methanogen abundance, is delayed.ConclusionsThe methane reducing effect of A. taxiformis during rumen fermentation makes this macroalgae a promising candidate as a biotic methane mitigation strategy for dairy cattle. But its effect in-vivo (i.e. in dairy cattle) remains to be investigated in animal trials. Furthermore, to obtain a holistic understanding of the biochemistry responsible for the significant reduction of methane, gene expression profiles of the rumen microbiome and the host animal are warranted

Effect of the macroalgae Asparagopsis taxiformis on methane production and rumen microbiome assemblage.

BackgroundRecent studies using batch-fermentation suggest that the red macroalgae Asparagopsis taxiformis has the potential to reduce methane (CH4) production from beef cattle by up to ~ 99% when added to Rhodes grass hay; a common feed in the Australian beef industry. These experiments have shown significant reductions in CH4 without compromising other fermentation parameters (i.e. volatile fatty acid production) with A. taxiformis organic matter (OM) inclusion rates of up to 5%. In the study presented here, A. taxiformis was evaluated for its ability to reduce methane production from dairy cattle fed a mixed ration widely utilized in California, the largest milk producing state in the US.ResultsFermentation in a semi-continuous in-vitro rumen system suggests that A. taxiformis can reduce methane production from enteric fermentation in dairy cattle by 95% when added at a 5% OM inclusion rate without any obvious negative impacts on volatile fatty acid production. High-throughput 16S ribosomal RNA (rRNA) gene amplicon sequencing showed that seaweed amendment effects rumen microbiome consistent with the Anna Karenina hypothesis, with increased β-diversity, over time scales of approximately 3 days. The relative abundance of methanogens in the fermentation vessels amended with A. taxiformis decreased significantly compared to control vessels, but this reduction in methanogen abundance was only significant when averaged over the course of the experiment. Alternatively, significant reductions of CH4 in the A. taxiformis amended vessels was measured in the early stages of the experiment. This suggests that A. taxiformis has an immediate effect on the metabolic functionality of rumen methanogens whereas its impact on microbiome assemblage, specifically methanogen abundance, is delayed.ConclusionsThe methane reducing effect of A. taxiformis during rumen fermentation makes this macroalgae a promising candidate as a biotic methane mitigation strategy for dairy cattle. But its effect in-vivo (i.e. in dairy cattle) remains to be investigated in animal trials. Furthermore, to obtain a holistic understanding of the biochemistry responsible for the significant reduction of methane, gene expression profiles of the rumen microbiome and the host animal are warranted

Effect of the macroalgae Asparagopsis taxiformis on methane production and rumen microbiome assemblage (vol 1, 3, 2019)

Table S1. Quality filtering and OTU distribution at each incubation time. Table S2. Diversity indices at each incubation time. Figures S1A., S1B, S1C Rarefaction curves of equilibration, control and A. taxiformis amended vessels respectively. Figure S2. Principle Coordinate Analysis plot. Table S3. OTU table. Table S4. Raw sequence barcodes for archived 16S rRNA gene amplicon data. Table S5. Results of AMOVA and HOMOVA statistical tests. (XLSX 3751 kb