Defining Fair Notice: Logical Outgrowth Doctrine Applied to the Waters of the United States

In 2014, the Corps of Engineers and Environmental Protection Agency sought to bring clarity to the scope of “waters of the United States” through notice-and-comment rulemaking. On June 29, 2015, the agencies published a joint final rule that immediately prompted lawsuits across the entire country. This current legal controversy provides a convenient backdrop to propose a new method to analyze logical outgrowth. This Note will use the Proposed and Final Rule as an administrative law case study. It argues that the Final Rule is substantively within the authority Congress delegated to the Corps of Engineers and the EPA

Evidence for surface uplift of the Atlas Mountains and the surrounding peripheral plateaux: Combining apatite fission-track results and geomorphic indicators in the Western Moroccan Meseta (coastal Variscan Paleozoic basement)

This work represents an initial attempt to link the evolution of the topography in relation to the general tectonic framework of western Morocco. For this purpose, in a section of the Western Moroccan Meseta different tools are combined in order to attain the general objective. Apatite fission-track (AFT) data of granitic rocks of the Rabat–Khenifra area give ages around 200 Ma with track length distributions which are compatible with the thermal models already established for the area. An inverse correlation between AFT ages and elevation is observed which is compatible with previous models indicating northward tilting of the whole Western Moroccan Meseta which is younger than 20–25 Ma. In order to test this possibility a detailed analysis of the topography at different scales in the Western Moroccan Meseta has been performed. Results indicate that two open folds with different amplitudes are recognized and that the one with wider wavelength could correspond to a lithospheric fold as previously stated by other authors on the basis of independent geological arguments. The northward tilting proposed based on the AFT data agrees with the results obtained in the analysis of the topography which reinforces the presence of a very open fold with a wavelength of 200–300 km in the north-western limb of the Western Moroccan Meseta

Ice surface changes during recent glacial cycles along the Jutulstraumen and Penck Trough ice streams in western Dronning Maud Land, East Antarctica

Reconstructing past ice-sheet surface changes is key to testing and improving ice-sheet models. Data constraining the past behaviour of the East Antarctic Ice Sheet are sparse, limiting our understanding of its response to past, present and future climate change. Here, we report the first cosmogenic multi-nuclide (10Be, 26Al, 36Cl) data from bedrock and erratics on nunataks along the Jutulstraumen and Penck Trough ice streams in western Dronning Maud Land, East Antarctica. Spanning elevations between 741 and 2394 m above sea level, the samples have apparent exposure ages between 2 ka and 5 Ma. The highest-elevation bedrock sample indicates (near-) continuous minimum exposure since the Pliocene, with a low apparent erosion rate of 0.15 ± 0.03 m Ma−1, which is similar to results from eastern Dronning Maud Land. In contrast to studies in eastern Dronning Maud Land, however, our data show clear indications of a thicker-than-present ice sheet within the last glacial cycle, with a thinning of ∼35–120 m during the Holocene (∼2–11 ka). Difficulties in separating suitable amounts of quartz from the often quartz-poor rock-types in the area, and cosmogenic nuclides inherited from exposure prior to the last deglaciation, prevented robust thinning estimates from elevational profiles. Nevertheless, the results clearly demonstrate ice-surface fluctuations of several hundred meters between the current grounding line and the edge of the polar plateau for the last glacial cycle, a constraint that should be considered in future ice-sheet model simulations

Recombinant MVA-prime elicits neutralizing antibody responses by inducing antigen-specific B cells in the germinal center.

The RV144 HIV-1 vaccine trial has been the only clinical trial to date that has shown any degree of efficacy and associated with the presence of vaccine-elicited HIV-1 envelope-specific binding antibody and CD4+ T-cell responses. This trial also showed that a vector-prime protein boost combined vaccine strategy was better than when used alone. Here we have studied three different priming vectors-plasmid DNA, recombinant MVA, and recombinant VSV, all encoding clade C transmitted/founder Env 1086 C gp140, for priming three groups of six non-human primates each, followed by a protein boost with adjuvanted 1086 C gp120 protein. Our data showed that MVA-priming favors the development of higher antibody binding titers and neutralizing activity compared with other vectors. Analyses of the draining lymph nodes revealed that MVA-prime induced increased germinal center reactivity characterized by higher frequencies of germinal center (PNA <sup>hi</sup> ) B cells, higher frequencies of antigen-specific B-cell responses as well as an increased frequency of the highly differentiated (ICOS <sup>hi</sup> CD150 <sup>lo</sup> ) Tfh-cell subset

Regional and global forcing of glacier retreat during the last deglaciation

The ongoing retreat of glaciers globally is one of the clearest manifestations of recent global warming associated with rising greenhouse gas concentrations. By comparison, the importance of greenhouse gases in driving glacier retreat during the most recent deglaciation, the last major interval of global warming, is unclear due to uncertainties in the timing of retreat around the world. Here we use recently improved cosmogenic-nuclide production-rate calibrations to recalculate the ages of 1,116 glacial boulders from 195 moraines that provide broad coverage of retreat in mid-to-low-latitude regions. This revised history, in conjunction with transient climate model simulations, suggests that while several regional-scale forcings, including insolation, ice sheets and ocean circulation, modulated glacier responses regionally, they are unable to account for global-scale retreat, which is most likely related to increasing greenhouse gas concentrations.This is the publisher’s final pdf. The published article is copyrighted by the author(s) and published by Nature Publishing Group. The published article can be found at: http://www.nature.com/ncomms/2015/150821/ncomms9059/full/ncomms9059.htm

Psychiatry during the Nazi era: ethical lessons for the modern professional

For the first time in history, psychiatrists during the Nazi era sought to systematically exterminate their patients. However, little has been published from this dark period analyzing what may be learned for clinical and research psychiatry. At each stage in the murderous process lay a series of unethical and heinous practices, with many psychiatrists demonstrating a profound commitment to the atrocities, playing central, pivotal roles critical to the success of Nazi policy. Several misconceptions led to this misconduct, including allowing philosophical constructs to define clinical practice, focusing exclusively on preventative medicine, allowing political pressures to influence practice, blurring the roles of clinicians and researchers, and falsely believing that good science and good ethics always co-exist. Psychiatry during this period provides a most horrifying example of how science may be perverted by external forces. It thus becomes crucial to include the Nazi era psychiatry experience in ethics training as an example of proper practice gone awry

In situ cosmogenic radiocarbon production and 2-D ice flow line modeling for an Antarctic blue ice area

Radiocarbon measurements at ice margin sites and blue ice areas can potentially be used for ice dating, ablation rate estimates and paleoclimatic reconstructions. Part of the measured signal comes from in situ cosmogenic ¹⁴C production in ice, and this component must be well understood before useful information can be extracted from ¹⁴C data. We combine cosmic ray scaling and production estimates with a two-dimensional ice flow line model to study cosmogenic ¹⁴C production at Taylor Glacier, Antarctica. We find (1) that ¹⁴C production through thermal neutron capture by nitrogen in air bubbles is negligible; (2) that including ice flow patterns caused by basal topography can lead to a surface ¹⁴C activity that differs by up to 25% from the activity calculated using an ablation-only approximation, which is used in all prior work; and (3) that at high ablation margin sites, solar modulation of the cosmic ray flux may change the strength of the dominant spallogenic production by up to 10%. As part of this effort we model two-dimensional ice flow along the central flow line of Taylor Glacier. We present two methods for parameterizing vertical strain rates, and assess which method is more reliable for Taylor Glacier. Finally, we present a sensitivity study from which we conclude that uncertainties in published cosmogenic production rates are the largest source of potential error. The results presented here can inform ongoing and future ¹⁴C and ice flow studies at ice margin sites, including important paleoclimatic applications such as the reconstruction of paleoatmospheric ¹⁴C content of methane