Inoculate Low-income Countries, Stop Trying with U.S. Citizens Who Still Don’t Want It

Inoculate Low-income Countries, Stop Trying with U.S. Citizens Who Still Don’t Want It

By: Hannah Gardner

Convincing people in the United States who don’t want to get vaccinated is time consuming, complicated, and expensive but vaccinating people in developing countries is only about logistics. We are in a global emergency. A necessary question to consider - how can we make the greatest impact with the resources we have?

Since March, the United States has discarded 15 million expired vaccines[1]. Alabama alone has thrown away over 65,000 vaccines[2].

The consequences of wasted vaccines – the virus spreads in the most vulnerable countries, which could’ve otherwise benefited from vaccine protection. Statistics show that merely 1.9% of residents in low-income countries have received at least one dose of the vaccine[3]. An end to the pandemic is inconceivable without vaccine access in every country.

Vaccine access inequities are exacerbated by booster vaccines, and the United States is not solely to blame. Nationalism is on display, as the North American, European, and other high-income countries are hoarding vaccines. Canada has enough doses to vaccinate its country four times over[4]. The “need” for booster shots is the rationale behind vaccine stockpiling. While booster shots are necessary among certain high-risk professions and the elderly, data on an immediate need for booster shots in the general population is sparse and conflicting. While we continue to research this issue, extra vaccines should be given to low-income countries for their first and second doses. 

Do we have a moral obligation to bolster low-income countries? In the words of bioethicist Giovanni Berlinguer, “the idea that the combination of scientific progress and free market would spontaneously extend its benefits worldwide, which was dominant in the past two decades, has failed, and a paradoxical situation about science has arisen[5].” There has never been a more perfect example of this paradoxical situation than the COVID-19 vaccine. Scientific innovation gave us this vaccine in an unparalleled timeline – seemingly a quick solution to this pandemic. However, vested interests in this technology have propagated inequities in access and affordability. Manufacturing companies have patented market-exclusivity. Countries that can afford vaccines receive protection, and countries that cannot suffer. This pandemic will not end until countries that can afford the vaccine spread the wealth.

The U.S. has an abundance of vaccines, but too much of our effort is focused on vaccinating our unvaccinated. We face internal vaccine opposition stemming from the spread of misinformation, mistrust in science, and conspiracy theories. Countless efforts have been made to address this opposition through scientific explanations, marketing strategies, monetary incentives, and even pleas from the President of the United States. Yet, our vaccination rates remain stagnant. Perhaps we are naive to think that we can argue with irrationality and the great misinformation machine that is the internet.

Conversely, willingness to take the vaccine is almost 20% higher in low-income countries than it is in the United States[6]. Surveys indicate that on average, 80% of people in low-income countries would take the vaccine[6] and hesitancy is generally attributed to vaccine induced symptoms. This form of hesitancy is easier to address than what we face in the United States. Overall, the uptake of vaccines would yield positive outcomes in low-income countries.

However, shifting inoculation efforts will have repercussions. Pockets of unvaccinated people in the U.S. leave us susceptible to the virus continuing to spread and perhaps, what is more concerning, mutate. While virus mutations mostly result in innocuous but slightly more infectious strains, scientists are more worried about a mutation that evades our vaccines[7]. This potential reality must be taken seriously as scientists and politicians debate vaccine mandates - a reality that may arrive after it’s too late.

The potential benefits of vaccine advocacy in low-income countries are substantial. Increasing vaccination rates in low-income countries would result in decreasing COVID-19 infections, fewer mortalities, relief in overburdened hospitals and clinics, and economic benefits. Specifically, the economic benefits would manifest by prevented illness costs, a larger productive workforce, and the re-opening of closed businesses[8].

Before we can work towards vaccinating low-income countries, there are critical steps that must be taken.

 

Our nation must, in collaboration with countries globally, support an effort to produce billions of doses. Advocacy groups have pointed to The Build Back Better Act for supporting this initiative. Specifically, SEC. 31022. of The Build Back Better Act titled, “Funding for Public Health and Preparedness Research, Development, and Countermeasure Capacity,” incorporates $1.3 billion to expand global vaccine production.

Secondly, we need to generate support among political leaders to reallocate excess vaccine supplies to low-income countries. This step requires the support of public health agencies with access to data, such as the CDC. Data will illustrate where vaccines are going to waste. For example, doses are likely being wasted in states with higher concentrations of vaccine hesitancy. Doses in these states can be reallocated to low-income countries.

Lastly, our country’s decision to hastily offer booster shots may be ill-considered. While the WHO has already urged countries to delay booster rollouts, we need to apply greater pressure to examine alternative strategies that are global in scope. We need to engage with stakeholders, public health experts, and politicians to prioritize vaccinating low-income countries first.

The global inequities in this pandemic can be attenuated by distributing resources fairly. It is up to us to prioritize where the vaccines go.

 

 

 

 

 

 

 

References

1.         Murphy, J.E.a.J., 15 million Covid vaccine doses thrown away in the U.S. since March, new data shows. nbcnews, 2021.

2.         Goldman, D., Alabama Just Tossed 65,000 Vaccines. Turns Out It’s Not Easy To Donate Unused Doses. npr, 2021.

3.         Hannah Ritchie, E.M., Lucas Rodés-Guirao, Cameron Appel, Charlie Giattino, Esteban Ortiz-Ospina, Joe Hasell, Bobbie Macdonald, Diana Beltekian and Max Roser, Coronavirus Pandemic (COVID-19). OurWorldInData.org, 2020.

4.         Bolongaro, S.R.a.K., Canada has reserved more vaccine doses per person than anywhere. BNN Bloomberg, 2020.

5.         Berlinguer, G., Bioethics, health, and inequality. Lancet, 2004. 364(9439): p. 1086-91.

6.         Solís Arce, J.S., et al., COVID-19 vaccine acceptance and hesitancy in low- and middle-income countries. Nature Medicine, 2021. 27(8): p. 1385-1394.

7.         The effects of virus variants on COVID-19 vaccines. World Health Organization, 2021.

8.         Ozawa, S., et al., Estimated economic impact of vaccinations in 73 low- and middle-income countries, 2001-2020. Bull World Health Organ, 2017. 95(9): p. 629-638.

 

Education in the Pandemic Era

Education in the Pandemic Era: Insight into the Future of Schooling for Students with Developmental Disabilities

Jayati Sharma

COVID-19 has undoubtedly changed the face of education around the globe. With over 90% of US households reporting some form of distance learning since the onset of the pandemic, online learning has become a core & lasting part of many Americans' lives this year, with the potential to last far into 2021, too.

Many children and families struggled through March's abrupt transition to distance learning, and continue dealing with the subsequent aftershocks of obstacles in the face of this unprecedented scale of online learning. A rather quiet, often overlooked portion of the student population has, however, found at least some solace in this transition from in-person to online education. Children with neurological and developmental disabilities have, compared to their neurotypical peers, gleaned some benefit from being able to avoid the social factors of in-person schooling that often create undue stress, depression, and anxiety.1

Despite gaining some valuable benefits, however, many of these students have disproportionately  suffered from the lack of social interaction that they require, a notably common feeling for students everywhere.2 A hybrid educational format appears sorely needed to address the unique experiences of students with developmental disabilities.

To date, there exist few to no federal laws surrounding special education in hybrid and virtual settings. However, the US Department of Education has put forth guidance for schools in all 50 states to prioritize the accessible and equitable delivery of education to all students with disabilities using online education, which has been re-emphasized since March 2020.3 To cement these priorities in law and produce actionable goals in reducing education disparities broadly and specifically for students with developmental disabilities, three key areas for policy change emerge:

1. Integrating hybrid in-person & virtual education formats going forward

Children will still of course need in-person instruction for their social and educational progress. A targeted goal of integrating in-person and virtual education for students with developmental disabilities will be a step towards promoting these student's academic success without sacrificing their mental health. A recent qualitative study found that state education policies that leverage research-based virtual education practices and explicitly define virtual education goals has been found effective in maintaining virtual school graduation rates >= 60%.4 Practical goal-setting must be the first priority in creating equitable learning environments for the future.

2. Mitigating the effect of digital inequality/inequity through regular federal & state funding and evaluation

Since the beginning of the pandemic, disparities in access to essential resources needed for virtual learning (internet connectivity, laptops, tablets, etc.) have been well documented, especially in chronically underfunded and systemically disadvantaged communities.5 These disparities, exacerbated by the lack of a national strategy or guidance for schools, have only been addressed in districts and states with available funds. A Texas school district that engaged its community in open communication, redirected funds towards providing Chromebooks to all families, and created supplemental education opportunities for disadvantaged found success in virtual learning outcomes.6 Policy that underscores the importance of mitigating resource access imbalances will improve educational outcomes for all students.

3. Create specialized online teaching curricula to develop educational expertise

The 2015 report from The Center on Online Learning and Students with Disabilities (COLSD) highlighted, with significant foresight, the policy goal of creating and regularly evaluating structured online teaching curricula and certificates to prioritize quality virtual instruction for students with developmental disabilities.7 Just this year, teachers have been under immense pressure to adapt to virtual, in-person and hybrid formats at the pace of changing state and national guidance, or lack thereof. Creating cogent achievable virtual learning curricula will lessen educational disparities in these students.

Though all children have suffered due to the physical, mental, and emotional toll of the pandemic, some aspects of the virtual learning environment have highlighted the potential for continuing hybrid education formats, especially for children with developmental disabilities. Each student and family's experience throughout the pandemic has been paradoxically both unique and universal. Federal and state governments must invest in the future of education to avoid the shaky, obstacle-ridden transitions to hybrid and virtual learning in the face of future public health crises, and to better support education for all students in the country.

Without this due redress, the ever-present disparities in education seen between more and less socioeconomically disadvantaged families and communities will only grow.

References:

1 Reicher D. (2020). Debate: Remote learning during COVID-19 for children with high functioning autism spectrum disorder. Child and adolescent mental health25(4), 263–264. https://doi.org/10.1111/camh.12425
2 Constantino, J. N., Sahin, M., Piven, J., Rodgers, R., & Tschida, J. (2020). The Impact of COVID-19 on Individuals With Intellectual and Developmental Disabilities: Clinical and Scientific Priorities. The American journal of psychiatry177(11), 1091–1093. https://doi.org/10.1176/appi.ajp.2020.20060780
3 Urging States to Continue Educating Students with Disabilities, Secretary DeVos Publishes New Resource on Accessibility and Distance Learning Options. U.S. Department of Education. https://www.ed.gov/news/press-releases/urging-states-continue-educating-students-disabilities-secretary-devos-publishes-new-resource-accessibility-and-distance-learning-options

4 Yi, J. (2020). A Grounded Theory Study: A Snapshot of States' Governing Practices on K12 Virtual Education Programs. ProQuest Dissertations Publishing. https://search.proquest.com/docview/2465448874?fromopenview=true&pq-origsite=gscholar

5 Measuring Household Experiences during the Coronavirus Pandemic: Household Pulse Survey - Phase 3. US Census. https://www.census.gov/data/experimental-data-products/household-pulse-survey.html

6 Tremmel, P., Myers, R., Brunow, D.A., & Hott, B.L. (2020). Educating Students With Disabilities During the COVID-19 Pandemic: Lessons Learned From Commerce Independent School District. Rural Special Education Quarterly, 29(4), 201-210. https://doi.org/10.1177/8756870520958114

7 Basham, J.D., Stahl, W., Ortiz, K.R., Rice, M.F., & Smith, S.J. (2015). Equity Matters: Digital & Online Learning for Students with Disabilities. The Center on Online Learning and Students with Disabilities. https://kuscholarworks.ku.edu/bitstream/handle/1808/22627/2015_COLSD_Annual-Publication_FULL.pdf?sequence=1

 

Resources to Learn More:

http://www.centerononlinelearning.res.ku.edu/

https://www.census.gov/data/experimental-data-products/household-pulse-survey.html

 

Mass Transit in the age of COVID-19: What lies on the tracks ahead?

Steven Jerjian

On 23rd January 2020, authorities in Wuhan, China, shuttered the entire city public transit network to fight the spread of coronavirus. Nonetheless, the virus was already rapidly spreading around the world. By early April, New York City subway ridership had plummeted by 92% as travel was strongly discouraged and stay-at-home orders were in place.

While the freefall of international air travel amid the pandemic may have garnered the most public attention, the short-term impacts closer to the ground have been just as severe. Public transit administrations, many already struggling, are now facing crises. Fare revenue and passenger numbers collapsed across the world in early 2020, and slow, unsteady recoveries have followed over the months since( 1,2). Adjustments in service schedules have saved some expenses, but with the need to avoid overcrowding, many services still run well below capacity, and enhanced cleaning protocols have been costly. Meanwhile, the toll of COVID-19 infection on transit workers has been dire (3,4).

To alleviate the short-term economic impacts of COVID-19 and keep transit systems treading water, US policymakers have strived to incorporate financial aid in support packages. The CARES Act passed in March last year included $25 billion for the Federal Transport Administration to allocate to public transit. However, there remain pleas for more support to stave off further service cuts and staff layoffs (5,6). In December, leaders from Washington D.C., Maryland, and Virginia urged the then-incoming Biden-Harris administration to increase federal funding and make a long-term commitment to the D.C. area metro network, which has underpinned federal government operations for some time. The network now faces a $500 million shortfall by 2022 and may have to eliminate 3,800 positions (7).

Even as widespread vaccination by mid-2021 has become a welcome possibility, the future of public transport depends on rehabilitating public confidence in its safety, and strategic investment to improve and expand viable transit options.  

 Despite initial fears that outbreaks in cities like New York were exacerbated by transit use, evidence from a report commissioned by the American Public Transportation Agency (APTA), suggests limited COVID-19 transmission risk for passengers on mass transit systems, at least for short journeys, due to a combination of reduced crowds, mask mandates, sanitization protocols, and ventilation systems (8). Ridership levels have not fluctuated in line with recent surges in COVID-19 cases in the US and multiple countries in Europe and Asia, and no known ‘super-spreader’ events have been linked to mass transit. However, the weak recoveries in transit ridership but faster rebounds in car use following the easing of initial restrictions suggest that fears over COVID-19 may be driving people with the option to favor the convenience and perceived safety of private vehicles (9).  As new information and data on the efficacy of safety measures on public transit become available, strong cross-platform messaging on these facts, from transit administrations, advocates, and local leaders, is essential to assuage public fears and attract riders. Effective campaigns to encourage personal hygiene and the importance of mask-wearing on transit (belatedly mandated by the CDC (10)) have restricted the incidence of outbreaks and provide a ready blueprint.

Beyond this, structured investment is also critical to bolster and expand existing networks, as well as improving service reliability, to encourage ridership. In a world adjusting to the devastation caused by the pandemic, investment can support the implementation of contactless payment technologies, and the development and deployment of apps providing health guidance, as well as detailed, real-time updates on services, crowding levels, and passenger flow (8). These will all be essential for managing increases in ridership levels while maintaining appropriate safety procedures.

Although it remains to be seen in what capacity people working from home will return to physical workspaces, the benefits of investing in transit systems are several-fold. Transit systems across the world have continued critical operations to provide travel for many essential workers on the pandemic frontline. In the US, lower-income workers, students, and people of color constitute a large proportion of public transit riders, making investments in these systems a matter of racial and socioeconomic equity. Investment in public transport directly provides and maintains jobs and stimulates economies by improving accessibility. Safe, efficient networks can drive reductions in congestion, emissions and the incidence of road traffic accidents. Through interfaces with cycling options and walkable neighborhoods as part of a coordinated transport and ‘streetscaping’ policy, incentivizing people to drive less can make timely and necessary contributions to a healthier population and a healthier planet (11,12). Beyond the current turmoil and longer-term global ramifications of COVID-19, the existential threat of climate change looms large.

The financial strain many US transit administrations were under even before COVID-19 mean that investments to modernize and revitalize local and national transit infrastructure should be a legislative priority for the new administration and Transportation Secretary, Pete Buttigieg. Encouragingly, Biden’s American Rescue Plan proposes $20 billion in relief funding for transit agencies, acknowledging their essential role in rebuilding the economy (13).

While the economic and human cost of COVID-19 on public transit worldwide has been heavy, there is a unique opportunity for countries, not least the US, to steer clear of a regressive increase in private car use, and ensure that a robust and equitable economic recovery, as well as the battle against climate change, are spearheaded by sustainable and green modes of public transport.

 Steve Jerjian is a Postdoctoral Fellow at the Zanvyl Krieger Mind/Brain Institute at Johns Hopkins University

Twitter/Instagram: @sjjerjian

References (last accessed 01/31/2021)

1.     https://www.politico.com/states/new-york/albany/story/2020/10/19/transit-operators-across-the-globe-face-a-reckoning-1327371

2.     https://www.theigc.org/blog/impact-of-covid-19-on-public-transport/

3.     https://prospect.org/coronavirus/six-months-into-the-pandemic-transit-workers-are-still-dying/

4.     https://time.com/5869375/public-transit-coronavirus-covid/

5.     https://www.apta.com/news-publications/press-releases/releases/new-heroes-act-is-critical-to-public-transit-survival/

6.     https://usa.streetsblog.org/2020/12/15/new-covid-19-relief-bill-starves-transit-again/

7.     https://mayor.dc.gov/release/dc-maryland-virginia-call-additional-federal-funding-wmata

8.     https://www.apta.com/research-technical-resources/research-reports/public-transit-and-covid-19-pandemic-global-research-and-best-practices/

9.     https://usafacts.org/articles/covid-public-transit-decline/

10.  https://apnews.com/article/joe-biden-travel-transportation-airlines-coronavirus-pandemic-70025b2a6e1cc0ec44be214ba08c94a4

11.  https://www.masstransitmag.com/management/news/21202717/ca-editorial-transit-is-in-a-death-spiral-better-service-bus-lanes-and-other-smart-investments-can-save-it

12.  https://www.wri.org/blog/2020/04/coronavirus-public-transport-stimulus-packages

13.  https://www.ttnews.com/articles/bidens-transportation-aid-covid-19-package-congressional-radar

 

 

Embracing discomfort through COVID-19

Embracing discomfort through COVID-19

Joshua Hooks

A couple of months ago, something remarkable happened. I was going to the grocery store and as has become customary, I tied my double stranded face mask before leaving the car. But this day, unlike many before it, the act was almost unconscious. The tie behind my head, which for weeks felt clumsy and foreign, was finished in a matter of seconds, and I was out of the car before I knew it.

I know this sounds ordinary to many by now, but I am once again amazed by how quickly we, as humans, can adapt to a “new normal”. When faced with disruptions in life, as trivial as a stubbed toe or as major as a global pandemic, people manage to eventually recalibrate and carry on. Some take longer than others, and it certainly is not always a smooth transition, but I am constantly impressed by how quickly we collectively push through setbacks, changes, and tragedies with a desire to “keep on keeping on”. 

While ruminating on this thought, it occurred to me that perhaps the harder thing for people to do is to resist the urge to accept a reality that feels outside their control. It seems to me that the desire to adapt and adjust to the current situation at hand is so incredibly human that resistance to that inclination is often the more difficult option. I think we make things “normal” for many reasons. Perhaps it is partly a survival instinct or partly a way to stay sane during chaos and hurt. The energy it takes to keep getting angry by a repeated injustice or to grieve a loss every time it crosses your mind would be debilitating. Paradoxically, keeping the pain of an issue at the forefront of our mind is what gives us the resolve to actively work against it and change our circumstances. 

So yes, this is yet another plea to stay diligent. To endure the awkwardness of wearing a mask while visiting parents or grandparents. To delay or reimagine the amazing birthday party or baby shower that you had been hoping for. I don’t want anyone to get used to cancelling these events or even to get used to wearing a mask, to the contrary let the disruption, and the exasperation that you feel, keep the magnitude of this pandemic at the top of your mind.

The alternative is that we grow accustomed and numb to 3,000+ COVID-19 deaths a day, that we normalize super spreader events and jeopardize the wellbeing of the most vulnerable among us. While we have gotten much better at treating COVID-19, the daily reality is still severe and long-term consequences are still being determined. From the massive outbreaks and deaths that are rising in assisted living facilities, to recent studies finding inflammation around the heart following mild or asymptomatic cases in student athletes, we have a long road ahead of us. To face the tragedy that is this pandemic with the passion and resolve that is needed we must fight the inclination to make any part of this year a “new normal”.

Resources

  1. Kevin Stankiewicz & Rattner (2020). Nursing homes create ‘perfect storm’ for Covid outbreaks as cases and deaths surge again. Retrieved from: https://www.cnbc.com/2020/11/30/covid-cases-and-deaths-in-nursing-homes-are-getting-worse-.html

  2. Sengupta (2020). Even if you’re asymptomatic, COVID-19 can harm your heart, study shows – here’s what student athletes need to know. Retrieved from: https://theconversation.com/even-if-youre-asymptomatic-covid-19-can-harm-your-heart-study-shows-heres-what-student-athletes-need-to-know-149243

The Climate Action Now Act & The Paris Agreement

The Climate Action Now Act & The Paris Agreement

Tatiana Eaves

The Climate Action Now Act was introduced in the House on March 27 as bill number H.R. 9, by Rep. Kathy Castor (D-FL14). H.R. 9 is legislation that directs the president to develop a plan for the United States to meet its nationally determined contribution under the Paris Agreement. It requires the U.S to remain in the Paris Agreement beyond 2020 by preventing the administration from using any federal dollars to withdraw from the agreement.

In September 2016, during his closing months as president, Obama formally entered the Paris agreement. With that he also committed the United States to reducing its emissions by 26% below its 2005 levels by 2025. The Paris Agreement is an agreement within the United Nations Framework Convention on Climate Change (UNFCCC) that deals with the greenhouse gas emissions mitigation, adaptation and finance signed in 2016. The language of this agreement was negotiated by representatives of all major emitting countries (196 state parties) at the 21st Conference of the Parties of the UNFCCC in Paris, France. The only significant emitters that have not signed on are Syria and Nicaragua.

The long-term goal of the Paris Agreement is to keep the increase in the global average temperature well below 2 °C above pre-industrial levels and to limit the increase to 1.5 °C, in efforts to substantially reduce the risks and impacts associated with climate change. It also aims to increase the ability of parties to adapt to the adverse impacts of climate change and make "finance flows consistent with a pathway towards low greenhouse gas emissions and climate-resilient development". Under the Paris Agreement, each country must determine, plan, and regularly report on the contribution that it undertakes to mitigate global warming.

The U.S. is responsible for about 15% of global greenhouse gas emissions. Since Trump’s decision to pull out of the Paris Agreement, a wave of states, cities, and corporations have stepped up and made ambitious commitments to reduce climate-damaging pollution. For example, Virginia’s Governor Ralph Northam announced that the state will be joining the Transportation and Climate Initiative (TCI), a group of northeastern and mid-Atlantic states that work together to reduce pollution from the transportation sector—which, in Virginia, is the largest source of greenhouse gases. California’s Governor Jerry Brown signed into law two bills that help provide a roadmap for addressing greenhouse gas emissions from buildings—which represent a quarter of California’s emissions—produced by burning fossil fuels onsite for heat and hot water.

Public concern about our climate crisis has also risen across generational, geographic, and partisan lines. The shift in public opinion is fueled in part by extreme storms, record heat, and dire scientific reports emphasizing the urgency to act. The Climate Action Now bill is a result of these public shifts in opinions and concerns. This bill will achieve its goals of limiting greenhouse gases and promoting green jobs due to the specific deadlines it sets on the President to report his climate plans. “H.R. 9 requires the President to develop and update annually a plan for the United States to meet its nationally determined contribution under the Paris Agreement on climate change. The bill outlines what must be included in the plan, including descriptions of steps to (1) cut greenhouse gas emissions by 26%-28% below 2005 levels by 2025, and (2) confirm that other parties to the agreement with major economies are fulfilling their announced contributions. The President must seek and publish comments from the public when submitting and updating the plan”.

It also requires that within six months, the President must report on the effect of the Paris Agreement on clean energy job development in rural communities and contract with the National Academy of Sciences to report on the potential impacts of a withdrawal by the United States from the agreement on the global economic competitiveness of the U.S. economy and on U.S. workers.

This bill marks the first congressional vote in a decade to address the threats of climate change. This is monumental and representative of the change our society is facing in reference to public opinion on climate change. However, as this bill has passed the House it is unlikely to pass the Senate or even come to a vote. The reasons being that it is a Republican majority and President Trump wishes to pull out of the Paris Agreement altogether. I wonder if this policy is too ambitious to pass the Senate at this time and know that there is potential for this bill to be bipartisan. In the House, it was seen as a democratic bill as most supporters were democrats and there were only three republican signatures.

Many opponents counter that the Paris Agreement is economically costly and burdens the U.S. to international norms instead of self-directing its own energy future; that the Paris agreement will cause Americans to lose jobs in the energy sector and that taxpayer money is wasted due to the proposed Green Climate Fund that would collect $100 billion per year by 2020. The goal of this fund would be to subsidize green energy and pay for other climate adaptation and mitigation programs in poorer nations. I personally do not agree with these claims as green energy is highly profitable and brings in millions of jobs and I believe it is our duty as a major industrial country to pay for green innovation in poorer nations.

The climate crisis is catching up with us. Climate change is expected to lower our economy by increasing the losses of American infrastructure, increasing export/import prices for fish, and negatively effecting the tourism industry.  The IPCC report states that extreme weather in the last 3 years has cost our country $400 billion in damage and the climate is already changing faster than previous models predicted. That means on our current path this number is expected to keep growing year after year. By 2020 it is expected that coastal damages will cost $120 billion. For example, the frequency at which regularly dry areas in Miami have become substantially flooded occurred 5-10 times per year in previous years, which was easily manageable by the city. Now the flooding has reached a frequency of 30-40 times per year due to overall sea level rise. That has increasingly negative effects on tourism and revenue overall.

I believe that staying in the Paris Agreement is the only way we will tackle these issues and reduce the detrimental impacts that climate change will have on people’s livelihoods and the economy. This was traditionally not a partisan concept. I am wondering how in today’s political climate we can make this a bipartisan bill. The main concept of this bill is to not pull out of the Paris Agreement. Therefore, I am unsure where the policy might be adjusted or improved. Potential lies in the timeline the president has in reporting the impacts of the Paris Agreement on the economy and laying out specific plans for lowering the emission rate of the country. It is also difficult to ensure that other major polluters like China are doing their part in the Paris Agreement. It is difficult to put money and effort into green infrastructure if other major polluters are not doing the same. Lastly, I wonder if the Paris agreement itself could be modified to hold all countries accountable more effectively and also obtain international support.

 

Resources

1.     Congress.gov (2019). H.R.9 - Climate Action Now Act

2.     EPA.gov (2014). Global Greenhouse Gas Emissions Data.  Retrieved from: https://www.epa.gov/ghgemissions/global-greenhouse-gas-emissions-data#Country

3.     IPCC (2014). Climate Change 2014: Mitigation of Climate Change . Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Edenhofer, O., R. Pichs-Madruga, Y. Sokona, E. Farahani, S. Kadner, K. Seyboth, A. Adler, I. Baum, S. Brunner, P. Eickemeier, B. Kriemann, J. Savolainen, S. Schlömer, C. von Stechow, T. Zwickel and J.C. Minx (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.

4.     IPCC (2018). Global warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty [V. Masson-Delmotte, P. Zhai, H. O. Pörtner, D. Roberts, J. Skea, P.R. Shukla, A. Pirani, W. Moufouma-Okia, C. Péan, R. Pidcock, S. Connors, J. B. R. Matthews, Y. Chen, X. Zhou, M. I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, T. Waterfield (eds.)]. In Press.

Does the U.S. Need a New Deal on Stem Cell Policy?

Does the U.S. Need a New Deal on Stem Cell Policy?

A. Rahman Ford, JD, PhD

Newly-appointed FDA Commissioner Stephen Hahn may be facing a Rooseveltian moment in stem cell policy.

In the midst of the Great Depression, President Franklin D. Roosevelt instituted his New Deal, a series of reforms aimed at quelling the economic uncertainty that Americans were facing as a result of a devastated economy. In his First Inaugural Address, Pres. Roosevelt famously remarked, “the only thing we have to fear is fear itself – nameless,  unreasoning, unjustified terror which paralyzes needed efforts to convert retreat into advance.”

While certain not as dire as the Great Depression, stem cell policy may likewise be in an uncertain position. Despite its intention to provide clarity in a nebulous regulatory landscape, the current FDA stem cell regulatory framework – found principally in the FDA’s 2017 guidance – has arguably created policy confusion in its practical application. Thus, American stem cell policy may need to be revisited.

Possible re-evaluation could begin with a distinction between autologous and allogeneic therapies, with the states assuming regulatory authority over the former and the FDA assuming authority over the latter. This could make administrative sense for three reasons: (1) it is debatable whether the FDA was ever intended to exercise authority over autologous stem cell therapies (SCT): (2) increased FDA regulation of SCT has been of questionable effectiveness; and (3) states have the required institutional apparatuses to police clinics offering SCT within their respective jurisdictions.

In the context of SCT, the FDA defines “autologous” as the “implantation, transplantation, infusion, or transfer of human cells or tissue back into the individual from whom the cells or tissue were recovered.” Autologous cells are extracted from a parson and then re-administered to that same person. Conversely “allogeneic” SCT use stem cells from another person.

It might be administratively prudent for the FDA to relinquish its regulatory authority over autologous SCT for several reasons. First, autologous therapies were long considered “practice of medicine.” As Teo (2017) notes, “the FDA has always been clear on its stance: it does not regulate the practice of medicine between physicians and patients.” Indeed, a person’s own stem cells were only legally deemed “drugs” in 2006 when the FDA changed 21 CFR 1271, amending “into another human” to “into a human,” according to Michael Freeman and  Mitchell Fuerst.

During FDA administrative hearings in the 1990s, several organizations such as the American Red Cross, the American Society for Clinical Oncology (ASCO) and the Society for Assisted Reproductive Techniques argued that the FDA was only granted authority over allogeneic tissue transplants, to control the transmission of communicable diseases. Since then, the FDA has continued to widen its regulatory scope over autologous therapies. The benefits of its extension of authority have questionable.

Second, the FDA guidance was intended to provide clarity; however, vagueness and ambiguity persist in practice. Disagreement among stem cell researchers, ethicists, industry and clinicians has been pointed and acrimonious to the point of stale mate. One camp advocates for increased FDA regulation and enhanced enforcement efforts against “rogue” SCT clinics. The other camp recommends less-restrictive regulations and a more liberal revision of the FDA Guidance. Both camps agree that current stem cell policy is unsustainable and in need of re-evaluation.

For its part, the FDA has repeatedly issued warning letters to clinics offering unapproved stem cell products. The FDA has also filed federal lawsuits in Florida and California seeking injunctions. At the same time, patient demand is increasing rapidly, as evidenced by the increasing number of clinics offering stem cell therapies. Despite these efforts, nether camp is content with the FDA’s current stem cell policy posture.

Third, the states are institutionally capable of regulating autologous SCT in their respective jurisdictions, through legislation, prosecution or through professional licensing boards. In 2017, Texas Governor Greg Abbott signed a law that makes Texas the first state to authorize the use of SCT for patients with certain severe chronic condition or terminal illnesses. Arkansas is on course to be the first state to require medical insurance companies to cover SCT. New York State Attorney General Letitia James filed a lawsuit against a clinic offering SCT, maintaining that it misled patients with deceptive marketing practices. The Illinois Department of Financial and Professional Regulation is also investigating patient complaints.

For a potential Commissioner Hahn-led stem cell policy New Deal, distinguishing between autologous and allogeneic therapies and allowing states to take the lead on autologous therapies may be a viable first step.

A. Rahman Ford, J.D., Ph.D. is a freelance writer on the topic of stem cell policy. He earned his J.D. from the Howard University School of Law and his Ph.D. in Political Science from the University of Pennsylvania. His writing can be found at https://www.clippings.me/arahmanford.

Mass Shootings: Are We Focusing on the Right Thing?

Mass Shootings: Are We Focusing on the Right Thing?

Eric Kramer

Based on the news, it seems like mass shootings are occurring practically every day. While it is true that the rate of mass shootings in the U.S. has been steadily increasing over the past 30 years (1), mass shootings still result in only a small portion of total gun deaths in America (2). In cities like Baltimore, citizens are falling victim to gun violence in the streets on a daily basis, however these tragedies get little mass media coverage. On the other hand, it seems Americans are in a state of paralytic fear at the thought of mass shootings. Widespread media coverage of these mass shootings has created huge debate over issues like guns and mental illness. Clearly, we all want to prevent these shootings from happening, but are we a) focusing on the right issue? and b) implementing the policies most likely to prevent these tragedies?

Our goal should be more broad: to reduce gun violence in America. By doing so, not only will be reduce mass shootings, but we will save countless more American lives by focusing on those that may fall victim to gun violence outside of a mass shooting. If your home was infested with hundreds of mice, but you kept seeing only the same two mice in the kitchen, would you only get rid of the two “troubling” mice, or would you want to get rid of them all? Hopefully, you thought ‘get rid of them all’. While not the perfect analogy, this idea still applies to gun violence. Why focus on the “troubling” mass shootings (where you will have minimal impact), when you could have a much bigger impact on reducing gun violence in America? How do we start

The solution starts with reframing the episodic depictions of mass shootings. Too often, mass shootings are blamed on people with mental illnesses. Policymakers then go on to advocate for better access to mental health treatment, largely ignoring the issue of gun control. In reality, not all mass shootings are done by individuals with mental illnesses. More generally, people with mental illnesses are not more dangerous or more prone to gun violence than the general population (3). Most people with serious mental illnesses are not violent, and the individuals that are,  are responsible for only a small proportion of gun violence (2). In addition, people with mental illnesses are no more likely to carry guns than the general population (4).

Once we are more self-aware of news media depictions of mass shootings and how mental illness should not be blamed (as this could further stigmatize mental illness and prevent people from seeking treatment) (5), we can focus on the chief cause: guns. Several policies have actually proven to be effective in reducing gun violence in America, yet there has been little progress in translating these policies into federal law. These policies include permit-to-purchase laws, safe-storage laws, and “red-flag” laws (6). I will not go on to detail these laws, but briefly, requiring a permit (with an extensive background check) to purchase a gun, mandating firearms be stored in a safe way, and allowing for guns to be taken away from those deemed to be immediate dangers to themselves or others, have all shown to be effective ways of reducing gun violence (6). Together, in addition to investing into addressing social determinants of health and promoting health equity, these offer great potential for reducing gun violence.

We need to work together to end the gun violence epidemic in America. Go out and vote. Contact your representatives and express your anger that nothing is being done to stop people from dying from guns. Tell them you believe guns are at fault, and that we should not be blaming gun violence on people with mental illnesses. Instead, we should be helping and encouraging people with mental illnesses to seek treatment by destigmatizing mental illness. Reach out to your local gun violence advocacy groups and find out how you can help. Only together can we make a difference and take on gun rights groups like the NRA.

References

1. CDC. Stats of the States - Firearm Mortality. (n.d.). Retrieved October 12, 2019, from https://www.cdc.gov/nchs/pressroom/sosmap/firearm_mortality/firearm.htm.

2. Mcginty, E. E., Webster, D. W., Jarlenski, M., & Barry, C. L. (2014). News Media Framing of Serious Mental Illness and Gun Violence in the United States, 1997-2012. American Journal of Public Health, 104(3), 406–413. doi: 10.2105/ajph.2013.301557

3. Elbogen, E. B., & Johnson, S. C. (2009). The Intricate Link Between Violence and Mental Disorder. Archives of General Psychiatry, 66(2), 152. doi: 10.1001/archgenpsychiatry.2008.537  

4. Swanson, J. W., Mcginty, E. E., Fazel, S., & Mays, V. M. (2015). Mental illness and reduction of gun violence and suicide: bringing epidemiologic research to policy. Annals of Epidemiology, 25(5), 366–376. doi: 10.1016/j.annepidem.2014.03.004

5. Mcginty, E. E., Webster, D. W., & Barry, C. L. (2013). Effects of News Media Messages About Mass Shootings on Attitudes Toward Persons With Serious Mental Illness and Public Support for Gun Control Policies. American Journal of Psychiatry, 170(5), 494–501. doi: 10.1176/appi.ajp.2013.13010014

6. Crifasi, C. (2018). Gun Policy in the United States: Evidence-Based Strategies to Reduce Gun Violence. Applied Health Economics and Health Policy, 16(5), 579–581. doi: 10.1007/s40258-018-0413-

COVID-19’s Momentum May Drive the ‘Open Science’ Movement Forward

COVID-19’s Momentum May Drive the ‘Open Science’ Movement Forward

Pelin Ozel

Along with the spread of the respiratory virus COVID-19, financial markets and healthcare providers bear the stress of growing public concerns and an increase in media coverage. Despite this growth in media coverage and public awareness of the urgency of COVID-19, the “open science” movement gains an advantageous momentum.

The spread of the virus has shaped our interactions and behaviors. The Harvard Business Review suggests that COVID-19 and its “severe exogenous demand and supply shocks” related to consumer confidence “can also push the real economy into a contraction.” On one hand, the spread of the virus manifests in our behaviors by straining consumer confidence and the trust between science and the public. On the other hand, COVID-19 provides eustress, or a positive stressor, by shaping how we interact with new research through open science. It is possible that COVID-19 will create an enduring change in the interactions and communication within scientific research as well.

In December of last year, the discourse between advocates for the open science movement and proponents of peer-reviewed journals intensified as the Trump administration set the stage for issuing an executive order. The Fair Access to Science and Technology Research Act, first introduced in 2013, would force an earlier release of taxpayer funded research and require free access to published manuscripts from research agencies with an annual budget of $100 million or more. This act, the Washington Post clarifies, would “force the public release of journal articles within six months of publication.”

Critics of the open science movement assert that the executive order for open access publishing may push researchers to find funding outside of the federal government through grants provided by private research institutions, pharmaceutical companies, or other benefactors. Although the research funding behind institutions may shift focuses, UNESCO explains that open science publishing would “make science more transparent” to promote “inclusive, effective…scientific collaboration and discovery across scientific fields” beyond funding sources. We are already seeing open access publishing thrive within a community to study COVID-19.

Open access science calls for public, free, and accessible forms of scientific research publishing. Recently, COVID-19 has created a microcosm for open access in epidemiology research. Computational evolutionary biologist Dr. Trevor Bedford at the Fred Hutchinson’s Vaccine and Infectious Disease Division explains that research on the virus’s genome is shared shortly after sample collection, sometimes between the span of three to six days.

On platforms such as Nextstrain, pathogen genome data are available to public health scientists. The open-source project’s goal aims to “aid epidemiological understanding and improve outbreak response” while providing free, easy access and bypassing the need for peer-reviewed publications. Beyond Nextstrain exist other platforms such as GISAID, specifically facilitating open-access epidemiological discussion on the influenza viruses. Virological.org provides researchers with updates across more open-access platforms such as BioRxiv and NIH’s genetic sequence database GenBank. Dr. Bedford states “getting to a 3-6 day turnaround opens up huge new avenues in epidemiology” referring to the rapid collaboration available on these open-access platforms.

In response to this progression in the open science community, Christian Drosten, a virologist from the Charité University Hospital in Berlin, dispels overinterpretations of information from GISAID on Science Magazine, specifically concerning the strains of viruses sequenced from different regions globally. As a virus spreads, it is natural that some mutations will occur during replication of the virus. Such replication can happen when the virus is transmitted between individuals. He hedges his claims of certain sequencing data by suggesting that between two global communities (e.g. Munich and Bavaria) “[similar mutated strain types on GISAID are] not sufficient to claim a link” between viral spread between two communities. Drosten highlights a big issue with the open science movement—a fast spread of information can be grossly misinterpreted by other scientists. A slight miscommunication in a rapidly moving field can lead to amplification of biases in data. Therefore, it is important to recognize the problems that can also arise and spread through open science platforms that may lead to public misinformation without a filter of scholarly peer-reviewing.

The current scientific narrative behind COVID posits concern and fear. By reframing the scientific narrative, current trends reveal a new narrative on influential communication, rapid responses, and a push for rigorous genomic data. Beyond the media attention garnered by the virus, it is vital to consider the lasting impact COVID-19 may have on our behaviors within the scientific community to shape how the public engages with scientists. As a graduate student at Johns Hopkins Medical School, I can begin to see an increase in collaboration among young scientists through online teaching and communication platforms. The evolution of how my department approaches literature reviews, to which academic journals investigators choose to submit their work, and how graduate students obtain a literature background during rotations will be shaped by the change in the science community’s behavior prompted by COVID-19.

Further Reading

https://hbr.org/2020/03/what-coronavirus-could-mean-for-the-global-economy

https://bedford.io/blog/genomic-epi-for-ncov-response/

http://www.unesco.org/new/en/communication-and-information/portals-and-platforms/goap/open-science-movement/

http://www.unesco.org/new/en/communication-and-information/portals-and-platforms/goap/open-science-movement/

https://www.washingtonpost.com/national/health-science/white-house-moves-to-make-federally-funded-research-open-to-the-public/2013/02/22/e2de59fc-7d22-11e2-82e8-61a46c2cde3d_story.html

https://www.sciencemag.org/news/2020/03/mutations-can-reveal-how-coronavirus-moves-they-re-easy-overinterpret

 

Opinion: Lower the legal limit to save Maryland lives

Opinion: Lower the legal limit to save Maryland lives

Naomi Greene

In November 2019, Governor Larry Hogan spoke at the 16th annual ceremony commemorating Marylanders that were killed by drunk drivers. At the commemoration ceremony, Governor Hogan said “we must continue to do everything in our power to save lives and to prevent future tragedies.”

Between 2013 and 2017, 17,236 Marylanders were injured or killed in motor vehicle crashes with impaired drivers. Alcohol-impaired drivers caused more than a third of all fatal motor vehicle traffic crashes in Maryland in 20173. And one in five Maryland middle school students report riding in a car with someone who had been drinking. These figures show that our current drunk driving laws are not enough. It’s time to look for more solutions. 

When Prohibition ended in 1933, the United States government took a lax approach to regulating drinking and driving. Guidelines created by the National Safety Council and the American Medical Association in 1939 stated that individuals with a BAC less than 0.15 should not be considered under the influence. Even if an individual were pulled over and presumed to be intoxicated, they could refute the evidence in court and escape criminal punishment. In 1983, Utah became the first state to change the legal limit to 0.08 and limit the use of evidence to escape punishment. Other states were slow to follow suit. In 2000, the federal government forced states to reduce their legal limit to 0.08 or risk loosing funds for highway infrastructure.

Currently, the National Transportation Safety Board recommends that states reduce the legal limit from 0.08 to 0.058. Scientists agree that impairment from alcohol begins well before the current 0.08 legal limit. At a 0.05 blood alcohol concentration (BAC), individuals have reduced reaction time, increased drowsiness, and trouble with basic driving tasks including braking, lane changing, and steering. The risk of dying in a motor vehicle crash also increases 4-fold among drivers with a 0.05 BAC, compared to drivers with no alcohol in their system. A study conducted by researchers at the University of Florida found that 360 lives per year were saved from alcohol-impaired motor vehicle crashes across all states that reduced their legal limit from 0.10 to 0.08 in the 1980s and 1990s. We could save an additional 538 lives per year by reducing the limit to 0.056.

Lowering the legal limit complements current drunk driving policies in Maryland. Since 2016, the legislature and Governor Hogan have bolstered DUI laws by mandating ignition interlocks for first time offenders and increasing license fees and suspension periods after a DUI. Ignition interlocks are devices linked to a vehicle ignition system. Drivers breath into the device, which registers their BAC. The vehicle will not start if the device registers a BAC above 0.08. Lowering the legal limit can further reduce the number of people who drive under the influence. Under this policy, law enforcement will catch more impaired drivers. These drivers will have to enroll in the ignition interlock program and will not be able to use their vehicles if they have even one drink. And the policy can have a dramatic effect on people’s decisions to drink and drive.

According to the World Health Organization (WHO), 108 countries have illegal BAC limits of 0.05 or less for the general population. Utah became the first state to reduce the legal limit from 0.08 to 0.05 with a new law enacted on December 31, 2018. The Utah Department of Public Safety reported that the new law has contributed to a decrease in alcohol-related motor vehicle fatalities in the state. Currently, the New York State Legislature is considering a bill to reduce the state’s DUI limit to 0.0513.

On December 5, 2019 – less than two weeks after the ceremony in Annapolis – 15-year-old Trinity Brooks was killed by a drunk driver. So, I implore the Maryland State Legislature and Governor Hogan to consider lowering the legal limit. We should ask ourselves what we stand to lose if we don’t.

For more information about the advocacy to reduce drunk driving in the United States, check out “One More for the Road: Drunk Driving since 1900” by Barron H. Lerner.

References

1.         16th Annual Ceremony Held in Annapolis to Honor Victims of Drunk Driving Crashes [Internet]. [cited 2020 Feb 24]. Available from: https://www.thebaynet.com/articles/1119/16th-annual-ceremony-held-in-annapolis-to-honor-victims-of-drunk-driving-crashes.html

2.         Maryland Department of Transportation. 2018 Maryland imparied driving prevention program area brief [Internet]. [cited 2018 Nov 27]. Available from: http://www.mva.maryland.gov/safety/mhso/FY19_Impaired_ProgramAreaBriefFINAL.pdf

3.         National Center for Statistics and Analysis. Alcohol-impaired driving: 2017 data [Internet]. Washington, D.C.; 2018 [cited 2018 Nov 27]. Available from: https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/812630

4.         Maryland Department of Health. 2016 Youth Risk Behavior Survey Results: Maryland High School Survey Summary Tables [Internet]. [cited 2018 Nov 28]. Available from: https://phpa.health.maryland.gov/ccdpc/Reports/Pages/YRBS-Main.aspx

5.         Novak M. Drunk Driving and The Pre-History of Breathalyzers [Internet]. [cited 2020 Feb 26]. Available from: https://paleofuture.gizmodo.com/drunk-driving-and-the-pre-history-of-breathalyzers-1474504117

6.         Wagenaar AC, Maldonado-Molina MM, Ma L, Tobler AL, Komro KA. Effects of legal BAC limits on fatal crash involvement: analyses of 28 states from 1976 through 2002. J Safety Res. 2007;38(5):493–9.

7.         National Highway Traffic Safety Administration. Legislative History of 0.08 Per Se Laws [Internet]. [cited 2020 Feb 26]. Available from: https://one.nhtsa.gov/people/injury/research/pub/alcohol-laws/08history/

8.         Thompson C. Federal agency says lowering legal limit could cut DUI deaths. The Baltimore Sun [Internet]. May; Available from: https://www.baltimoresun.com/maryland/bs-md-drunken-driving-20130514-story.html

9.         Moskowitz H, Florentino D. A review of the literature on the effects of low doses of alcohol on driving-related skills [Internet]. Springfield, VA; 2000 [cited 2018 Dec 20]. p. 1–62. Available from: https://one.nhtsa.gov/people/injury/research/pub/hs809028/title.htm

10.      Maryland Department of Transportation. New laws impacting Maryland drivers to take effect October 1 [Internet]. 2016 [cited 2020 Feb 24]. Available from: http://www.mdot.maryland.gov/News/Releases2016/2016_Sept_27_New_MVA_Laws_Effective_October_1

11.      World Health Organization. Legal BAC limits by country [Internet]. [cited 2018 Nov 11]. Available from: http://apps.who.int/gho/data/node.main.A1147?lang=en&showonly=GISAH

12.      Blowers C. Utah DPS: DUI crashes, fatalities down, but arrests remain consistent under .05 blood alcohol law [Internet]. St. George News. 2019 [cited 2020 Feb 26]. Available from: https://www.stgeorgeutah.com/news/archive/2019/07/11/cgb-utah-dps-dui-crashes-fatalities-down-but-arrests-remain-consistent-under-05-blood-alcohol-law/#.XlZ3wGhKg2z

13.      Slattery D. New York lawmakers weigh changing how drunk is too drunk to drive [Internet]. New York Daily News. 2020 [cited 2020 Feb 26]. Available from: https://www.nydailynews.com/news/politics/ny-new-york-politicians-want-to-lower-legal-blood-alcohol-content-20200129-l242snw5yrbmnpns3amcm225nu-story.html

14.      Menitoff R. Jennifer Jean Jones Had 94 Bottles Of Liquor, Drugs In Her Car When She Reportedly Struck, Killed 15-Year-Old Trinity Brooks [Internet]. [cited 2020 Feb 26]. Available from: https://baltimore.cbslocal.com/2019/12/05/dundalk-fatal-pedestrian-crash-trinity-brooks-latest/

The Great Waters of the United States

The Great Waters of the United States

Tatiana Eaves

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About 117 million people, or more than one third of the total U.S. population, gets some or all of their drinking water from public water systems that rely in some part on intermittent, ephemeral or headwater streams. This is water pumped through underground pipes from large wells, lakes, rivers, or reservoirs. This water not only is used in our homes but supports our fish and wildlife as well. Keeping this water clean is essential to our nation’s economy and survival.

In 2015 the Obama administration introduced the Clean Water Rule (CWR), known as the Waters of the United States Rule (WOTUS). The aim of this rule was to clarify what actually constitutes as the ‘waters of the United States’. This term was first mentioned in the 1972 Clean Water Act. The Clean Water Act states that WOTUS are ‘traditional navigable waters, interstate waters, and all other waters that could affect interstate or foreign commerce, impoundments of waters of the United States, tributaries, the territorial seas, and adjacent wetlands”. However, this became a hard definition to defend within the supreme courts. What waters are actually federally protected under this rule? There has been much debate over time about what constitutes as WOTUS, which has led to concerns among industry and environmental protection groups alike.

The Obama administration aimed to clear up this definition by defining the scope of federal water protection as particularly over streams and wetlands which have a significant hydrological and ecological connection to traditional navigable waters, interstate waters, and territorial seas. This includes those reservoirs, headwater streams and ephemeral ponds mentioned above.

The CWR was based on a review of 1,200 scientific studies that found that streams and wetlands were connected to waters downstream. The streams and wetlands that the CWR protects not only affect the water quality for fish downstream, but also provide nesting habitat for more than 50 percent of North American waterfowl. Wetlands span over 110 million acres across the U.S., and provide critical habitat for fish and wildlife while simultaneously aiding in filtration of contaminated runoff and groundwater storage. If we lose these wetlands, we risk losing habitat for fish and wildlife and subsequently the economic benefits of having both.

The Trump administration formally suspended the Clean Water Rule on January 23rd. Its replacement will strip protections from more than half of the nation's wetlands and allow landowners to dump pesticides into waterways, or build over wetlands, for the first time in decades.  That could open millions of acres of pristine wetlands to pollution or destruction, and allow chemicals and other pollutants to be discharged into smaller headland waters that eventually drain into larger water bodies. Wetlands play key roles in filtering surface water and protecting against floods, while also providing wildlife habitat.

This is not simply a rollback of Obama administration policies; it rolls back the policies from the ‘70s and ‘80s that protected smaller headwaters. This puts drinking water for millions of Americans at risk of contamination from unregulated pollution. Not only does this new set of policies remove protections for some wetlands and streams that run intermittently or temporarily underground, it will also get rid of a requirement that landowners seek permits from the U.S. Environmental Protection Agency (EPA), which had considered permits on a case-by-case basis before 2015.

The Trump administration’s new rule, which will be implemented in about 60 days, is the latest step in the Trump administration’s push to repeal or weaken nearly 100 environmental rules and laws, loosening or eliminating rules on climate change, clean air, chemical pollution, coal mining, oil drilling and endangered species protections. But farmers and fossil fuel groups supported the change.

PHOTO CREDIT TATIANA EAVES

The Politicization of Disease

The Politicization of Disease

Michael Dryzer

cells-dye-illness-microscopic.jpg

Last week, as I was clicking around the Internet one morning (in that time-frame of “pseudo-work” where one checks emails while their brain is still waking up), I stumbled across this article: “A Costco sample-stand worker turned away a kid wearing a face mask because she thought he was from China and could give her the coronavirus.

The article itself was a tedious read—the gist is that Asian Americans are being unfairly targeted and stereotyped in Washington (the location of the first US case) as a result of the novel coronavirus outbreak (nCoV) in Wuhan, China. I don’t use the word “tedious” to downplay the valid concern about stereotyping present in the article—it is a very real issue that affected our view of African migrants in the 2014 Ebola Pandemic and of Mexican migrants in the 2009 Swine Flu Pandemic before that. Instead, I was anxious as to whether the article I was reading was the first in a long line of similar stories to politicize and polarize the nCoV Crisis.

You might recall the last time something of this nature occurred in the United States and, indeed, around the global community. The 2014 Ebola Pandemic was heavily politicized and, here in the United States, played directly into the Red versus Blue politics we all know and love. This blog post by Scott Alexander discusses the topic more fully than we will here, and is an excellent read, so I suggest that you check it out if you have a few spare minutes. But, the bottom line of is this: A lot of issues, including disease control and prevention, get caught up in the right/left (lack of a) dialogue and become wedge topics that drive “different” groups of people apart, even though these issues affect all groups involved and require communication and compromise to be solved.

Speaking further on the role of this during the Ebola Crisis, the US response was sluggish and disorganized, and it’s fair to say that our national politics was a primary cause of this. On one side, Republicans like Texas Senator Ted Cruz, a 2016 presidential candidate at the time, were lambasting the Obama Administration for not taking Ebola seriously and shutting down our borders. On the other side, Democrats argued that Republican-led budget cuts to the NIH and CDC were to blame. Whether either side was right isn’t the problem here; what is the problem is that too many people were pointing too many fingers for anyone to come together and hash out a plan. The same thing happened during the Swine Flu Pandemic and every other disease in the last 200 years.

Were we always this way? The answer to that question is no. At one point, we were actually worse. Politicization of disease has existed for at least 200 years back before we even knew what viruses were. One early example is the European yellow fever outbreak of 1845. While sailing down the African coast, sailors of the British vessel HMS Eclair contracted yellow fever and briefly made port at the Portuguese settlement of Boa Vista in Cape Verde. When the Eclair eventually left the island and returned to England where it was quarantined, yellow fever had infected to the island’s inhabitants and rapidly began to spread.

The quarantine itself angered the British as people immediately partitioned into two groups and entered a gridlock as to how to deal with the situation. (Sound familiar?) Meanwhile, on the island of Boa Vista a third of the population died as a result of yellow fever—a fact the Portuguese government was not particularly fond of. (Keep in mind that this part of history was egregiously competitive, with all industrialized countries does whatever they could to mess with everyone else’s economies. So, while this event could have been an honest mistake by the British, it could’ve also been used to undermine Portuguese efforts on Boa Vista.) Consequently, international relations deteriorated.

To be fair, it’s difficult to resolve a public health crisis when you don’t know what viruses are, which is why we should be better about such things in today’s world, right? In many ways, this is absolutely correct. We have a variety of different tools at our disposal to monitor, contain, and end the nCoV crisis. The New York Times published an article that offers a primer on the outbreak and answers all the major questions you might have, such as its infection rate, its mortality rate, its symptoms, you name it. Our very own university has created an interactive dashboard that tracks the outbreak in real-time. Finally, in the case of scientific literacy, there are many doing what they can to fight misinformation concerning the virus.

So, it’s not all bad. We have the tools to fight the disease and protect ourselves against its spread and the spread of the lies surrounding it. And honestly, I haven’t seen too many articles like the Costco one at the time of writing this.

But we can’t grow complacent.

We’re still at the very beginning of this outbreak. The virus is still spreading, people are still dying, and politics is still the same as it’s ever been. Just last week the Trump Administration imposed travel restrictions on people who “pose a risk of transmitting the disease” and has begun quarantining returning American citizens. Like I’ve said several times before, I’m not here to argue whether or not this is the correct course of action.

I’m more worried about a case of inaction resulting from political gridlock, and if there is anything that could spark that, it’s something like the incident at Costco or these travel restrictions. By the end of the Ebola Crisis, there were 28,600 cases and 11,325 deaths. Those numbers could’ve been much lower if we the world had acted sooner and more decisively. Let’s not let this happen again. Let’s approach the nCoV Crisis with coordinated, clear-eyed, and evidence-based thinking and save lives.

PHOTO CREDIT: PXFUEL

Internalizing the Climate Crisis Using Technology, Data, and Role play

Internalizing the Climate Crisis Using Technology, Data, and Role play

Talia Henkle

Source: Climate Central

Source: Climate Central

 I had no real idea of what I was getting into when I signed up for the C-ROADS Climate Change Negotiations Simulation at the National Science Policy Network Symposium. The title was provocative and I figured maybe I could learn some more beyond my basic knowledge of climate change.  I was aware that climate change was a serious problem. However, without much of an idea of the tangible impacts, I must admit climate change policy was not among my top policy concerns.

A few days prior to the simulation, I received an email telling me that I was ‘to represent a US delegate in negotiations at the United Nations World Climate meeting’. I looked over the brief.

The goal of our negotiations was to limit global warming to “well below 2°C”, as was agreed upon in the 2015 Paris Agreement. As a US delegate I needed to keep our national interests in mind and ensure all countries were pulling their weight (e.g. China must agree to cut their emissions before the US considers action).

Seemed interesting enough. If any group of participants is likely to figure this out, it’s surely going to be a group of young PhD candidates interested in scientific advocacy (the cohort of attendees at this symposium).

When I arrived to the simulation, as a US delegate, I was directed to a nice table with chairs and decorations. I noticed that students representing India and China didn’t have a table and that those representing Undeveloped Nations had to sit on the floor.

I guess they’re going all out. My interest was certainly peaked.

They opened the activity explaining that C-ROADS is a peer reviewed and award-winning  platform “which allows participants to find out how their proposed policies impact the global climate system in real-time.” We were informed that this platform has been used all over the world. It was even used by President Obama’s climate-change team, including past Secretary of State John Kerry, prior to entering into their negotiations for the Paris Climate discussions.

During our negotiations, as delegates from our assigned nations, we were to determine

1.      What year to cap our CO2 emissions

2.      What year to begin reducing CO2 emissions, and at what rate

3.      How much we were going to reduce deforestation and how much land we were going to devote to afforestation

We would then enter our agreed upon commitments into the platform and it would show us how those policies would affect climate change. The estimates it generates are based on conservative estimations, which befits the preferences of policymakers who are wary of implementing policies based on exaggerations.

And thus it began.

Doing our best to follow our briefs, we began our negotiations. Despite my initial presumption that this simulation would be rather straightforward, Chinese delegates refused to define a date to begin reducing emissions—which was stipulation of the US brief. Additionally, it became clear that developing nations, which stand to be the largest producers of CO2 emissions in the future, need significant financial assistance in order to develop their countries sustainably—which involved an enormous and undesirable financial commitment from the US and other developed nations. This caused us delegates from developed nations to argue over who was to fork over the money and the developing nations to squabble over how much they were entitled.

The first round of negotiations ended in an unorganized blur. Each country announced their policy commitments and the numbers were entered into the C-ROADS platform.

Bad news. Given these policies, our climate was conservatively estimated to increase 4°C (7.2°F) by 2100. Not only did our negotiations fail, but we then we entered our data into the Surging Seas Mapping tool to evaluate the consequences of the corresponding sea level rise on coastal cities around the world. Goodbye Miami. Goodbye Shanghai.

On that dire note we began our second round of negotiations. When those still resulted in warming of 3.5°C (6.5°F) we all worked together to come up with very progressive and aggressive emissions capping and reduction goals. We were very proud of ourselves even if we knew such measures were unlikely to be implemented, particularly given that Donald Trump confirmed his intention of withdrawing the US out of the Paris Climate accord in November 2020. We entered our lofty goals in the C-ROADS simulator, and it still projected that the climate would increase 3°C (5.4°F).

We went through what that entails by year 2100.

·       Sea level rise ~1m

·       ~7.4% increase in the global proportion of land under drought

·       ~17% reduction in freshwater access

·       ~21-52% of plant and animal species committed to extinction

Talk about demoralizing. I couldn’t believe how dire the situation was. The climate crisis suddenly surged to the top of my list of policy concerns. I was gutted and scared.

Illustration by Elise Amel

Illustration by Elise Amel

In the debriefing we discussed why it was so difficult to keep warming to “well below 2°C” and the importance of limiting CO2 emissions as soon as possible. We also discussed actions we could take to help, from recycling to running for office.

Coming out the experience, it was made extremely clear to all of us that profound cooperative global action was immediately necessary in order to mitigate the accumulating global climate problems as much as possible. If our world leaders continue to think only about their own nations’ interests, they are effectively choosing to end life as we know it (and don’t take my word for it—I would encourage everyone to read the executive summary of the 2017 Climate Science Special Report).

It’s natural to look at the enormity of the climate crisis and feel completely helpless and overwhelmed. There are individual changes you can make every day to lower your carbon footprint but all and all this is a larger issue than one person can change on their own. However, there is power in numbers and knowledge is power!

On that note, we’ve resolved to bring this simulation to Hopkins in early 2020! If you are interested in getting involved in this initiative or learning more about how to bring the activity to your organization contact me at thenkle1@jhmi.edu.

Reducing Gun Violence Town Hall 10/31/19

Reducing Gun Violence Town Hall 10/31/19

Eric Kramer & Alice Rhoades

Thanks to the news media and shows such as The Wire, we were familiar with Baltimore’s gun violence long before we made this city our home. While living here as public health students, we have come to learn that Baltimore is so much more than the violence it is known for. However, the fact remains that it has the second highest homicide rate in the nation. Attending a town hall on gun violence drove this problem home, but it also reinforced the city’s sense of community and collaboration that provides promise of finding a solution. 

We arrived early and could feel the excitement in the gallery as community leaders, gun research experts, law enforcement, city council members, and Baltimore citizens came together to discuss this important issue. 

The meeting started with a powerful testimony from Baltimore youth leader, Antonio Moore. He compared Baltimore neighborhoods to warzones as he played two cell phone videos where we could hear gunshots and police sirens. He then proceeded to give a strong call to action to the council and everyone in the room but lamented that he felt he was “preaching to the choir”. 

As representatives from community organizations, the office of the mayor, the police department and researchers (from the University of Maryland, Johns Hopkins, and Harvard) took to the podium to give testimony. Three themes emerged. 

The first was to recognize the impact of trauma due to gun violence that has already sunk its teeth into this city. There was talk of Adverse Childhood Events (ACEs) and the role that experiencing violence at a young age works to perpetuate violence. This drew attention to the need for programs and resources that support victims and families of victims. Thomas Apt of Harvard discussed policies that find balance between support and punishment, policing and programming. Joseph Richardson from SHOCK Trauma also played a powerful clip from his upcoming documentary Life After The Gunshot, which highlights the experiences of male survivors of gun violence.

The second was the need to view youth less as the problem and more as part of the solution. Speaker after speaker emphasized the importance of supporting youth programming and providing grants for youth-led efforts. James Tipson (JT), from the nonprofit Roca, underscored the need for youth to have the ability to make a mistake and recover. Antonio Moore drew attention to the work young people are already doing with limited resources.  

The final theme was a call to break down silos between the sectors and address this issue holistically. This was our main take-away from this town hall. It offered a platform for like-minded individuals to discuss their work and perspectives on gun violence and allow networking across these different organizations. We saw many introductions made and several business cards exchanged. 

It was inspiring to hear the voices of people working hard to address this challenge and we were reminded of the grit and sense of community that are characteristic to Charm City. As Moore mentioned, a lot of this town hall was directed at an audience that understands this issue and recognizes that work needs to be done. However, there seems to be some disconnect between gun experts and actual community members that have been directly affected by gun violence. As Antonio and a mother who lost her son to gun violence pointed out, people are perpetually dying in the streets. How can we use what we know and work with the community to stop these people from dying?

As Master of Public Health students, we were reminded that research and evidence-based programs and policies are all important but real change will not occur unless support is given alongside community members who are on the ground. More work must be done to transform these powerful conversations into policies and programs that will help reduce the impact of this problem. We must hold each other accountable and continue collaboration.  

PHOTO CREDIT SANTA FE REPORTER

Protecting Scientific Integrity

Protecting Scientific Integrity

Tatiana Eaves

In the age of rapid news cycles and technological developments, there have been concerns over the movement of science. Specifically, in how external political and industry forces can influence the quality and scope of scientific research and in general, a professional’s scientific integrity.

Scientists at federal agencies have said external political and industry forces heavily influence the quality and scope of their research, according to a large survey conducted by the Union of Concerned Scientists in 2015, involving thousands of top researchers. This still holds true today. The most recent example comes from the National Oceanic and Atmospheric Administration (NOAA) retracting a public service announcement made by their Chief, presenting false information to the public due to pressures from the executive branch of the government. Additionally, the Government Accountability Office, a federal watchdog, concluded in July that the Environmental Protection Agency violated ethics rules when it replaced academic scientists with industry representatives as members of science advisory panels.

In order for science to keep up with the pace of information spreading and to retain public trust in science and scientists, a new bill has been proposed with an aim of protecting scientific integrity. The Scientific Integrity Act was first introduced by the 115th congress to the House of Representatives by Representative Paul Tonko (D-NY) in April of 2017. This bill unfortunately died when the congress adjourned sine die. Representative Tonko reintroduced the bill when the 116th congress took office with Senator Brian Schatz (D-Hawai‘i).

According to Senator Schatz, the scientific integrity act would do three things: Formalize and reinforce policies that require federal agencies that conduct or fund scientific research to maintain clear scientific integrity principles; affirm that science dictates policy, and that scientific research should be free from the pressure of politics, ideology, or financial influence; and hold public scientists to high standards and guarantee their rights and protections under the law.

The bill was approved by the House of Representatives’ Committee on Science, Space, and Technology on 17 October in a 25–6 vote that included bipartisan support. The need for scientific integrity policies in federal agencies, in particular, has received support from both sides of the aisle during a congressional hearing in July. Both parties stressed the importance of protecting scientists and the scientific process. Although this bill has passed the house, with impeachment hearings and a lot on the plates of congressmembers as of late, we’ll have to see how much bipartisan support this bill has in the Senate. Additionally, if it passes the senate, what will happen when it reaches the President’s desk?

 

“Our economy, our health and safety, and our environment all depend on independent federal scientific research and fully informed, science-based policies. The Scientific Integrity Act would protect scientists from political interference in their scientific work, and make sure that they can carry out their research and share it without fear of retaliation. Congress should pass the Scientific Integrity Act so that all presidential administrations can be held to that strong standard,” - Dr. Andrew Rosenberg, Director of the Center for Science and Democracy at the Union of Concerned Scientists.

PHOTO CREDIT TATIANA EAVES

JHSPG Receives 2019 Research!America Microgrant

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JHSPG Receives 2019 Research!America Microgrant

We are excited to announce that the Johns Hopkins Science Policy Group was awarded a $900 grant from Research!America to fund bipartisan engagement efforts in advocating for and promoting science and evidence-based policy.

The microgrant will be used to fund our 2nd Annual Baltimore City Hall Poster Session in March 2020, which will bring early career researchers (graduate students and post-doctoral students) to present their work to our city council representatives, as well as the Baltimore community, on issues pertaining to our community (gun violence, opioid crisis, nutrition, women's health, etc) to provide an opportunity for dialogue and mutual learning as well as helping trainees learn how to communicate science to a broader audience.


PHOTO CREDIT RESEARCH!AMERICA

In celebration and defense of progress for women's health

In celebration and defense of progress for women's health

I was delighted to read that Planned Parenthood selected Baltimore Health Commissioner Leana Wen as next President. Dr. Wen, an ER doctor, a fierce advocate and outspoken leader in Public Health, is the right person to take on the fight to protect women’s access to reproductive health care in times, in which women’s rights are increasingly under attack, women’s health issues are neglected, and efforts are under way to overturn Roe v. Wade.

Aside from the moral imperative that women should be free to make decisions about their own bodies, there is also vast scientific evidence showing that access to preventive and reproductive healthcare leads to better physical and mental health outcomes. Furthermore, empirical studies have demonstrated that it can interrupt vicious cycles of disadvantage, experienced in particular by young women and women from marginalized communities.

Elected officials should therefore strongly oppose any bill that tries to criminalize abortion as well as the nomination of Brett Kavanaugh to the Supreme Court, a move that threatens to reverse decades of progress for women’s rights, and instead act in accordance with scientific findings and support health care equity and reproductive justice.

PHOTO CREDIT BRETT SIMMONS / CREATIVE COMMONS

JHSPG receives Research!America grant

JHSPG receives Research!America grant

Richard Sima

We are excited to announce that the Johns Hopkins Science Policy Group was awarded a grant from Research!America to fund bipartisan engagement efforts in advocating for and promoting science and evidence-based policy!  

We plan to use these funds to reach out to local candidates of all parties running for office and urge them to keep evidence-based policies in mind.  We also will be organizing events to showcase all the cool, useful research being conducted in Maryland to remind our fellow citizens and our representatives why science is essential to a healthy populace and democracy.  Stay tuned!

PHOTO CREDIT RESEARCH!AMERICA

The Republican House tax plan threatens students, science, and society

The Republican House tax plan threatens students, science, and society

Richard Sima, Kaitlin Wood, Leah Cairns, Jenny Carlson, and Chanel Matney

Last month, the House of Representatives passed its tax reform bill, the Tax Cuts and Jobs Act. Clearing this first legislative hurdle presents an imminent threat to the lives of roughly 145,000 graduate students and could cripple the future of scientific research and innovation in the United States.

As doctoral students in the biomedical sciences at Johns Hopkins University, we receive a living stipend of roughly $30,000 as well as a tuition waiver in exchange for the research and teaching we perform. While we currently pay taxes on our stipends, the tuition waiver is not considered taxable income because none of that money actually ends up in our pockets. The House tax bill would classify this tuition waiver as taxable income. At Hopkins, graduate tuition exceeds $50,000; if this sum were also taxed, the effective tax rate on our stipend would more than quadruple and exceed the tax rate paid by people earning in excess of $500,000 a year. While certain institutions (including Johns Hopkins) can shield their students from this attack, many students will face a tough decision: either take an unexpected and severe pay cut or abandon their doctoral education.

Unfortunately, a tax on the tuition waiver is only the first of many provisions that collectively harm graduate students. The House bill also eliminates the student loan interest deduction, removes the Lifetime Learning Credit, and imposes an excise tax on university endowments. Taken together, these measures compound the burden on students and educators across America.

When we entered graduate school, we accepted that we would sacrifice potentially higher-paying jobs in order to pursue the questions and problems that we are passionate about. This passion drives us to work long hours improving our collective understanding of the world and discovering new tools and technology that benefit all of humanity. Though we are willing to give the energy of our young adult lives to these pursuits, we also need to care for our families and our futures. Our decisions to pursue the opportunities afforded by graduate education are influenced by our individual privileges as well as familial, institutional, and social support. Students who begin with less navigate a more delicate balance between their pasts and futures than those who can rely upon dependable support. The Tax Cuts and Jobs Act will disproportionately burden those who begin with less, subsequently exacerbating the racial and socioeconomic inequalities already present throughout our nation. This tax bill would make higher education financially challenging for all but the wealthiest of students. These new taxes run counter to the ideal of meritocracy at the heart of science and America.

The resulting brain drain stemming from this financial barrier to entry will have long-lasting and far-reaching consequences for research and our country. As current and former graduate students, the five of us are conducting research on a wide variety of topics, including: the molecular mechanisms underpinning premature aging; how bacteria affect mosquito transmission of viruses and parasites; how neurons connect with one another in the cortex; the structure and function of a cancer-causing biological pathway; and, how the brain predicts the sensory consequences of movement.

Our ability to work on these important scientific problems would be stymied by this tax plan. According to a 2016 poll conducted by the nonprofit science policy group, Research!America, a majority of Americans agree that “basic scientific research that advances the frontiers of knowledge is necessary”. Graduate student researchers are an indispensable force that drives both basic and applied scientific innovation. The research we conduct also spurs economic growth; every dollar invested in National Institutes of Health research funding produces $2.21 in goods and services within just one year.

The amount of revenue gained from taxing graduate students is a pittance to the federal government, but will be keenly felt by those affected. In the long-term, scientific progress will be stalled, economic growth hampered, and new cures for diseases delayed. The costs to students, science, and society are far too high to justify passing the Tax Cuts and Jobs Act.

An amendment to the bill to remove the harmful provisions on higher education was made prior to the House vote on the tax reform bill. However, this amendment was voted down along party lines. Protecting the values of higher education and our nation’s future should not be a partisan issue.

  • https://medium.com/@jhscipolgroup/the-republican-house-tax-plan-threatens-students-science-and-society-90cb8fff52f6

September 27: Public Comment deadline for new EPA regulations

By Jenny Carlson

Definition of ‘‘Waters of the United States’’—Recodification of Pre-Existing Rules

AGENCY: Department of the Army, Corps of Engineers, Department of Defense; and Environmental Protection Agency(EPA).

ACTION: Proposed rule.

 

I. What is the overarching issue?

The 1972 Clean Water Act gave the federal government authority to limit pollution to both major bodies of water (i.e. Chesapeake Bay) and to streams and wetlands that drain into those bodies of water. However, in 2001 and 2006, two Supreme Court decisions resulted in legal confusion on whether or not the federal government has the authority to regulate smaller streams, headwaters, and wetlands.

What are the benefits of the existing rule? Protecting upstream waters from pollution also protects drinking water supplies, coastal waters, and help reduce the nitrogen and phosphorus nutrient pollution which lead to dead zones.

Who opposes the existing rule? Farmers, property developers, fertilizer and pesticide producers, oil and gas producers, and golf course owners. Farmers fear that the rule would result in major costs related to environmental assessments and permits.

 

II. What is the goal of the proposed rule?

 Rescind and re-evaluate the definition of “waters of the United States.”

The Clean Water Act of 2015 expanded the definition of “waters of the United States” to include “headwater streams, lakes, and wetlands and other waters that contribute significantly to protect the integrity of navigable waters”1 as a pollution prevention mechanism. The EPA and the Army are proposing a new rule to review and revise this definition, which is consistent with the Executive Order signed on February 28, 2017, ‘‘Restoring the Rule of Law, Federalism, and Economic Growth by Reviewing the ‘Waters of the United States’ Rule.’’

 

III. Leaving a Public Submission- also referred to as a “Comment”- (due September 27th, 2017) on the regulations.gov page: https://www.regulations.gov/comment?D=EPA-HQ-OW-2017-0203-0001

 

Do you support the proposed rule?

o   Your statement should include why you support the rescinding of the definition of “waters of the United States” and reverting back to the standards that were adopted in 2008.

Do you oppose the proposed rule?

o   Your statement should include why you support the current definition of “waters of the United States” and to uphold the one million comments and 1,200 peer-reviewed studies that were reviewed for the 2015 Clean Water Act.

 

IV. Tips on leaving a Public Submission- taken directly from the regulations.gov website[1]

·       State your position (yay or nay) at the very beginning

·       Avoid getting stuck in the weeds of the terminology or policy

·       Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted

·       There is no minimum or maximum length for an effective comment

·       The comment process is not a vote – one well supported comment is often more influential than a thousand form letters

 

V. Do agencies even read my comments?

Yes! See below from regulations.gov.

“On April 21, 2014, the agencies published a proposed rule to reduce uncertainty about the scope of “waters of the United States” covered by Clean Water Act programs, that arose from interpretation of Supreme Court decisions in 2001 and 2006, and the subsequent guidance issued by the agencies in 2008. During the public comment period, which ran until November 14, 2014, over one million comments were received. Stakeholder input received during public outreach events in combination with the written comments received during the public comment period have reshaped each of the definitions included in the final rule, ultimately with the goal of providing increased clarity for regulators, stakeholders, and the regulated public to assist them in identifying waters as “waters of the United States.” The rule reflects the judgment of the agencies when balancing the science, the statute, the Supreme Court opinions, the agencies’ expertise, and the regulatory goals of providing clarity to the public while protecting the environment and public health.”[2]

“Public participation matters. Democratic, legal, and management principles justify why public comments make a difference in regulatory policy. Public participation is an essential function of good governance. Participation enhances the quality of law and its realization through regulations (e.g. rules).”[3]

 

1. https://www.epa.gov/sites/production/files/2015-06/documents/508-final_clean_water_rule_economic_analysis_5-20-15.pdf

2. https://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf

[3] https://www.regulations.gov/docs/FactSheet_Public_Comments_Make_a_Difference.pdf