U.S. Administrative Law eJournal最新文献

{"title":"All the Sovereign's Agents: The Constitutional Credentials of Administration","authors":"Katharine Jackson","doi":"10.2139/ssrn.3813904","DOIUrl":"https://doi.org/10.2139/ssrn.3813904","url":null,"abstract":"At a time when citizens must rely on administration to tackle the urgent threats of global warming, a pandemic, and destabilizing inequality, critics both left and right would tear it down. <br><br>Libertarian opponents denounce agency discretion as obnoxious to the rule of law and its norms of generality and neutrality. They argue that regulatory agencies violate the separation of powers and defy the principle of limited government. But their favored solution, a strict application of the non-delegation doctrine, would create a new, undemocratic separation of powers problem: ascribing to unelected judges responsibility for economic and social regulation. <br><br>On the other hand, conservatives with a more authoritarian inflection would rescue agencies from their constitutional exile by placing them under more direct executive control. Bootstrapping agencies to the president’s electoral credentials, their solution carries Schmittian implications.<br><br>Administration fares little better in the hands of the left. They blame it for a variety of ailments: the reification of social differences and the juridification of human nature; regulatory capture; depoliticization of the economy and the subsidization of financial capitalism; and, ultimately, populist politics. <br><br>This paper will put administration on firm constitutional footing. It argues that critiques of the administrative state rely upon mistaken notions of popular sovereignty and the rule of law. First, they posit the law as the “will” of an organ-body democratic sovereign that is transcribed (however ham-handedly) by elected officials. Yet, as recent theory shows, there is no exogenous democratic will to transcribe. Second, they posit that this law can be uncontroversially applied by neutral judges and administrators. For them, the rule of law protects political equality through the unwavering application of abstract, general legislation. Critical theorists show, however, that the application of abstract law to concrete cases may only exacerbate inequality. Legal realists demonstrate that law is underdeterminate; unelected judges and administrators will inevitably find themselves smuggling outside values into their decision-making. <br><br>By treating administration as part of representative government, however, agencies can gain constitutional credentials. If democracy aspires not to universal consent and a formalist understanding of law, but instead to democratic autonomy (Urbinati &amp; Warren, 2008), then administration can be legitimate. Indeed, agencies already serve as fora for representative politics as citizens organize around rulemaking. They also act as representatives themselves. By providing points of entry into policymaking, independent agencies help constitutional democracies ensure that power can respond effectively to popular demands while always remaining an empty place. <br>","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"25 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2021-07-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121769789","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Private Enforcement","authors":"Stephen B. Burbank, Sean Farhang, H. Kritzer","doi":"10.4337/9781781000564.00016","DOIUrl":"https://doi.org/10.4337/9781781000564.00016","url":null,"abstract":"Our aim in this Article is to advance understanding of private enforcement of statutory and administrative law in the United States and to raise questions that will be useful to those who are concerned with regulatory design in other countries. To that end, we briefly discuss aspects of American culture, history, and political institutions that reasonably can be thought to have contributed to the growth and subsequent development of private enforcement. We also set forth key elements of the general legal landscape in which decisions about private enforcement are made, aspects of which should be central to the choice of an enforcement strategy and, in the case of private enforcement, are critical to the efficacy of a private enforcement regime. We then turn to the business of institutional architecture, describing the considerations — both in favor of and against private enforcement — that should affect the choice of an enforcement strategy. We lay out choices to be made about elements of a private enforcement regime, attending to the general legal landscape in which the regime would operate, particularly court access, as well as how incentives for enforcement interact with the market for legal services, which has important implications for private enforcement activity. We situate these legislative choices about private enforcement in the context of institutions that shape them. Finally, we seek to demonstrate how general considerations play out by examining private enforcement in two policy areas: legislation proscribing discrimination in employment, and laws protecting consumers from unfair and deceptive practices.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"54 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2021-06-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122479626","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Valuing Density: An Evaluation of the Extent to which American, Australian, and Canadian Cities Account for the Climate Benefits of Density through Environmental Review","authors":"A. Minelli, Sara Savarani, Danielle H. Spiegel-Feld, K. Wyman","doi":"10.2139/ssrn.3873479","DOIUrl":"https://doi.org/10.2139/ssrn.3873479","url":null,"abstract":"This study looks at the extent to which major cities in the United States, Australia, and Canada assess the climate impacts of densification through the environmental review process. Research indicates that greater urban density is associated with lower household greenhouse gas (GHG) emissions in high GDP countries. Yet there is reason to believe that cities may be taking a parochial approach to evaluating the climate impacts of rezonings in their environmental reviews that fails to consider the environmental costs of maintaining low density. In this study, we survey the legal and policy frameworks governing the environmental review in American, Australian, and Canadian cities to determine the extent to which they consider and analyze the GHG benefits of land use changes that increase urban density. We also analyze environmental review documents for proposals to increase residential density in cities to determine the extent to which policy makers have incorporated empirical knowledge regarding the relationship between density and GHGs emissions into their environmental reviews of proposed land use changes. We find that very few cities of those we surveyed use a formal environmental review process for analyzing the GHG impacts of land use changes. In addition, the small number of cities in our survey that analyze the GHG implications of land use changes do not appear to comprehensively consider the broader GHG benefits of densification. In fact, cities that assess the GHG impacts of zoning changes appear more likely to consider densification as causing climate harms rather than climate benefits.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"48 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2021-06-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115436789","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Retiring ‘No Look’ Judicial Review in Agency Cases Involving Science","authors":"E. Elliott","doi":"10.2139/ssrn.3766372","DOIUrl":"https://doi.org/10.2139/ssrn.3766372","url":null,"abstract":"The Supreme Court's casual statement in Baltimore Gas and Electric Co. v. NRDC, 462 U.S. 87 (1983) that reviewing courts should be \"most deferential\" to agency predictions \"on the frontiers of science\" has spawned a liner of cases in the lower courts that rubber stamp agency decisions with what amounts to \"no look\" judicial review. This development is criticized on a number of legal and policy grounds. It is suggested that the increasing reliance on algorithms and other forms artificial intelligence makes it particularly important for the Supreme Court to clarify the proper standard of review in agency cases involving science.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"48 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2021-01-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"126573608","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Section 13(b) of the FTC Act at the Supreme Court: The Middle Ground","authors":"H. Beales, B. Mundel, T. Muris","doi":"10.2139/ssrn.3750787","DOIUrl":"https://doi.org/10.2139/ssrn.3750787","url":null,"abstract":"In 1981, while in the FTC's Bureau of Consumer Protection, two of the authors were instrumental in initiating the FTC's fraud program, relying on Section 13(b)'s authority to obtain a permanent injunction to seek equitable relief, including asset freezes and consumer redress. The fraud program has become a mainstay of the Commission's consumer protection program, and the agency now coordinates local, state, national, and international agencies to fight the many faces of fraud. When the Obama Administration claimed that 13(b) could be used beyond fraud cases, an authority that all previous Commissions believed they lacked, we warned that this overreach could threaten the heretofore uncontroversial fraud program. A case currently before the Supreme Court challenges the FTC' s ability to obtain monetary relief under 13(b) in any circumstances, which we call the Never position. The Commission takes the opposite extreme, arguing that monetary relief is available in any case it chooses, which we term the Always position. We argue that both positions are wrong. Among other problems, the Never position would terminate the fraud program, ending 40 years of successful use of an important, practical solution to one of the major problems that consumers face, with no clear evidence that the Commission has exceeded its authority. The Always position ignores both the text of Section 13(b), which limits permanent injunctions to \"proper cases,\" and the statutory structure, which itself limits the FTC's ability to obtain monetary relief. Congress originally considered Section 13(b) as part of a comprehensive set of changes to enhance the Commission's authority, which also included what became Section 19 two years later. That section limits the FTC's ability to obtain monetary relief to conduct that a reasonable person would know was dishonest or fraudulent. <br><br>We argue instead for a middle ground. Because Section 19 requires separate administrative proceedings before the Commission can seek monetary relief, the money would be gone without the ability to obtain extraordinary relief, especially an ex parte asset freeze. It therefore cannot be used to attack fraud successfully. The middle ground would allow 13(b) to be used against fraudsters. Another advantage of the middle ground is that it respects the original vision of the FTC that there are some law violations for which monetary relief is inappropriate, a view codified in both 1914 and again in Section 19 in 1975. For example, complex issues of advertising substantiation, as well as issues about the adequacy of disclosures to consumers, about which reasonable experts often disagree, should normally be resolved through the administrative process. To subject all violations of the FTC Act routinely to potential monetary relief risks chilling the provision of truthful and useful information, as well as other conduct beneficial to consumers.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"9 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2020-12-17","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130769032","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Interagency Coordination on Labor Regulation","authors":"Hiba Hafiz","doi":"10.2139/ssrn.3741536","DOIUrl":"https://doi.org/10.2139/ssrn.3741536","url":null,"abstract":"After 9/11, Congress, federal agencies, and scholars exposed the devastating results of the national security agencies’ failure to coordinate. The financial crisis has been linked to similar coordination failures in the context of interagency banking regulation, with jurisdictional gaps and blind spots resulting in failure to prevent a global recession. But despite Gilded Age-levels of inequality, little attention has focused on the failures of interagency coordination to secure Americans’ access to economic opportunity through work—whether through securing higher wages and higher union density, coordinating government enforcement to achieve redistributive goals and combat consolidation of employer buyer power, or overcoming systemic abuses in employers’ wage theft, discrimination, and worker mistreatment. The crippling spread of the coronavirus (COVID-19) pandemic demands that now, more than ever, agencies coordinate in their regulation of labor markets to accomplish micro- and macroeconomic policy outcomes. \u0000 \u0000This Essay is a component of a larger project that seeks to document federal agencies’ selective coordination along six core policy vectors that impact work- or income-based avenues towards equality—macroeconomic, microeconomic, institution-building, industry-specific, anti-subordination, and democratic/expressive policy. It presents the results of a novel data set collecting and systematizing existing Memoranda of Understanding (MOUs) authorized by the core agencies involved in labor market regulation: the Department of Labor (DOL), its sub-agencies, the National Labor Relations Board (NLRB), the Equal Employment Opportunity Commission (EEOC), the Department of Justice-Antitrust Division, and the Federal Trade Commission. By reviewing and hand-coding the 113 discoverable MOUs from the 1950s to the present, the Essay highlights which labor agencies coordinate most and least, what MOUs historically facilitate as a substantive and administrative matter, best practices of interagency coordination through MOUs, the network of existing institutional relationships for mobilization along the six policy vectors previously identified, and the broad scope and areas of labor market regulation on which coordination has not yet occurred. It concludes by arguing that the federal government lacks a coherent, aligned vision on labor market regulation and economic mobility through work, and proposes next steps for integrating agency coordination.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"5 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2020-12-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121723314","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Deference is Dead (Long Live Chevron)","authors":"N. Richardson","doi":"10.31235/osf.io/bdxrf","DOIUrl":"https://doi.org/10.31235/osf.io/bdxrf","url":null,"abstract":"Chevron v. NRDC has stood for more than 35 years as the central case on judicial review of administrative agencies’ interpretations of statutes. Its contours have long been debated, but more recently it has come under increasing scrutiny, with some—including two sitting Supreme Court justices—calling for the case to be overturned. Others praise Chevron, calling deference necessary or even inevitable. All seem to agree the doctrine is powerful and important. This standard account is wrong, however. Chevron is not the influential doctrine it once was and has not been for a long time. It has been eroded from the outside as a series of exclusions have narrowed its scope, and has been hollowed out from the inside as Justices have become ever more willing to find clear meaning in statutes, thereby denying deference to agencies. In recent years, agencies have won only a handful of statutory interpretation cases, and none in more than four years. Only once since 2015 has deference been outcome-determinative. At the Supreme Court level (though not, for now, in the circuit courts), deference is dead. The once-crystal Chevron has turned to mud. As a result, however, it is less likely to be formally overturned than widely believed—critics of deference and of administrative power on the Court would gain little. Instead, Chevron’s future is likely to be one of further decline, at least in the short term. This has implications for major policy areas like climate change, health care, and immigration where regulatory policy is necessary and challenges are likely to reach the Court.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"61 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2020-08-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"127091230","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Comments on “Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process”","authors":"M. Luttrell","doi":"10.2139/ssrn.3923773","DOIUrl":"https://doi.org/10.2139/ssrn.3923773","url":null,"abstract":"Were this anti-regulatory NPRM—or any logical outgrowth of it—to be finalized, it would result in repeated violations of the Clean Air Act and the Administrative Procedures Act. The problematic methodologies being codified in this NPRM would often generate nonsensical, arbitrary results, and would promote multiple biases that undermine the goals of the Act.It is unfortunate that the Trump administration is rushing out a slew of standards during a national pandemic. The stakeholders that normally would organize and engage to protest these actions through participation in notice-and-comment rulemaking and strategic litigation are spread thin, and many do not have sufficient time to participate meaningfully. Women, in particular, have been negatively impacted by the lack of normal childcare supports during this time, and COVID-19 infections have disproportionately affected people of color. Many organizations have requested an extension of time to respond to this rulemaking;unfortunately, EPA provided only a week’s extension, leaving a comment period of less than 60 days. Under the circumstances, this refusal to allow adequate time for the public to review and critique the proposed econometric and scientific methodologies—which are to be applied to a diversecollection of very complicated provisions—was unreasonable, arbitrary and capricious.And the stakes here are incredibly high. Consider PM 2.5 pollution, which causes tens of thousands of excess deaths every year. Virtually any CAA regulation that reduces any type of air pollution will—intentionally or not—reduce the number of fatalities that result from exposure to PM 2.5. The issue of how we value this human impact of pollution regulation and deregulation is far too important to be given such rushed treatment. Rather than carefully consider the best way to conduct an econometric analysis—if one is even appropriate—or the best way to use risk assessment data, the Trump EPA seems instead to be intent on codifying a set of biased methodologies while it still has control of the agency. If successful, the outcome will be dramatic—a thumb on the scale in favor of weaker standards, with millions of undercounted and systematically undervalued human lives hanging in the balance.This rulemaking is an effort to use a general authorization to issue CAA regulations to enable the EPA to override the more specific provisions of the CAA that limit or prohibit certain considerations. This is not a legitimate use of section 301(a)(1) of the Clean Air Act. Many of the regulatory analyses being “standardized” with this rulemaking did not begin to gain traction in the environmental context until after the CAA had been enacted. It is thus unsurprising that they often do not square well with the objectives, substance, and procedure actually laid out in the CAA. To overlay the methodologies advanced in this NPRM over the entire mass of diverse CAA provisions would re-write those provisions to favor factors that are curr","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"50 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2020-08-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132948997","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Best Practices","authors":"David T. Zaring","doi":"10.2307/j.ctvp2n3x4.22","DOIUrl":"https://doi.org/10.2307/j.ctvp2n3x4.22","url":null,"abstract":"In traditional administrative law, agencies pass rules and courts review them. But what if agencies stopped acting by rule and started leading by example? With best practices rulemaking - a theoretically voluntary way of coordinating administrative action both within and across agencies - leading by example is what agencies are increasingly doing. Although best practice rulemaking has been ignored by the legal literature, regulation through best practices has increased sevenfold in the past ten years in the federal government alone, touching every aspect of administrative law. This paper describes and evaluates best practices rulemaking, tracking its origins in business management, its adoption by the public sector, and analyzing how it works in that sector, through a series of case studies. Although best practices purport to be best, there is nothing particularly best about them. The rulemaking technique is a way of obtaining common practices, not ideal ones. Accordingly, best practices rulemaking is therefore particularly useful when we want agencies to coordinate, but don't care much about the standard of coordination that they adopt. The paper concludes with a consideration of the future of best practices. As best practices rulemaking, along with other forms of horizontal, informal agency action, continues to grow, and grow apart from judicial supervision, Congress may ultimately wish to point the way to appropriate publicity and forms of consultation through an Informal Administrative Procedure Act.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"38 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2020-02-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131348665","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

{"title":"Codifying the Cost-Benefit State","authors":"Brian F. Mannix, B. C. Dooling","doi":"10.2139/ssrn.3449229","DOIUrl":"https://doi.org/10.2139/ssrn.3449229","url":null,"abstract":"Almost fifty years of presidential direction and agency practice, combined with ten years of increasing encouragement from the Supreme Court, suggest that the cost-benefit state has not only arrived, but is well past its introductory season. Benefit-cost balancing is now a dominant paradigm in administrative law for evaluating federal agencies’ exercise of delegated regulatory discretion. In response to increased scrutiny upon judicial review, agencies have taken steps to firm up their benefit-cost analyses. Still, despite multiple Executive Orders and supplementary guidance, neither executive nor legislative action has produced a clear set of justiciable standards against which courts can evaluate agency analyses for adequacy. \u0000 \u0000Some agencies have recently initiated rulemakings to codify their own analytical procedures under particular laws. While this statute-by-statute interpretive approach may be useful, it is unlikely to provide consistency across government or broadly-applicable tools for courts to use in varying regulatory domains. The time might be right to develop judicially-enforceable, government-wide standards for the use of benefit-cost analysis in rulemaking. \u0000 \u0000Others have examined theories of judicial authority to require and to review agency benefit-cost balancing in rulemaking. In this article we focus instead on the executive’s authority to write a cross-government “rule-on-rules” to govern regulatory analysis, including benefit-cost analysis and the courts’ authority to enforce such a rule. While such a rule would probably lack direct statutory authorization under current law, we offer the example of the Council on Environmental Quality (CEQ) regulations, which govern agencies’ use of Environmental Impact Statements, to illustrate how the absence of express statutory authority is not necessarily fatal to the project, particularly when it promises to produce tools that judges will find useful in carrying out their Article III responsibilities. \u0000 \u0000In Section I, we review the rise of the cost-benefit state as a result of its development in the executive branch and its treatment by the courts. In Section II, we examine theories of judicial authority to require benefit-cost analysis (BCA). Section III describes a nascent efforts by one agency to codify its own use of BCA, presents the question of whether a broader, cross-cutting “rule-on-rules” that lacks clear statutory authority would be judicially enforceable, and describes the CEQ analog as a potential precedent. In Section IV, we review the constitutional authorities that might support a cross-cutting BCA rule, and present two theories to support judicial enforcement of such a rule.","PeriodicalId":233762,"journal":{"name":"U.S. Administrative Law eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-08-29","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129789274","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}