Michigan Journal of Environmental & Administrative Law最新文献

{"title":"The Locked Gates to Tension City: The Commission on Presidential Debates, the FEC, and the Two-Party System","authors":"Tommy La Voy","doi":"10.36640/mjeal.8.2.locked","DOIUrl":"https://doi.org/10.36640/mjeal.8.2.locked","url":null,"abstract":"Since John F. Kennedy and Richard Nixon walked into a Chicago television studio for the first general election presidential debate in 1960, candidate debates have been a fundamental aspect of presidential campaigns and have had broader effects on society at large. The Commission on Presidential Debates (“CPD”) has been in charge of organizing the general election debates since it was created in 1987 by the Democratic and Republican parties. In its tenure, the CPD has restricted its massive platform almost every election to the Republican and Democratic candidates through the use of criteria that seemingly follow the law’s requirement of being pre-established and objective. But the CPD’s criteria is neither truly objective nor nonpartisan; it is effectively bipartisan. By ignoring and dismissing complaints about the CPD’s exclusion of third-party and independent presidential candidates, the Federal Election Commission (“FEC”), which is itself based on a bipartisan structure, reinforces the power of the partisan duopoly in American presidential elections.\u0000\u0000There is a strong argument that the FEC should hold the CPD to the legal requirement of non-partisan access to is debates. The spirit of the law points in this direction. But in this, the law is wrong. Rather than commit to the pretense of entirely open access in the elections, the FEC should revise its regulations to reflect the reality: American politics is run through a two-party system.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"48 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"134501639","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":"The Cost of Nothing Trumps the Value of Everything: The Failure of Regulatory Economics to Keep Pace with Improvements in Quantitative Risk Analysis","authors":"A. Finkel","doi":"10.36640/10.36640/mjeal.4.1.cost","DOIUrl":"https://doi.org/10.36640/10.36640/mjeal.4.1.cost","url":null,"abstract":"The entire U.S. federal regulatory apparatus, especially that part devoted to reducing (or deciding not to reduce) risks to the environment, health, and safety (EHS), relies increasingly on judgments of whether each regulation would yield benefits in excess of its costs. These judgments depend in turn upon empirical analysis of the potential increases in longevity, quality of life, and environmental quality that the regulation can confer, and also of the economic resources needed to “purchase” those benefits—analyses whose quality can range from extremely fine to disappointingly poor. The quality of a risk analysis (from which the benefits of control are derived) or of an economic analysis depends on attributes they share in common, such as the complexity and rigor of the data collection and mathematical modeling, the transparency by which the assumptions used are disclosed, and the humility of the conclusions drawn (particularly the care taken to acknowledge uncertainty in the estimate). This Article is part of a series of investigations by a multidisciplinary team of scholars, examining whether regulatory cost analysis may be systematically less rigorous, transparent, and humble as compared to the corresponding analyses of risk upon which regulations are jointly based. In this particular study, I contrast the attention paid to depicting uncertainty on the “cost side” versus the “risk side” of cost-benefit analysis, and show that regulatory economics has steadily remained about ten to fifteen years behind risk analysis with respect to this important attribute of analytic quality. Various sections of the Article explain why overconfident pronouncements about cost or risk can thwart sensible decisionmaking, demonstrate how an unbalanced approach to analyzing risks versus cost is untenable, and trace the history of attempts to improve the estimation of regulatory cost uncertainty both inside and outside the major federal EHS regulatory agencies. The core of this Article is a combination of a statistical analysis and a set of case studies, showing how much improvement remains to be made on the “cost side” of regulatory uncertainty analysis, and providing various sets of reasons why this particular deficiency arose and persists. If decisionmakers and the public are not informed that the true magnitudes of regulatory cost may be much higher or (more likely) much lower than the overconfident estimates provided with current regulatory analyses, they cannot express their desires for more or less regulatory stringency in light of the resulting uncertainty in net benefit.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"45 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"133421311","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":"Examining the Administrative Unworkability of Final Agency Action Doctrine as Applied to the Native American Graves Protection and Repatriation Act","authors":"A. Gerken","doi":"10.36640/mjeal.8.2.examining","DOIUrl":"https://doi.org/10.36640/mjeal.8.2.examining","url":null,"abstract":"The application of the Administrative Procedure Act (“APA”) to the Native American Graves Protection and Repatriation Act (“NAGPRA”) creates unique practical and doctrinal results. When considering the application of the current law concerning judicial review of final agency action under the APA to NAGPRA, it is evident that the law is simultaneously arbitrary and unclear. In the Ninth Circuit’s holding in Navajo Nation v. U.S. Department of the Interior, the Court applied final agency action doctrine in a manner that was legally correct but administratively unworkable. The Court’s opinion contravenes both the reasoning behind the APA final agency action doctrine and the purposes of both NAGPRA and the APA. The holding further allows for a finding of a final agency action despite the fact that the application of NAGPRA is the beginning of a process that will result in its own final agency action – the determination of which tribe owns the remains and artifacts. Such a result ignores sensitive issues of cultural patrimony (the identification of cultural heritage as to specific sets of remains or sacred object) associated with the NAGPRA inventory process, which requires that Native American remains and sacred objects found on federal land be inventoried by the federal agency that manages that land.\u0000\u0000The unworkability and legal incoherence of the Ninth Circuit’s decision in Navajo Nation stems from an underlying final agency action doctrine developed to protect property rights that fails to properly consider the unique context of cultural heritage rights implicated by statutes such as NAGPRA. These rights involve the recognition that human remains and ceremonial objects belong to a specific culture. The application of final agency action doctrine invites legal claims before anyone can adequately determine what culture the remains and artifacts belong to. Because of this, the courts or Congress must develop an alternative set of rules to be used when dealing with a final agency action that implicates the cultural heritage rights associated with ancient remains and sacred objects. Such an action would account for the unique nature of the rights in question. Doing so would make administrative agencies better equipped to provide inclusive protections to minority cultures in the performance of their duties.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"26 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114856926","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":"The Sun Doesn't Always Shine in Ohio: Reevaluating Renewable Portfolio Standards in Light of Changed Conditions","authors":"J. Smith","doi":"10.36640/mjeal.5.1.sun","DOIUrl":"https://doi.org/10.36640/mjeal.5.1.sun","url":null,"abstract":"In 2014, with the signing of Senate Bill 310 (S.B. 310), Ohio became the first state to put a temporary “freeze” on its renewable portfolio standard (RPS) and energy efficiency mandates. The law has generated nationwide attention and been criticized as a step back in the state’s clean energy policy. This Note examines the central justifications for the passage of S.B. 310, challenging conventional wisdom that the law does not serve the interests of Ohio citizens. After the passage of Ohio’s RPS in 2008, the economic and energy landscape within the state changed dramatically, due in large part to technological advances allowing for the development of the state’s large natural gas deposits. In order to fully assess these changed conditions, as well as the economic impact the energy mandates were having on ratepayers, Ohio lawmakers passed S.B. 310. While renewable resource advocates argue that increased renewable energy benefits the state of Ohio, this Note argues that S.B. 310 was an example of prudent lawmaking and should serve as a model for other states that have undergone changes in their energy landscape and economic situation since implementing their renewable portfolio standards.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"5 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"128735054","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":"Environmental Law at the Crossroads: Looking Back 25, Looking Forward 25","authors":"R. Lazarus","doi":"10.36640/mjeal.2.2.environmental","DOIUrl":"https://doi.org/10.36640/mjeal.2.2.environmental","url":null,"abstract":"Twenty-five years used to seem like an exceedingly long time. It certainly did when I was graduating from law school and not yet twentyfive. My perspective on time, however, has (naturally) since evolved, much as environmental law itself and the controversies surrounding it have, too, evolved. The contrast between environmental law twenty-five years ago and environmental law today is remarkable and makes clear that environmental law and lawmaking were changing in fundamental ways a generation ago, but those changes are revealed only now with the aid of hindsight. To be sure, the statutory texts of domestic environmental law are strikingly the same. And yet, it is that static quality that ironically underscores how much has changed. A generation ago, environmental law scholars would routinely comment on how the only constant in environmental law was change: its dynamic nature. Congress was regularly passing significant statutory amendments in what was largely a constructive iterative lawmaking process, involving federal and state legislatures, agencies, and courts. Some might have worried that the change was too great—making it too difficult for the regulated community to adjust and invest. Whether any such concern then was justified, the concern now is quite different: too little change rather than too much. And the static nature of environmental lawmaking here in the United States stands in sharp contrast to the dynamic nature of environmental lawmaking globally. The United States, once a lauded pioneer, now very much risks being left behind. This essay is written in celebration of the 25th Annual Meeting of the National Association of Environmental Law Societies at the University of Michigan Law School and in recognition of Michigan Law’s hosting of the Association’s inaugural meeting in 1988. The essay focuses on three topics in reflecting on the changes in environmental law and environmental lawmaking since the Association’s first meeting. The first is Congress and the politics of environmental law. The second topic concerns the courts and the changing relationship of constitutional law to environmental law. And, finally, the essay considers the contrasting nature of the challenges that environmental lawyers and environmental law face today as compared to twenty-five years ago.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129408778","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":"Utilizing Michigan Brownfield Policies to Incentivize Community-Based Urban Agriculture in Detroit","authors":"Nicholas Leonard","doi":"10.36640/mjeal.3.2.utilizing","DOIUrl":"https://doi.org/10.36640/mjeal.3.2.utilizing","url":null,"abstract":"As residents have increasingly moved from urban centers to suburbs, several cities have not been able to create effective solutions to the problems that such population loss has presented. Abandoned properties have proven to be the primary problem, and nowhere is that problem more pronounced than in Detroit. Urban agriculture has been widely embraced on a grassroots level as a potential solution to the pervasive problems that abandoned properties present and that cities have been unable to solve. While urban agriculture networks have largely arisen outside of municipal control, several cities are beginning to recognize urban agriculture as a potential tool for urban revitalization. However, there is a basic problem: many cities in which urban farming has flourished are riddled with brownfields. It is possible for cities and the urban agriculture community to turn this obstacle into an opportunity if they work together. By utilizing the Michigan Brownfield Redevelopment Financing Act to incentivize urban farming, Detroit could not only promote urban agriculture as a cost-effective tool for the revitalization of some of Detroit’s most distressed neighborhoods, but could also ensure that the farmers and the food they produce are safe from toxic contamination. By encouraging urban farms, Detroit will for the first time have a truly viable strategy to reversing blight and revitalizing some of the city’s most depressed areas.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"55 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122234043","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":"Look to Windward: The Michigan Environmental Protection Act and the Case for Atmospheric Trust Litigation in the Mitten State","authors":"Jonathan Coumes","doi":"10.36640/mjeal.10.1.look","DOIUrl":"https://doi.org/10.36640/mjeal.10.1.look","url":null,"abstract":"Failure to address climate change or even slow the growth of carbon emissions has led to innovation in the methods activists are using to push decisionmakers away from disaster. In the United States, climate activists frustrated by decades of legislative and executive inaction have turned to the courts to force the hand of the state. In their most recent iteration, climate cases have focused on the public trust doctrine, the notion that governments hold their jurisdictions’ natural resources in trust for the public. Plaintiffs have argued that the atmosphere is part of the public trust and that governments have a duty to protect it.\u0000\u0000These types of lawsuits, known as Atmospheric Trust Litigation, have foundered on the shoals of courts wary of exceeding their powers, whether granted by Article III or state constitutions. The trouble in many cases, including Juliana v. United States, has been standing. Courts balk at declaring that any one actor has the power to affect climate change. Since they usually think one actor can’t fix the climate, redressability is out the window. Even if courts get past redressability, they believe the scale of any potential relief is just beyond the ability of a court to order. The number of lawsuits that have been filed suggests that that reasonable minds can differ, but most judges have found plaintiffs do not have standing before clearing the cases off their dockets.\u0000\u0000This Note contends that at least one state remains fertile ground for an atmospheric trust lawsuit. Michigan’s 1963 Constitution implies that the atmosphere is within the public trust, and the Michigan Environmental Protection Act, passed to carry out the state’s constitutional duties towards the natural world, does away with most, if not all, of the standing issues that have stymied climate cases across the nation. Motions, briefs, and equitable relief are not the only way to avoid the onset of what could be the greatest calamity in the history of humanity, but in Michigan, at least, Atmospheric Trust Litigation may well be what breaks and rolls back the carbon tide.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"21 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"129994049","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":"Superfund Chaos Theory: What Happens When the Lower Federal Courts Don't Follow the Supreme Court","authors":"S. Ferrey","doi":"10.36640/mjeal.6.1.superfund","DOIUrl":"https://doi.org/10.36640/mjeal.6.1.superfund","url":null,"abstract":"There is legal chaos in the national Superfund. The Supreme Court reversed decisions of eleven federal circuit courts in United States v. Atlantic Research Corp. There is no instance in modern Supreme Court history where the Court reversed every federal circuit court in the country, as it did in Atlantic Research. The Supreme Court’s reversal was through a unanimous decision. This was extraordinary: It not only reversed the entire legal interpretation of one of America’s most critical statutes, but also re-allocated billions of dollars among private parties.\u0000\u0000The Supreme Court, when it rendered its decision, seemed to be rectifying a bottleneck in Superfund remediation of hazardous waste. However, in the decade since this Supreme Court decision, several federal trial and circuit courts have circumvented the Supreme Court command. This article illustrates how the lower federal courts have done this without violating Article III of the Constitution, by re-defining a one-word term.\u0000\u0000The practical impact has been chaos in hazardous substance remediation across the U.S., affecting an estimated 600,000 contaminated waste sites. There are huge dollar impacts: addressing the 350,000 remaining contaminated sites in the U.S. would cost up to one-quarter trillion dollars, or an expenditure of $6-8 billion annually.\u0000\u0000This Article analyzes how the lower federal courts have circumvented the Supreme Court decisions, with particular focus on decisions and legal prestidigitation in the most recent four years. This lower court inversion of the law is without much basis in law, and resurrects exactly what the Supreme Court thought it had overruled unanimously. What transpired in enforcement in the lower courts is not what the Supreme Court’s opinion contemplated. This Article examines the method by which the lower federal courts have created an ongoing legal mechanism to circumvent the most important Supreme Court holding in a critical area of the economy.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"47 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121586895","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":"Judicial Limitation of the EPA's Oversight Authority in Clean Water Act Permitting of Mountaintop Mining Valley Fills","authors":"C. D. Eaton","doi":"10.36640/mjeal.2.1.judicial","DOIUrl":"https://doi.org/10.36640/mjeal.2.1.judicial","url":null,"abstract":"Mountaintop removal mining operations in the Appalachian region have expanded significantly in recent decades. The practice decimates the mountain ecosystems by leveling forests, filling headwater streams, and producing significant runoff of heavy metals, sediment, and other pollutants that impair the aquatic environment of entire watersheds. Yet environmental permitting of the practice is relatively limited. A recent trend in litigation aimed at halting mining operations has involved challenging permits that authorize the discharge of mining overburden into headwater streams pursuant to the Clean Water Act (CWA). The Army Corps of Engineers has assumed jurisdiction over such discharges under section 404 of the CWA, asserting that overburden is “fill material.” Initial litigation on the matter challenged the Corps’ assumption of jurisdiction, asserting instead that overburden is a “pollutant,” the discharge of which is regulated by the Environmental Protection Agency (EPA) under section 402 of the CWA. After the courts upheld the Corps’ interpretation that overburden is fill, the issue became the degree to which section 404 allows or requires the EPA to exercise environmental oversight of the Corps’ permitting process. The EPA has recently attempted to increase its oversight role by establishing procedures to review permit applications before the Corps issues the permits and by retroactively “vetoing” existing permits that it has found result in irreparable environmental damage. Those actions have been subjected to challenges by the mining industry, which have produced court rulings constraining the EPA’s oversight authority. In this Note, I argue that Congress did not intend for mining overburden to fall within the purview of the Corps’ section 404 jurisdiction, and that the cases affirming the Corps’ assumption of such jurisdiction were wrongly decided. Assuming, however, that those cases will not be overturned, I argue that the EPA must be afforded the ability to exercise the oversight authority inherent in section 404 to ensure that the Corps’ permits for mountaintop removal mining valley fills do not result in undue environmental damage. I assert that the recent decisions in National Mining Association v. Jackson and Mingo Logan Coal Co. v. EPA improperly read limits into the EPA’s oversight authority, and that the courts of appeals should overturn those decisions. Absent the EPA’s second layer of environmental review of section 404 permitting, the fragile Appalachian landscape may be permanently destroyed as a consequence of mountaintop removal mining.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"4 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115619065","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":"Joseph L. Sax: The Realm of the Legal Scholar","authors":"Nina A. Mendelson","doi":"10.36640/mjeal.4.1.joseph.l.sax","DOIUrl":"https://doi.org/10.36640/mjeal.4.1.joseph.l.sax","url":null,"abstract":"It is one of my great regrets that I never really got to know Professor Joseph Sax personally. I joined the faculty at the University of Michigan Law School well over a decade after Sax departed our halls for the University of California at Berkeley’s Boalt Hall School of Law. I met him on one occasion several years ago, when he gave an engaging workshop at Michigan on governance issues around Colorado River water allocation, complete with a detailed map of the watershed. I am exceptionally fortunate, however, to occupy a chair named for him. This is not only because of his major contributions to the creation of environmental law, but because—even viewed at a distance—his career, accomplishments, and legacy are a model of what it can mean to realize one’s potential as a legal scholar. The numerous achievements in environmental law that made Sax a giant in his field have been widely recited elsewhere: his scholarship on the public trust doctrine and on citizen suits was path-breaking, and his scholarship on takings law was frequently cited in the Supreme Court. He was awarded the Blue Planet Prize, sometimes called the Nobel Prize for the environmental sciences, was named a Distinguished University Professor here at Michigan, and wrote an influential environmental protection statute for the State of Michigan. His contributions to law and the environment are legion; later in life he expanded his focus to cultural treasures as well as environmental ones.","PeriodicalId":401480,"journal":{"name":"Michigan Journal of Environmental & Administrative Law","volume":"48 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"117193700","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}