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How Scalia's Death Could Be a Pivotal Factor on Environmental and Climate Issues

How Scalia's Death Could Be a Pivotal Factor on Environmental and Climate Issues

Justice Antonin Scalia left an indelible mark on American law. His prodigious intellect, distinctive style and sharp wit will be sorely missed by his family, friends and colleagues.

His passing also creates a once-in-a-lifetime opportunity to shift the balance of power on the Supreme Court toward greater protection for the environment and greater access to the courts by those most affected by pollution and resource degradation.

Justice Antonin Scalia consistently voted in favor of property rights over protection of endangered species, wetlands and other natural resources. He dissented in the court’s landmark ruling in Massachusetts vs. EPA that the Clean Air Act authorizes the agency to regulate the carbon pollution causing global warming and ocean acidification.

A look at Scalia’s legacy reveals why his absence in the coming months could be a pivotal factor on environmental issues.

With few exceptions, such as his opinion in Whitman vs. American Trucking upholding the Environmental Protection Agency’s (EPA) authority to set health-based air quality standards without regard to cost and his opinion in City of Chicago v. Environmental Defense Fund rejecting industry arguments that coal ash isn’t a hazardous waste, Justice Scalia’s environmental legacy is decidedly negative.

Interpreting "Standing" and "Harm"

He consistently voted in favor of property rights over protection of endangered species, wetlands and other natural resources. He dissented in the court’s landmark ruling in Massachusetts vs. EPA that the Clean Air Act authorizes the agency to regulate the carbon pollution causing global warming and ocean acidification.

He wrote the majority opinion in a case limiting EPA’s authority to require pre-construction permits for new power plants that only emit greenhouse gases. He wrote the opinion overturning the mercury rule on a technicality—namely, that EPA should have considered cost as a threshold matter before even embarking on the rule-making instead of at the stage when the regulations were actually being applied to specific facilities.

He argued that the Clean Water Act should be narrowly construed to apply only to “relatively permanent bodies of water” rather than, as the lower courts had consistently ruled for more than 30 years, to the entire tributary systems of the nation’s major waterways.

And he is the author of several decisions severely limiting the ability of environmental plaintiffs to challenge unlawful government actions. This includes Lujan vs. Defenders of Wildlife, which the late Justice Blackmun in his dissent characterized as a “slash and burn expedition through the law of environmental standing.”

To establish standing, a plaintiff must show how it is injured by the action being challenged. Scalia applied a more liberal test of injury for industry plaintiffs than for environmental plaintiffs. Standing was presumed whenever industry alleged that a government action might cause undue economic harm but not when an environmental organization alleged that the same action would cause undue environmental harm.

Whither the Clean Power Plan?

Though President Obama has said he intends to nominate a successor “in due course,” Senate Republicans have vowed to stall the confirmation process in the hope that they will win the White House and have the opportunity to nominate someone more to their liking.

Suddenly the Supreme Court has become a huge prize in the 2016 elections and, given the stakes involved, it is likely that the vacancy will remain well into 2017 and the court will be forced to make a number of difficult decisions with an evenly divided bench.

A split court has important implications in a number of key environmental cases.

Top of the list is the president’s Clean Power Plan (CPP), a rule that requires states to develop plans to lower carbon dioxide emissions from power plants. Only days before Scalia’s death, the court in a 5-4 party line vote blocked the rule’s implementation pending a decision by the DC Circuit, which has scheduled oral argument for June 2. The stay order provides that it will remain in effect until the Supreme Court either denies review (unlikely) or issues a final decision.

Most observers believe the government, arguing that the Clean Power Plan is legal, drew a favorable panel on the DC Circuit court, which includes Judge Sri Srinivasan, who is rumored to be on Obama’s short list of nominees.

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Assuming Srinivasan remains on the panel and further assuming the panel issues a decision this year upholding the CPP (not a forgone conclusion), there is a good chance the vacancy on the Supreme Court will not be filled by the time the case arrives there in 2017. This increases the odds of a 4-4 split, which would result in the DC Circuit decision being upheld and the CPP dodging a bullet.

Clean Waters Act at Court

Another case that may be affected by Scalia’s departure but with far less at stake is Hawkes v. Corps of Engineers.

The question presented is whether landowners can go to court immediately when the regulators make what is called a “jurisdictional determination” under the Clean Water Act finding—for example, that there are wetlands on the property that may require a permit to fill.

There is a clear conflict in the circuits on this question. The Eighth Circuit in Hawkes held that jurisdictional determinations were reviewable in court, whereas the Fifth Circuit in Belle Co v. Corps of Engineers ruled that they are not.

Interestingly enough, the disagreement rests on how to read Justice Scalia’s opinion in Sackett v. EPA. In that case, a compliance order under the Clean Water Act required restoration of an allegedly illegally filled wetland and exposed the recipient to potential penalties of US$75,000 per day. Scalia ruled that the compliance order in this case is “final agency action” for which there is no adequate remedy in a court other than judicial review under the Administrative Procedure Act.

Another case being closely watched is the challenge to EPA’s Clean Water Rule that seeks to “clarify” the jurisdictional scope of the Clean Water Act and whether it covers tributaries that feed into waters protected by the act.

The need for clarification stems in large part from the Supreme Court’s decision in Rapanos v. U.S., where the court split 4-1-4 and Justice Scalia authored a plurality opinion that would significantly reduce the scope of the act.

Justice Kennedy wrote a concurring opinion rejecting Scalia’s approach and establishing the so-called “significance nexus” test—requiring the government to prove that a wetland, alone or in combination with other wetlands in the watershed, plays an important role in protecting the quality of the water downstream and therefore is subject to the Clean Water Act. Because Kennedy’s significant test has been adopted by nine circuit courts as the controlling opinion from Rapanos, EPA used it as the basis for the Clean Water Rule.

The Sixth Circuit has stayed the rule pending its decision on whether it has exclusive authority to decide its legality. If the Sixth Circuit asserts jurisdiction, a final decision could be issued this year and the court would then be faced with another petition for review, knowing that it could result in yet another divided decision.

Finally there is a case involving the cleanup of Chesapeake Bay which is heavily polluted by agricultural runoff and other sources. The Third Circuit upheld EPA’s landmark cleanup plan in a case brought by the American Farm Bureau and joined by over two dozen states.

The issue presented is whether EPA exceeded it authority by developing a complex “pollution budget” and allocating responsibility for reducing the inputs of nitrogen and phosphorous throughout the eight states that comprise the basin. The conference on whether to grant review will be considered at the next conference which is scheduled for Feb. 26. This will be the first test to see whether the post-Scalia court has the appetite to take up a case where there could be a 4-4 split.

With these and other environmental issues on the docket, the absence of Scalia will have a huge impact—as will the question of his eventual successor.


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A North Atlantic right whale feeds off the shores of Duxbury Beach, Massachusetts in 2015. David L. Ryan / The Boston Globe via Getty Images

The population of extremely endangered North Atlantic right whales has fallen even further in the last year, the National Oceanic and Atmospheric Administration (NOAA) said Monday.

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Hundreds of Canadian children took part in a massive protest march against climate change in Toronto, Canada, on May 24, 2019. Creative Touch Imaging Ltd. / NurPhoto / Getty Images

By Heather Houser

Compost. Fly less. Reduce your meat consumption. Say no to plastic. These imperatives are familiar ones in the repertoire of individual actions to reduce a person's environmental impact. Don't have kids, or maybe just one. This climate action appears less frequently in that repertoire, but it's gaining currency as climate catastrophes mount. One study has shown that the reduction of greenhouse gas emissions from having one fewer child in the United States is 20 times higher—yes 2000% greater—than the impact of lifestyle changes like those listed above.

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Do you feel embarrassed due to the foul odor coming from your mouth? Or your oral hygiene isn't as good as before, and you are suffering from gingivitis (inflammation of gums)?

Well, these oral problems are skyrocketing, and even young people are suffering from oral issues that result in a lack of confidence.

It's common to change your toothpaste by seeing the TV commercials that claim to free you from bad breath or sensitive teeth, but these products don't always work.

Fighting oral issues isn't that easy, even if you religiously follow what your primary school teacher has taught, to "Brush two times a day!"

Well, there is a much-hyped supplement in the market that claims to help you fight all of these oral issues: The Steel Bite Pro.

Steel Bite Pro is an oral supplement that claims to cure bad breath and other such oral issues like sensitivity and gum problems.

But does the supplement really work, or is it just like the useless toothpaste that you tried before? Let's find out in this review.

Who Should Use Steel Bite Pro?

The best part about Steel Bite Pro is that anyone can use the supplement to get rid of oral issues. The supplement contains natural ingredients such as turmeric, zinc, alfalfa, jujube seeds, and much more, so there are no chemicals at all.

No matter whether you are 20 or 60, you can use this supplement to overcome oral issues and get the confidence back that you are missing due to bad odor and sensitive teeth.

Steel Bite Pro Review: Overview of the Supplement

Steel Bite Pro is an all-natural supplement that contains a mix of natural supplements to rebuild your gums and teeth.

The supplement contains 29 different foods that help you reduce the gum pain and other dental problems you have been facing for years.

More than 55,000 people have used Steel Bite Pro till now, and the results of the supplement are pretty impressive. Furthermore, the supplement is prepared in an FDA-approved facility in the USA.

It is available in the form of pills that you can consume anytime, so using the supplement is incredibly convenient. There are numerous benefits of using the Steel Bite Pro as it solves a plethora of dental problems.

Click here to Get the Best Deal on Steel Bite Pro from the Official Website.

Pros and Cons: Steel Bite Pro

To understand the supplement better, it is essential to know about its pros and cons.


Convenient to Use

The dietary supplement is convenient to use as it comes in the form of pills. You can take the pill anytime, even when you are in your office or somewhere else. Now there is no need to use multiple kinds of toothpaste and splurge money by visiting a dentist.

All-Natural Ingredients

All the ingredients present inside the supplement are natural, and there are no chemicals that can harm your teeth or gums.


When you compare the cost of 1 bottle with the cost of a special toothpaste with the fee that your dentist charges, Steel Bite Pro will seem much more affordable. The supplement is available in multiple packages, so you will find it affordable to use.

No Side Effects at All

There are no side effects to using Steel Bite Pro, so you can rest assured that you won't face any headaches or other issues while curing the oral issues. The reason why Steel Bite Pro has no side effects is due to its natural ingredients.

Designed by Experts

The supplement is designed by experts that have been in the industry for years.

No Additional Medicines Are Required

When you are using Steel Bite Pro, you can avoid using other medicines that you have been taking to cure oral issues.

Attacks on the Pain

There are several ingredients present in Steel Bite Pro that attack tooth and gum pain so that you get some instant relief with the supplement.

Comes With a Money Back Guarantee

The supplement comes with a 60-day money back guarantee, so you can claim a full refund if you find the supplement isn't working for you, or if it isn't doing what the manufacturer has promised.


You Can Purchase It From the Official Site Only

The supplement is only available for purchase from the Official Website. Sometimes the supplement gets out of stock, so you have to wait for it to get back in stock.

A Single Bottle Costs More

If you buy a single bottle of the supplement, it'll cost you more than other packages with multiple bottles.

Ingredients in Steel Bite Pro

All the ingredients present in Steel Bite Pro are natural and have proven benefits for humans. Here is a list of supplements explained in detail and how they can benefit you if you start using Steel Bite Pro.


As per a study, there are innumerable benefits of using turmeric on your teeth. The natural herb has antimicrobial properties that help remove the plaque effectively from the teeth, exterminate bacteria and help cure sensitivity.

Moreover, turmeric is good for fighting oral inflammation issues. When applied on teeth, the ingredient gives instant relief from pain and is effective in curing mouth ulcers as well.


Berberine is a natural herb with proven antioxidant power to help you get rid of microorganisms developing inside the mouth. Furthermore, the ingredient has anti-inflammatory properties and is good for curing oral issues caused due to viruses and bacteria.


It is another natural ingredient that is used in a range of health supplements due to its healing power. The ingredient naturally heals the gums and the damage caused to the teeth by bacteria and microorganisms.

As per a study, it helps reduce the infection, oral pain, and cures other dental issues.

Milk Thistle

Your liver has a significant impact on your oral health, and that's where milk thistle works. The natural ingredient eliminates toxins from the liver and detoxifies your mouth as well.

Here is a study that proves how milk thistle is beneficial in detoxifying the liver.


The decaying of teeth is the initial phase of damage caused by bacteria thriving inside your mouth. Alfalfa works by reducing tooth sensitivity drastically and repairs the tooth decay caused by the bacteria.

It even stops the bacteria from growing further so you can expect good oral health.


A lot of natural supplements for teeth contain ginger because of its benefits on the teeth and the stomach. This ingredient present in the Steel Bite Pro reduces nausea and inflammation.

As per this study, there are umpteen other benefits of ginger as well, such as it maintains the pH inside your mouth.

Jujube Seeds

Jujube seeds are good for boosting the immunity. Also, the ingredient has excellent antioxidant properties and is rich in Vitamin C, which is beneficial for the teeth and overall oral health.


Dandelion is a natural ingredient extracted from herbs. The ingredient is rich in minerals and has immense benefits such as fighting the bacteria and preventing the infections occurring inside your mouth.


Zinc is essential for teeth, and that is why many toothpaste brands advertise that their product contains a good amount of zinc. Further, zinc is a natural immunity booster and fights against bacteria to prevent gum disease and cavities.

Moreover, zinc repairs the enamel on your teeth that's damaged due to toothpaste or any other reasons. Here is a study that shows the benefits of zinc for your teeth and mouth.

Chicory Root

Chicory root acts as a catalyst and increases the effectiveness of other ingredients. The reason why you get instant relief from pain after using Steel Bite Pro is due to the presence of chicory root in the pills.

Celery Seeds

Bacteria result in bad odor and can create cavities in the teeth. Furthermore, some bacteria result in tooth decay and harm the gums. The celery seeds fight these bacteria and prevent further growth.

Yellow Dock

To stay healthy, the teeth need to absorb the minerals present in the saliva. When your teeth are damaged for any reason, they stop absorbing the minerals, and the damage continues further.

Yellow dock helps the teeth to absorb the minerals while reducing the inflammation. Various studies have proven the efficacy of yellow dock for teeth and gums, and it is a natural and effective ingredient to keep the teeth healthy.

Raspberry, Chanca Piedra, and Artichoke

These three natural ingredients have similar properties and contribute a lot to the effectiveness of Steel Bite Pro. The ingredients have good amounts of vitamins and minerals, including Vitamin K, Vitamin C, magnesium, phosphorus, and folate.

The purifying agents will remove bacteria and other impurities from the mouth so that the other ingredients work well by repairing the teeth and gums.


The worst thing about oral issues is the pain that you have to go through. Steel Bite Pro claims to help with the pain as it contains feverfew, which is a natural pain reliever. The ingredient suppresses oral and dental pain so you will feel better instantly.

As per a study, there are some other benefits of feverfew, because it is a medicinal plant that suppresses other pains as well. Also, there are no side effects of feverfew at all.

Burdock Root

The root of the burdock plant comes loaded with antioxidants that improve the gum health and the overall health of your mouth.

The best thing about Steel Bite Pro is that the ingredients are present in exact quantities, so you can rest assured that there will be no side effects. Every ingredient is tested in the labs for its efficiency, and that's what makes the Steel Bite Pro a considerable option if you want to improve your oral and dental health.

Click here to See the full list of ingredients in Steel Bite Pro on the official website.

How Does Steel Bite Pro Work?

It is crucial to understand how the supplement works so that you can decide whether to invest in it or not. Below is a step by step process that will help you understand Steel Bite Pro on the go.

Step 1:

When you start consuming the supplement, the pills break down in your mouth. The ingredients then mix with saliva to perform their particular actions.

Step 2:

The ingredients fight the bacteria and heal issues such as wounds while reducing the inflammation caused in the mouth.

Step 3:

The supplement cements the root of the teeth so that there are no further oral and dental issues. Also, it heals the gums and repairs the enamel to provide you relief from sensitivity.

The minerals present in these ingredients strengthen the crown area of the teeth while repairing the cracks so that the damage can be stopped.

Step 4:

The supplement also has some impact on your overall health as the ingredients detoxify the liver by flushing away the toxins.

Step 5:

Consuming the supplement regularly will help you maintain the shield on the teeth that fights against bacteria and microorganisms. Also, it improves the condition of the teeth and curtails bad breath.

The working of Steel Bite Pro is really simple, as there are no complex ingredients present in the supplement. It is easy to use, and all you have to do is consume the pill regularly to keep your oral and dental health up to the mark.

Benefits of Steel Bite Pro

There are many benefits of using Steel Bite Pro since it is an all-natural supplement that has no side effects at all. Here are some benefits you need to consider before buying it.

Prevents Bleeding and Improves Gum Health

The reason why your teeth bleed is due to the loose gums. The space between the tooth and the gum results in bleeding, and that's where Steel Bite Pro helps. The supplement tightens the gums so that there is no bleeding at all.

Whitens the Teeth Naturally

The ingredients present in the supplement, such as zinc and milk thistle, whiten the teeth naturally. There is no need to invest in expensive teeth whitening toothpaste if you are using Steel Bite Pro.

Reduces Bad Breath

The supplement contains ingredients that improve the overall health of the teeth, and it automatically reduces bad breath.

Helps Cure Tooth Pain

Steel Bite Pro has feverfew, which is a natural pain reliever ingredient. The ingredient cures tooth and gum pain and can have instant results after you consume Steel Bite Pro.

Click here to Learn more about the Benefits of Steel Bite Pro on the official website.

Side Effects of Using Steel Bite Pro

You may find it surprising, but Steel Bite Pro has no side effects at all as the supplement contains natural ingredients and has exact quantities so that there are no ill effects on your health. If you keep using the supplement as prescribed, then it can have some excellent results.

Who Should Refrain from Steel Bite Pro?

Steel Bite Pro is an all-natural dietary supplement to improve your dental and oral health.

Anyone can use the supplement, including pregnant women and breastfeeding mothers. There are no harms of using the supplement.

However, it would be great to consult a doctor before using the supplement to find out if you are allergic to any of the ingredients.

Dosage and Tips to Start

To get the most from Steel Bite Pro, you should consume two pills with water every day. Take both capsules together anytime that's convenient for you.

To get the best results, follow a brushing regime, and massage your teeth regularly with some good-quality oil to increase the effectiveness of the pills.

Where to Buy Steel Bite Pro, and Guarantees?

You can only buy Steel Bite Pro from the Official Site, as the supplement is not available anywhere else for purchase. You can choose from three available options:

●1 bottle (60 pills) $69

●Three bottles (180 pills) $117

●Six bottles (360 pills) $294 (Best Deal)

You get a 60-day money back guarantee with all the packages, no matter if you go for one bottle or six bottles. You are eligible to claim the full refund within 60 days of the date of purchase.

Steel Bite Pro Reviews: Closing Thoughts

After this definitive review, it will be easier for you to find out whether you should use Steel Bite Pro or not. The supplement contains a mix of 29 natural ingredients that have proven benefits and are tested in labs.

It is essential to get rid of oral and dental issues before things get out of control and you have no option left despite visiting a dentist.

Getting a good quality supplement is essential, so Steel Bite Pro is a viable option if you need a supplement with no side effects.

Anyone can use this supplement irrespective of age, sex, and medical conditions. Lastly, buy the supplement only from the official site so that you can easily claim the refund if required.

Click here to Get the best deal on Steel Bite Pro from the official website.

For the first time on record, the main nursery of Arctic sea ice in Siberia has yet to start freezing by late October. Euronews / YouTube

By Sharon Guynup

At this time of year, in Russia's far north Laptev Sea, the sun hovers near the horizon during the day, generating little warmth, as the region heads towards months of polar night. By late September or early October, the sea's shallow waters should be a vast, frozen expanse.

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Fossil remains indicate these birds had a wingspan of over 20 feet. Brian Choo, CC BY-NC-SA

By Peter A. Kloess

Picture Antarctica today and what comes to mind? Large ice floes bobbing in the Southern Ocean? Maybe a remote outpost populated with scientists from around the world? Or perhaps colonies of penguins puttering amid vast open tracts of snow?

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