1/9. There are many problems with this rule. Pruitt/Wheeler threw out EPA's own established procedures to short-circuit the science review: changes to the review process since 2017 undermined its quality, credibility, and integrity.

2/9. Pruitt/Wheeler kicked all 7 members off the Clean Air Scientific Advisory Committee, and replaced them under a policy found to be arbitrary and capricious by the U.S. district court of SDNY. The repopulated CASAC has the appearance of lack of impartiality.
3/9. Wheeler refused to form a CASAC Ozone Review Panel 3 months after EPA issued a call for nominations for such a panel, thereby depriving CASAC of the breadth, depth, and diversity of expertise, experience and perspectives needed for ozone NAAQS Review.
4/9. The Ozone review process was truncated and accelerated, leading to inadequate scientific review, and inappropriate commingling of science and policy reviews. Fewer opportunities for public comment created a less transparent NAAQS scientific review process
5/9. As professional malpractice, the stripped down and reconstituted CASAC offered advice outside of its expertise, particularly with regard to epidemiology (there were zero epidemiologists on CASAC). The CASAC chair imposed a burden of proof contrary to that of the CAA.
6/9. CASAC and Wheeler failed to adequately consider at-risk populations. Expert judgment is needed to advise regarding at-risk populations because direct empirical evidence regarding at-risk populations is lacking. CASAC lacked the basis/credibility for making such judgments.
7/9. One member of CASAC acknowledged that "asthma has important features beyond airflow limitation," yet such features were not adequately accounted for in the Administrator's decision.CASAC failed to advise that levels below the current standard would provide margin of safety.
8/9. In a 2015 Wall Street Journal op ed, Dr. Cox, who chaired CASAC in this review, stated that it is “cynical” to “use” “asthma patients to promote a pro-regulation political agenda.” Why was he chairing the ozone review? This is clear appearance of lack of impartiality.
9/9. EPA engaged in science denial in rigging the scientific review process to assure an answer that would fit a predetermined policy outcome. EPA needs to restore process and procedures to re-establish credibility and to assure that regulations follow the science and the law.

More from Economy

1/ Trend Factor: Any Economic Gains from Using Information over Investment Horizons? (Han, Zhou, Zhu)

"A trend factor using multiple time lengths outperforms ST reversal, momentum, and LT reversal, which are based on the three price trends separately."

https://t.co/udkvsdw2Lz


2/ This resembles combining multiple measures of ST reversal, momentum, and LT reversal (forecasts determined by walking forward rather than using signs from the full sample).

Unlike normal moving average signals, these are *cross-sectional.* More below:
https://t.co/wkIFLg9jtK


3/ Unsurprisingly, the Trend factor formed by this approach outperforms benchmarks in terms of both Sharpe ratio and tail metrics. It's combining momentum with two factors that are negatively correlated to it AND using multiple specifications.

More here:
https://t.co/x8Tloz3iyL


4/ "Average return and volatility of the trend factor are both higher in recession periods. However, the Sharpe ratio is virtually the same.

"Interestingly, all of the factors still have positive average returns.

"Momentum experiences the greatest increase in volatility."


5/ "In terms of maximum drawdown and the Calmar ratio, the trend factor performs the best.

"The trend factor is correlated with the short-term reversal factor (35%), long-term reversal factor (14%), and the market (20%) but is virtually uncorrelated with the momentum factor."
Long rant: This @WSJ article bemoaning the decline of price theory is really worth highlighting. The economic theories and so called "laws of economics" that the WSJ consistently and religiously defends, are the source of their authority, power and privilege.


So called economic "theories" like "you get paid exactly what you are worth" and "markets are perfectly efficient" and "when wages rise, jobs fall" and "raising taxes on the rich kills jobs and growth" and "increasing justice decreases economic efficiency" and...

"Government intervention in markets always creates more harm than good" and "any regulation that constrains corporations kills growth and productivity", etc etc are effectively a protection racket for the rich. It is a set of internally consistent and mathematized conjectures...

That are all demonstrably nonsense. But getting people to accept these "theories" as laws of nature and immutable, timeless truths is the most effective way our current economic elites have found to maintain and enhance the status of the powerful and persuade the weak and poor...

to shut the fuck up and accept their lot in life. Now, FINALLY, some economists- are actually beginning to look at the real world evidence to determine whether these propositions actually describe anything real here on planet earth. Let me save you some time. The answer is NO.

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