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Judge Rules Big Oil Can't Be Sued For Climate Change Costs (cbsnews.com)
An anonymous reader shares a report: A U.S. judge who held a hearing about climate change that received widespread attention ruled Monday that Congress and the president were best suited to address the contribution of fossil fuels to global warming. So he threw out lawsuits that sought to hold big oil companies liable for the Earth's changing environment. Noting that the world has also benefited significantly from oil and other fossil fuel, Judge William Alsup said questions about how to balance the "worldwide positives of the energy" against its role in global warming "demand the expertise of our environmental agencies, our diplomats, our Executive, and at least the Senate. The problem deserves a solution on a more vast scale than can be supplied by a district judge or jury in a public nuisance case," he said. Alsup's ruling came in lawsuits brought by San Francisco and neighboring Oakland that accused Chevron (CVX), Exxon Mobil (XOM), ConocoPhillips (COP), BP (BP) and Royal Dutch Shell (RDS.A) of long knowing that fossil fuels posed serious risks to the environment, but still promoting them as environmentally responsible.
Glad the judge had enough sense to throw this case out.
Want to get public action on climate change? Convince people and win elections. Using the courts to forward your agenda can and will backfire.
I seem to remember a particular article written about a party using the courts to forward their agenda is bad.
If Big Oil is to be held liable, then we have to throw in the anti-nuke scaremongers and NIMBYs.
long knowing that fossil fuels posed serious risks to the environment, but still promoting them as environmentally responsible.
No one ever promoted fossil fuels as environmentally responsible. The point is they produce enough energy for our needs at an acceptable cost. It would be lovely to have cleaner alternatives.
It's also really weird to leave out coal. Isn't coal an overwhelming portion of the problem?
I think Big Oil needs to be punished for this misinformation campaign. Spreading the belief that Fossil Fuels are not causing global warming or global warming doesn't exist, also their effort to criticize alternative energy sources to prevent energy diversity is rather shady as well.
That said, Fossil Fuels offer a rather safe high density and portable energy source. Where failure of such companies to meet the demand for oil would also be harmful and criminal.
The Gasoline Automobile was considered an environmental friendly invention, at the time. Mostly due to the fact the pollution effect is less then the effect of having a lot of horses in a City, Needing food and cleaning, Attracting pests and plagues.
Alternate sources are getting close (I feel they would be closer if Big Oil didn't try to keep them down) to being as good as Fossil Fuels, Exceeding it in some areas, but behind in others. But I doubt we can truly get off Fossil Fuels, but we can be able to replace a lot of it.
Big Oil isn't the cause of climate change, it is the consumers who are.
The difference between Tobacco and Oil is that Tobacco doesn't have many or any real advantages other then for entertainment. So its harmful side effects which were hidden lied about and distorted (like what big oil had done) were not offset by its advantages.
If something is so important that you feel the need to post it on the internet... It probably isn't that important.
Well, yes. Political questions should be decided politically.
(No, I don't own any oil stock.)
This is one of those things where the actual responsiblity is so spread out that it's just ridiculous to blame the vendor.
How many hundreds of times have YOU personally made the decision to fill your vehicle with fuel? You damn well knew (you did not merely suspect, you the person doing it knew) that it was definitely and inevitably going to pollute the air, with zero chance that it wouldn't pollute. And it was going to happen as a direct consequence of you running your engine after yyou having decided to turn the key.
But no, it's not all on you, because there are hundreds of millions of people, just like you, who were in exactly the same situation and made the same decision that you did. And just like you, those hundreds of millions of people knew for sure, without the slightly doubt or speculation, that their own vehicles were going to definitely going to cause air pollution, and that as a whole, all our vehicles working together were going to pollute in a large, significant way.
And me too. You can blame me for my share. I have filled my tank and driven many times.
Did we do this because we were tricked? Fuck no. We did it because we didn't have a better alternative. Whose fault is that? Reality's fault. It's a shame we don't have teleportation spells, but we don't, so we burn stuff for energy, knowing that it pollutes.
Some people make an effort to stop doing that. That's great. Fuck yeah! You're awesome. And that's the way ahead: high-five the people who make the choice to stop polluting, instead of blaming the people who .. well, no, not the polluters, but whose who sold us the means to pollute, as if We The Burners deserved less blame than they do. If you're going to point your fucking finger, point it at everyone. Point it at the earth itself. Point it at the gods for not giving us teleportation spells.
If you need to blame big oil for something, you might have a better case for pollution that is directly tied to drilling, like for spills, pipelines disrupting habitats, etc. That's totally fair game, because oil can be delivered without fuckups if people try hard enough and are willing to pay enough. (But that's not what this story is about. But I'm giving you an out here, if you need a bad guy and you refuse to accept that we are all the bad guys.)
"Believe me!" -- Donald Trump
That judge may or may not have the law interpreted correctly, but his spew about politicians making decisions about science rather strongly suggests the majority of his income derives from ExxonMobil or the equivalent Putin-owned company.
One more example of why judges should be required to accept the input of nonlegals like, you know, scientists and software professionals.
As long as we're getting our governmental wires crossed, let's have our elected representatives vote to lock him up!
Your view of the world is 'interesting'.
You think 'Big Oil' is a thing, like a group that holds meetings and makes decisions.
You imagine that judges decide what sources are used to defend a particular side in a court case - that is left to the attorneys.
I like how you lump 'software professionals' with scientists - I'm going to guess you wanted to be a scientist, but wound up a software professional, so you viewcthem as equivalent.
Ken
like what's causing the warming, and what the speed and essential content of response needs to be,
should be decided by science,
and then the results of that should be respected by political leadership.
Oh what a wonderful world that would be....
Where are we going and why are we in a handbasket?
San Francisco and Oakland: Oh please, let us sue the oil companies. Oh please let us sue them from our glass towers funded by hi-tech industry, fueled by the very energy we decry, birthed by the military-industrial complex we revile. Oh please, mr. judge we implore you! We're good liberals. Pay no attention to the prime mover behind the curtain.
Judge: No.
For all intensive purposes, "whom" is no longer a word. That begs the question, "who cares"?
I love this logic - he must be on the payroll of 'big oil' to reach that conclusion, otherwise my long-held beliefs are wrong! it's right up there with 'the Russians threw the election, otherwise I have to admit that Hillary was a lousy candidate.
Ken
I think that what he meant by "turning off the tap" was something more current and abrupt, not 100 years from now. And in that scenario, many people likely could die, without heat, or transport of food and medicine.
Look back up at my post, now look back down, you're on the Internet. Now look back up. I'm a signature.
why judges should be required to accept the input of nonlegals like, you know, scientists and software professionals.
Never heard of Friends of the Court? Amicus curiae to the Latin speakers.
Please learn about how the judiciary works before you spew misinformation.
I'm giving up using oil, gasoline, plastic and electricity made from fossil fuels. Now if I can only find a hydrogen powered steam engine to run my generator.
Let me see if I understand you correctly.
A. You think this judge is a jackass.
B. He's a jackass because he declined to unilaterally decide energy policy, instead leaving policy to policy-makers.
C. You would have preferred for the jackass judge to decide national energy policy himself.
Is that about right?
But you do know that people only exhale as much CO2 as the food they eat took from the atmosphere?
I don't tend to "know" things that are false.
CO2 exhalation is a result of a chemical process in our body, and has no relation whatsoever to the amount of whatever we consumed itself consuming CO2. I mean, how on earth to you square your insane belief system with someone on an all-meat diet, where a cow itself exhales CO2 and then we kill the cow and eat it and ourselves produce CO2 in turn? What about someone on an all-water diet for a week or two who continues to exhale CO2?
Talk about anti-science...
It is a zero sum game, or are you an complete idiot?
What I have found in life is that people who believe anything is a "zero-sum game" are the same kind of naive quacks that believe in crystal healing and perpetual motion machines...
"There is more worth loving than we have strength to love." - Brian Jay Stanley
Ok, let's hypothesize this. Whose responsibility is this, and why?
And just making sure: you're saying the public has less responsibility than the people who sold them the fuel, right? We could have gradually started using less and less, but it was more important that the vendor had the discipline to make sure they didn't sell us too much each year, correct? And were they also supposed to make sure a competitor didn't come in and fill the remaining demand Should Exxon have resorted to deadly force to prevent BP from selling people too much?
I think you are straining to avoid putting the responsibility where it really belongs. OTOH, if you blame the people who burn the fuel, all the weird shit goes away.
"Believe me!" -- Donald Trump
The courts are good at individual cases that have nuance and the technicalities of jurisprudence. That is not the place to drive social agenda to solve societal problems.
As a general proposition I agree but sometimes there is no other choice. The rest of the government doesn't always act in a manner that makes social change feasible.
People exhale CO2. When the EPA or courts expands the authority of the government to regulate CO2 as a pollutant they can effectively regulate your breathing.
That's one of the more ridiculous arguments I've read in a while. No amount of breathing by humans makes CO2 a pollutant. Massive release of sequestered CO2 from burning coal and oil does make CO2 a pollutant. Anything can be a pollutant if there is enough of it to screw up the ecosystem. Do you really not understand the difference between regulating industry emissions of a chemical versus respiration? Exactly how do you think an EPA regulation will deny you access to breathing?
I'm mostly there with solar power and electric cars. My lawn mower and snow blower are next. Eliminating plastic is beyond me, but I do try to minimize my use when it's practical.
If your roof isn't shaded by trees, then solar electricity probably makes sense, especially if your state offers any sort of incentive program. A few states have anti-solar programs (Florida) or really cheap electricity (Idaho), but even without incentives, it's becoming cost effective in many areas.
If you drive under 100 miles a day, there's little reason not to be driving electric. Certainly for most two-car families, one should be electric. Plug-in hybrids give you many of the advantages, allowing you to only buy gas on trips unless you have a particularly long commute. Having switched entirely to pure EVs, I have no regrets.
By all means live an Amish 15th Century technology lifestyle!
I think I will keep my lifestyle with vaccinations and Internal Combustion engines that can get me anywhere in the world in about 24 Hours. You know like Al Gore and all the other high living Global Climate "Experts."
RDS is not American. For that matter, other countries can sue all of these companies too.
Stop trying to protect your dying fossil fuel industry.
-- Tigger warning: This post may contain tiggers! --
So I must point out that if we just dump fossil fuels today, everybody, across the board, we are going to be in a world of hurt
Which is an argument for a gradual replacement of power supplies with more sustainable ones, rather than abruptly dynamiting all the existing power plants and outlawing internal combustion engines. But gradual replacement is exactly what we are doing. Nobody is advocating an abrupt "stop all fossil fuel use immediately right now." So I'm not sure what your point is.
http://www.geoffreylandis.com
Try again.
Crops are grown using synthetic fertiliizers that rely on the Haber Bosch process to provide the nitrogen compounds. It's an extremely energy intensive process. The crops are further mechanically sown, use synthetic pesticides, and are mechanically harvested, transported and packaged . All of these processes use oil. The same goes for animal feed and caring for animals.
Try actually thinking next time.
When Vermin Supreme is elected and we switch to a pony based economy, all these problems will be solved.
There are 200,000 ponies in America, 300 million people. Every person gets a pony, genocide might be required to make the math work.
John McAfee 'It was like that time I hired that Bangkok prostitute; to do my taxes, while I fucked my accountant'
You think 'Big Oil' is a thing, like a group that holds meetings and makes decisions.
There was even a documentary about that selfsame group trying to influence US energy policy in the early '90s. They even had an official meeting.
What are you complaining about, I've downsized to a 5 liter V8. (But I smeared some JB weld onto the cam lobes and put in a lower ratio final drive gear.)
John McAfee 'It was like that time I hired that Bangkok prostitute; to do my taxes, while I fucked my accountant'
And an explosion of human life was the result.
(-1: Post disagrees with my already-settled worldview) is not a valid mod option.
Have you seen the battery bank for that monster. ROI for running that thing is still unviable. Maybe in the future we will have cheaper versions, but for now that beast is out of reach for the vast majority of farmers.
Some days I get the sinking feeling Orwell was an optimist.
It sounds like you didn't read the article at all. Or even the summary for that matter.
but his spew about politicians making decisions about science rather strongly suggests the majority of his income derives from ExxonMobil or the equivalent Putin-owned company.
I see no such statement in the article. What are you talking about?
One more example of why judges should be required to accept the input of nonlegals like, you know, scientists and software professionals.
He did. The article says:
Alsup brought in the world's leading experts on climate change at an unusual hearing in March that he said was intended to educate him about the science behind the Earth's warming.
We are *all* guilty.
Singling out the folks that dig the stuff out of the ground, clean it up, and bring it to the rest of us is just scapegoating.
"Reality is that which, when you stop believing in it, doesn't go away." - Philip K. Dick
Your view of the world is 'interesting'. You think 'Big Oil' is a thing, like a group that holds meetings and makes decisions.
Yes, in fact they were and they did, in the form of the American Petroleum Institute.
In a 1998 memo, they outlined their "action plan" for a campaign to cast doubt on climate science. Which they implemented pretty much as written.
(despite the fact that they had already-- in 1980-- identified climate warming due to carbon dioxide as a problem.)
(news article here.)
Since we are going to run out of fossil fuels, we better have to. And if the burning of those last fossil fuels heats our environment so much that we will have a hard time growing food, what is the use of trying to distribute that non-growing food?
I have seen this argument before. When we do get close to actually running out of fossil fuels (50 years by some estimates), the free market is the best solution for finding answers to the problem. Using the court system to sue oil companies today only slows any progress they will put forth to find a new business model later. If you think companies like Shell or BP are not investing in energy for the future, then you are very naive.
Some days I get the sinking feeling Orwell was an optimist.
Try again.
Crops are grown using synthetic fertiliizers that rely on the Haber Bosch process to provide the nitrogen compounds.
And I never said it wasn't. The question was where does the carbon you exhale come from. The answer is, it originated from plants, who fixed it from the atmosphere.
It did not originate from the fertilizer. The fertilizer provides nitrogen, not carbon.
http://www.geoffreylandis.com
Not only oil companies are liable for Earth's changing environment but thermal power generating units are also responsible. Attention must be paid to nuclear power plants. It has 100,000 times the energy density of coal, so that even a small plant would be much more efficient than huge, noisy dams and wind farms, which spoil the landscape.Water, wind, and solar power cannot reliably provide energy on the scale required for a modern economy. One kilogram (2.2 pounds) of water behind a dam that is 100 metres (328 feet) high can provide just 1/3,600 kilowatt hours of energy. One kilogram of coal, by contrast, provides about 7 kWh of energy — 20,000 times more. Renewable energy is best for peak load while nuclear power is very much required as a base load plant. https://electricalbaba.com/loa...
Alsup is actually one of the most respected, non-corporate, judges in the US at the moment, and has a tendency to end up with the more difficult cases. He most certainly does seek the input of experts, and even - in the Oracle vs Google case, for example - took the effort to learn programming so he'd have a better understanding of the case.
Your criticisms are severely misplaced. I'd like to find some way to hold the fossil fuel industry to account too, but if Alsup of all people is saying this path is a no-go, then we should find alternatives.
You are not alone. This is not normal. None of this is normal.
Why can't both be true?
So to be clear regardless if you think the judge actually is capable of doing his job, the fact he correctly states that it's the government's job to determine policy makes him in the pocket of an oil company or Russia?
Do you have a newsletter I could subscribe to?
One more example of why judges should be required to accept the input of nonlegals like, you know, scientists and software professionals.
So as a matter of interest, the fact that the judge clearly acknowledged the link between global warming and CO2 which is the only nonlegal aspect of this case, what would have changed? Do you think the presence of a scientists telling the judge something he already acknowledged suddenly changes the fundamental way our governments are setup?
I have an idea, maybe you should leave legal decisions to the legals.
I don't know what is going on ... but SOMEONE owes me a million dollars !!
I'm betting you wouldn't have the guts to tell someone living in the poorest parts of Africa or Asia that the food they have to scramble to get to literally keep their kids from starving to death will cost twice as much because you want to virtue signal and outlaw the use of fossil fuels.
I'm betting they do. How many people die from Malaria in Africa? That's not stopping many from trying to ban DDT worldwide.
The cities attorney was quoted as saying:
"Our litigation forced a public court proceeding on climate science, and now these companies can no longer deny it is real and valid."
I actually wonder who he's referring to. BP a major investor in Wind power in the USA, who's CEO is pushing for a price to be put on carbon? Royal Dutch Shell a major investor in electric charging infrastructure? Chevron with their work on Solar power? Conoco Phillips who have published on their homepage: "We recognize that human activity, including the burning of fossil fuels, is contributing to increased concentrations of greenhouse gases (GHGs) in the atmosphere that can lead to adverse changes in global climate.". Or maybe Exxon who have published a page dedicated to the very art of not denying climate change is real and valid http://corporate.exxonmobil.co....
Congratulations San Francisco! What a .... errr ... win?
Now can we please eliminate the San Francisco city attorney who is constantly expelling CO2 while contributing nothing at all of value to society.
Source:
https://www.ecowatch.com/clima...
Elon is about to display his new lithium powered AI driven gurneys in a few weeks I heard. Medicare funding will be diverted just a wee bit into this new ground breaking technology.
The main issue is that all of this carbon has been slowly trapped in the earth over the last hundreds of millions of years, until we started releasing it at an alarming rate within the last few hundred years. That's obviously going to have a significant affect on the environment.
This is a fairly long read, but worth it. At least checkout "The Story of Energy" section.
Fossil fuels... what were fossils again?
genocide might be required to make the math work.
Eggs, omelet, repeat as necessary.
If Big Oil had shifted their focus decades ago to renewable energy, who knows how much further we would be advanced on that subject. Perhaps we would have only pushed back global warming a few years, perhaps decades. We will never new because Oil companies would rather use that information for increasing the height of their oil rigs and protect their investment.
Place something witty here
I could just wave a magic wand and remove anything and everything derived from fossil fuels from protester's lives. They would be so fucked, it would be hilarious to watch. And many of them appear too stupid to even know it.
All the carbon containing fossil fuels were also technically produced from CO2 captured by photosynthesis.
Filthy plants polluting the world with their complex carbon chains and corrosive O2.
You are confusing the CO2 required to produce food, and the CO2 we exhale. Let us ignore the CO2 produced by food. We as human , do not exhale more CO2 than what we use as energy (actually CO2, H2O and various other elements through urine). If we exhaled MORE than we consumed , we would *loss weight*. If we exhaled less than we consume we *gain weight*. It is a simple fact that for a normal human in homeostase and not gaining/losing weight (let us ignore exchanging muscle for fat and vice versa - so a first approximation), what we consume is what we exhale. As such the GP is right, and not anti science, we are not exhaling more CO2 than we consume. Now the food we produce generate different amount of CO2 depending on what is produced, how it is transported and how it is prepared, but that is different than pretending human would be taxed on their BREATH what the OP was pretending would happen.
C. Sagan : A demon haunted world:
http://www.amazon.com/gp/product/0345409469/
visit randi.org
I say free the trapped CO2 - For a warm and verdant future. Our planet has definitely seen higher CO2 levels than humans have recently experienced. It's called a greenhouse gas because it is added to greenhouses in order for plants to thrive. If you love trees you'll join my movement
this sig is deprecated
Venus begs to differ. Or are you suggesting that CO2 has no effect at all in the atmosphere?
Those who advocate genocide deserve every protection afforded by law, and none afforded by common human decency.
So if by "almost" there I mean 80%, I can ignore plastics completely, as that's only 4% of oil. But you're right when it comes to oil used for other things besides my cars. 70% of US oil consumption is for transportation, and 65% of that is personal vehicles.
So switching to EVs for personal transport accounts for about 45% of oil use. Since we have solar, I would say we can safely say we've fossil fuel consumption on our behalf by over 50%. Yes, that's not "almost" there, but it's a very sizable dent.
If everyone reached for the low hanging fruit, we would be in much better shape.
You don't think maintenance of roads may have something to do with the amount and type of traffic riding on those roads...
Or do you think places just repave all the roads every year?
What about all of those people who were complicit in this environmental crime? What of those of who had dirty 2-cycle lawnmowers and big gas guzzling cars, and who heat our homes using propane, NG, coal, and wood?
What about the basic "that's how civilization works" ?! We'll learn and change as a civilization - no single company did this. We were all complicit together.
Now - go recycle those soda can's boys and girls.
And - stop using plastic gosh darn-it.
The fucking moron environmentalists killed the nuclear energy program - where we wound't have had this issue in the first place.
https://www.youtube.com/watch?...
And an explosion of human life was the result.
The Green Revolution simply postponed starvation events, and made them bigger because populations grew before they occurred. You get higher yields with intensive farming of guilds than by using synthetic fertilizers on monocultures. And now that the efficacy of synthetic pesticides is waning, farming monocultures is becoming inviable. In fact, planting monocultures literally produces pest swarms (by providing them with abundant food) and those swarms then move on to other fields and decimate them, too. Everything about green revolution farming is wrongheaded, because it is destructive to the biosphere and the land's long-term ability to produce food.
TL;DR: The result was (and will continue to be) larger starvation events.
"You're right," Fisheye says. "I should have set it on 'whip' or 'chop.'"
Citing inside climate news is like citing the daily mail.
There's any number of sites that have the memo on them. I cited those two because they have the actual scan of the memo on them, not merely the text file, and added the New York Times article, as a mainstream media source, but if you don't like those, I can send you a few dozen other links to the file. Or you could just google it.
By the way, everything you're accusing Exxon of is actually what a group of environmentalists and plaintiff's lawyers decided to do,
I gave a citation and links to three different sources. Where is yours?
Ah, you don't have a citation, you're making that up. Right. That's a trick right out of Göbbels, that "the cleverest trick used in propaganda" is to accuse your enemies of what you yourself are doing.
with funding by various Rockefeller foundations (among others). The main people that would benefit from this case being successful would be the class action attorneys, who would stand to make hundreds of millions if not billions.
Have you fully thought about the fact that the fossil fuel industry is a trillion dollar industry? Mere "hundreds of millions" is less than penny ante to them.
Who is more likely to fund a campaign, an industry that has a trillion dollars at stake, or some random collection of lawyers who say wait, maybe if we believe the science, some time in the far distant future some laws might or might not get written that might or might not allow a new grounds for lawsuit? Oh, wait, we know the answer to that, because we already have the American Petroleum Institute memo laying out their campaign and asking for 2 million dollars in funding... for the first year.
Yes, that's right-- the API considered this so important that they could ask fossil fuel companies to contribute a whopping 0.0002% of their cash flow to deal with it.
Petroleum comes from plants. Over a few thousand years (we used to think millions, but it's pretty easy to show that decomposition of plants under pressure happens much, much quicker).
All the carbon that is released from petroleum, originally came from the atmospheric carbon soaked up by plants.
SJW: a person who perceives an injustice, and while correcting it, commits a greater injustice.
And all the oil used- came from plants.
SJW: a person who perceives an injustice, and while correcting it, commits a greater injustice.
I'm betting you wouldn't have the guts to tell someone living in the poorest parts of Africa or Asia that the food they have to scramble to get to literally keep their kids from starving to death will cost twice as much because you want to virtue signal and outlaw the use of fossil fuels.
I'm betting they do. How many people die from Malaria in Africa? That's not stopping many from trying to ban DDT worldwide.
Actually the ban is to keep it effective. Widespread DDT use = Mosquitoes that are not effected by DDT.
My Transformation Website
Kindle Books http://www.catprog.org/rev
Interactive CYOA http://www.catprog.org/st
They've found oil underneath forests in Mexico. And there is evidence that when you find oil underneath plant life, those oil fields naturally replenish themselves.
SJW: a person who perceives an injustice, and while correcting it, commits a greater injustice.
http://www.rense.com/general63/refil.htm
I don't know why that link didn't post
SJW: a person who perceives an injustice, and while correcting it, commits a greater injustice.
Of course that so-called "fossil carbon" was mainly forest a few thousand, or hundred thousand, years ago, and thus plants.
Uh, I believe you mean a few hundred million years ago.
A hundred thousand years is mere a blink of an eye in geologic time.
http://www.geoffreylandis.com
And the potassium and phosphorus (the other members of the "big three" of fertilizer science) come from ... unicorn farts? Or, are they mined? Out of holes in the ground? Just possibly.
Have you read a review of K and P resources recently? It's not pretty reading. Particularly if you've got children.
Birds are not dinosaur descendants;birds are dinosaurs, for all useful meanings of "birds", "are" and "dinosaurs"
Very true. Most people don't realize how industrial a process farming has become, and how extractive it is.
First, I realize my quoting your question left it ambigiois what I was answering no to.
No, Iâ(TM)m not bothered or worried in the least whether or not (mis)information campaigns do or do not align with the conclusions I find in peer reviewed journal articles. If the facts are soundly reasoned by relevant experts it certainly shouldnâ(TM)t matter to anyone valuing the scientific method.
Regarding observed warming for the last 100 years, Iâ(TM)ve already stated many times that there is no uncertainty there at all.
I also realize in reviewing the paragraphs I quoted I missed inserting ... between each, the Italicized paragraphs in the previous post do not necessarily follow immediately after one another in the journal article referenced and apologies that the layout unintenionally gives that appearance.