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For nearly two decades, efforts have been made to formulate an environmental right. Among the most prominent examples are the Stockholm Declaration of 19721 and, more recently, the statement of principles for environmental protection and sustainable development of the United Nation's World Commission on Environment and Development.2 Parallel endeavors also have been made in the domestic context. Proposals have been made periodically in the United States for amendments to the federal Constitution,3 and a number of states have adopted broad-ranging environmental provisions in their constitutions.4
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