Place-Based Theory of Standing, A

issue of law and that a plaintiff should have something beyond a generalized interest in law enforcement. While respecting these views that underlie current doctrine, the place-based approach seeks to implement them in a doctrinally simpler way. Although less sweeping in legal terms, the place-based approach speaks to a more fundamental point than its alternatives. It asks us to see individuals, not just as legal actors who have the capacity to file law suits, but as people who live in a physical space and develop very real connections to their surroundings.2"6 It asks courts, in short, to develop a sense of place. Although standing law relates to a technical if not arcane aspect of federal jurisdiction, it also provides the setting in which courts bless certain individual interests as legitimate and others as ethereal. It is time for the courts to recognize that we all have an interest in the environmental integrity of our surroundings, rather than treating the environment as presumptively irrelevant to our lives and requiring individualized proof to the contrary. 216. As Mark Sagoff says, A natural landscape becomes a place-"a shape that's in your head"-when it is cultivated, when it constrains human activity and is constrained by it, when it functions as a center of felt value because human needs, cultural and social as well as biological, are satisfied in it.... This contrasts entirely with the attitude of the outsider... for whom "[n]othing has a drift or relation; nothing has a history or a promise. Everything stands by itself, and comes and goes in its turn, like the shifting scenes of a show, which leaves the spectator where he was." Mark Sagoff, Settling America or The Concept of Place in Environmental Ethics, 12 J. ENERGY NAT. RES. & ENvTL. L. 349, 358 (1992) (quoting MARK TWAIN, LIFE ON THE MISSISSIPPI 38 (1911); JOHN HENRY NEWMAN, THE IDEA OF A UNIVERSITY 99 (Frank M. Turner ed., 1996)). Sagoff also presents an evocative quote from Alan Gussow: "'A place is a piece of the whole environment that has been claimed by feelings."' Id. at 359. 1558 HeinOnline -55 UCLA L. Rev. 1558 2007-2008