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In contrast with the federal Constitution, seven state constitutions have provisions that explicitly provide a right to a clean and healthy environment, although the language in these Environmental Rights Amendments (ERAs) varies from state to state.4 New Yorks, for example, states that [e]ach person shall have a right to clean air and water, and to a healthful environment.5 Pennsylvanias ERA,6 among the earliest to be adopted and the most-cited, has been a source of litigation related to the state legislatures enactment of oil and gas laws that were found to have violated the states trust responsibility.7 Montanas ERA was central to Held v

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