“…174 Douglas would have lauded this approach, as it mirrored his earlier advocacy of "Committees of Correspondence" to initiate local citizen action. 175 The themes of wilderness and sanctuary were mainstays of Douglas's judicial philosophy. He surely would have embraced the views of biologist and nature writer David George Haskell, who wrote that "because life is a network, there is no 'nature' or 'environment' separate and apart from humans.…”