 Critics of this view allege that there is a very basic difficulty with the proportionality principle, which is that it is insensitive to the myriad ways in which people interact with place, which ought to be relevant to a theory of territorial justice. It relies on a homogeneous and undifferentiated view of resources as existing in the world, and thereby raising property and distributive justice questions. This treats ‘resources’ as equivalent to natural things which can be brought under an ownership relation. Both Kolers (2009) and Moore (2012, 2015) have argued that the concept of ‘resource’ does not refer to a natural kind, but contains an important relational element, such that something gets transformed from being part of the natural world to a resource by being viewed instrumentally and that this relational character is part of how we individuate resources and distinguish resources from things in the physical world that are not resources. This means that what counts as a resource is historically, culturally and individually variable. Something can be a resource for one person or one group, because instrumental to the satisfaction of his or her purposes or needs, but not a resource for someone else, because that person does not view the object instrumentally. For example, the Lakota Sioux believe that the Black Hills are sacred, which means that they don’t view them instrumentally. When in 1980, they won a U.S. Supreme Court award, compensating them for the unlawful taking of Sioux lands, they rejected the award: they didn’t want compensation; they wanted the mining stopped. This highlights the problem with the proportionality principle and common ownership: it is biased towards intensive uses relative to population. It wrongly assumes that we view all things in the natural world from the same instrumental perspective, such that the ideas of trade-offs, compensation and use-value are obviously applicable and neutral terms to use. What is needed, critics allege, is a set of principles to adjudicate territorial claims that better respect cultural variability with respect to land.