 Alternative formulations are possible, however. A basic environmental human right can be understood as requiring maintenance and restoration of an environment that is safe for human life and health. Many countries have environmental rights of this sort in their constitutional bills of rights (Hayward 2005). And the European Union’s Bill of Rights, the  Charter of Fundamental Rights of the European Union,  includes in Article 37 an environmental protection norm: “A high level of environmental protection and the improvement of the quality of the environment must be integrated into the policies of the Union and ensured in accordance with the principle of sustainable development.” 