The Environmental Rights Amendment to the Pennsylvania Constitution, Article I, Section 27, has become a feature of environmental litigation in our commonwealth over the nine years since a Pennsylvania Supreme Court plurality reanimated it in Robinson Township v. Public Utilities Commission, 83 A.3d 901 (Pa. 2013). In my February column I alluded to some analytical inconsistencies within the Pennsylvania appellate courts' post-Robinson opinions. This column seeks to sharpen up two large issues under the first sentence of Section 27, the one granting an environmental right. First, is that right substantive or procedural? Second, does the right apply to all environments, or just to "traditional environmental media?"