to Callicott's elaboration of the Aldo Leopold land ethic, the land ethic (and, by implication, Callicott's own non-anthropocentric, holistic environmental ethic to the extent that it may differ from Leopold's) has been subject to the charge of “ecofascism,” notably leveled by Tom Regan. If members of overpopulous species, such as deer, ought to be “culled” or “harvested,” in the name of preserving the integrity, stability, and beauty of the biotic community, and if staggeringly overpopulous Homo sapiens is also but “a plain member and citizen” of the biotic community, then why should culling and harvesting humans be any less obligatory? In “The Conceptual Foundations of the Land Ethic,” Callicott replies that Leopold presented the land ethic as an “accretion” to our evolving complex set of ethics. In other words, the land ethic burdens us with additional moral obligations; it does not substitute for or replace our previously evolved moral obligations, among them the duty to respect the rights of our fellow human beings to life, liberty, and the pursuit of happiness. This reply led to another criticism: that Callicott provides no “second-order principles” to prioritize duties to fellow humans and those to the biotic community when they conflict. In response, Callicott offered two second-order principles as a framework to adjudicate between conflicting first-order duties: 1) “obligations generated by membership in more venerable and intimate communities take precedence over those generated in more recently emerged and impersonal communities”; 2) “stronger interests take precedence over duties generated by weaker interests.” Because our various human community memberships are both more venerable and intimate and because human interests in enjoying rights to life, liberty, and the pursuit of happiness are very strong, Callicott argues that our traditional obligations to individual fellow human beings trump our obligations to preserve the integrity, stability, and beauty of the biotic community — at least, he believes, when it comes to the prospect of culling members of the overpopulous Homo sapiens species. Additionally, Callicott has been criticized for espousing an overbearing and impolitic monism in environmental ethics. He does not reject pluralism in environmental ethics outright; he only rejects theoretical pluralism, not interpersonal pluralism or normative pluralism. Callicott claims that philosophers and laypersons should not adopt one theory, say utilitarianism, for one purpose or in one context and another theory, say Kantian deontology, for another purpose or in another context (this would be theoretical pluralism). Such theories are mutually