The Conservation Article is comprised in part of a provision that stems from the 1902 Constitution (section 3, regarding natural oyster beds), in part of provisions that originated in the 1971 Constitution (sections 1 and 2, regarding natural resources and historical sites), and in still another part of a provision approved by voters in 2000 (section 4, regarding the right to hunt, fish, and harvest game). In providing for a separate Conservation Article, drafters of the 1971 Constitution were taking a path followed by a growing number of states in the last four decades. However, in declaring in this article that it shall be the policy of the state to protect its natural resources, Virginia constitution makers followed a particular approach, which differs from that of states whose constitutional provisions guarantee a right to a clean and healthful environment.
SITES OF THE COMMONWEALTH
To the end that the people have clean air, pure water, and the use and enjoy-
ment for recreation of adequate public lands, waters, and other natural
resources, it shall be the policy of the Commonwealth to conserve, develop,
and utilize its natural resources, its public lands, and its historical sites and
buildings. Further, it shall be the Commonwealth's policy to protect its atmo-
sphere, lands, and waters from pollution, impairment, or destruction, for the
benefit, enjoyment, and general welfare of the people of the Commonwealth.
This section first appeared in the 1971 Constitution, and, together with the next section, has been referenced in various environmental-protection statutes enacted