Criticizing the individualistic approach in general for failing to accommodate conservation concerns for ecological wholes, J. Baird Callicott (1980) has advocated a version of land-ethical holism which takes Leopold’s statement “A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise” to be the supreme deontological principle. In this theory, the earth’s biotic community per se is the sole locus of intrinsic value, whereas the value of its individual members is merely instrumental and dependent on their contribution to the “integrity, stability, and beauty” of the larger community. A straightforward implication of this version of the land ethic is that an individual member of the biotic community ought to be sacrificed whenever that is needed for the protection of the holistic good of the community. For instance, Callicott maintains that if culling a white-tailed deer is necessary for the protection of the holistic biotic good, then it is a land-ethical requirement to do so. But, to be consistent, the same point also applies to human individuals because they are also members of the biotic community. Not surprisingly, the misanthropy implied by Callicott’s land-ethical holism has been widely criticized and regarded as a reductio of the position (see Aiken (1984), Kheel (1985), Ferré (1996), and Shrader-Frechette (1996)). Tom Regan (1983, p.362), for example, has condemned the holistic land ethic’s disregard of the rights of the individual as “environmental fascism”. Under the pressure from the charge of ecofascism and misanthropy, Callicott (1989 Ch. 5, and 1999, Ch. 4) has later revised his position and now maintains that the biotic community (indeed, any community to which we belong) as well as its individual members (indeed, any individual who shares with us membership in some common community) all have intrinsic value. The controversy surrounding Callicott’s original position, however, has inspired efforts in environment ethics to investigate possibilities of attributing intrinsic value to ecological wholes, not just their individual constituent parts (see Lo 2001 for an overview and critique of Callicott’s changing position over the last two decades; also see Ouderkirk and Hill (eds.) 2002 for debates between Callicott and others concerning the metaethical and metaphysical foundations for the land ethic and also its historical antecedents). Following in Callicott’s footsteps, and inspired by Næss’s relational account of value, Warwick Fox in his most recent work has championed a theory of “responsive cohesion” which apparently gives supreme moral priority to the maintenance of ecosystems and the biophysical world (Fox 2007). It remains to be seen if this position will escape the charges of misanthropy and totalitarianism laid against earlier holistic and relational theories of value.