December 13, 2019. Professor Payne presented a paper in Germany at the University of Wurzburg. She argues that in the context of a multi-disciplinary exploration of the constitution of value by law, the environment has been analyzed as property, as something that can be dissected into ecosystem services which can then be monetized, and as a complex system with existential implications for humanity. In the case of forced exchanges, notably chronic or accidental environmental damage, the monetary value emphasized by the first two approaches is inappropriate. Instead, law should (and often does) require replacement of the functional value of the damaged environment.