Independently of the Universal Declaration of the Rights of Mother Earth and the International Tribunal for the Rights of Nature, New Zealand created another facet of the emerging paradigm in two contrasting, but complimentary, ways. On May 24, 2015, Pope Francis, head of the Roman Catholic Church, issued his encyclical Laudato Si—Latin for "Praise Be to You", a line from the Canticle of the Sun, a famous hymn praising God for the handiwork of Nature, written by St. Francis of Assisi, who lived in 13th-century Italy. The Te Urewera Act has caught the attention of Rights of Nature activists in South America and North America, who are studying it closely to see how it might be applied in the United States and elsewhere, as Rights of Nature ordinances are gaining ground in American communities, especially those faced with hydraulic fracturing and its toxic by-products.