safe, clean, healthy and sustainable environment.” 27 Framework Principle 11 is “States should establish and maintain substantive environmental standards that are non-discriminatory, nonretrogressive, and otherwise respect, protect, and fulfill human rights.” These measures should be preventive, precautionary, and consistent with all relevant international environmental, health, and safety standards. 32. Framework Principle 12 requires States to “ensure the effective enforcement of their environmental standards against public and private actors.” Clearly these principles (11 and 12) apply in the context of climate change, requiring States to establish, implement, and enforce effective laws and policies to reduce greenhouse gas emissions. The Climate Change and Human Rights Jurisprudence of International Courts The European Court of Human Rights 33. The European Court of Human Rights (ECtHR) has issued many decisions involving the right to life (Article 2 of the European Convention on Human Rights).28 While the ECtHR has not dealt specifically with climate change, the other cases involving environmental risks are analogous. 34. The case law is clear that the State has a positive obligation to protect the lives of citizens within its jurisdiction under Article 2 of the ECHR. This obligation applies to both public and private activities that endanger the right to life. If the government knows that there is a real and imminent environmental threat, the State must take precautionary measures to prevent infringement as far as possible. 35. A leading precedent is Oneryildiz, a case in which at least 26 people died in an explosion at a municipal landfill site, with evidence that Turkish governments knew for years about the serious danger of such an event. In its judgment, the Court stated, “The positive obligation to take all appropriate steps to safeguard life for the purposes of Article 2 entails above all a primary duty on the State to put in place a legislative and administrative framework designed to provide effective deterrence against threats to the right to life.” 29 36. A similar case, Budayeva, arose after mudslides in the Caucasus killed several inhabitants of the town of Tyrnauz. The Government of Russia did not cause the mudslides, but the Court held that it still had a responsibility to take appropriate steps to safeguard the lives of those within its jurisdiction. Above all, the European Court stated, Governments must adopt legal frameworks designed to effectively deter threats to the right to life from natural disasters as well as dangerous human activities.30 The Inter-American Court of Human Rights 37. In its 2017 Advisory Opinion, the Inter-American Court of Human Rights (IACHR) 27 J. Knox, Special Rapporteur on Human Rights and Environment. 2018. “Framework Principles on Human Rights and the Environment: The main human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment.” UN Doc. A/HRC/37/59. 28 See, among other examples, Öneryildiz/Turkey (ECtHR 30 November 2004, no. 48939/99), Budayeva et al./Russia (ECtHR 20 March 2008, nos. 15339/02, 21166/02, 20058/02, 11673/02 and 15343/02), and Fadeyeva/ Russia (ECtHR 9 June 2005, no. 55723/00). 29 Öneryildiz/Turkey (ECtHR 30 November 2004, no. 48939/99), para. 89. 30 Budayeva and others v. Russia, application. No. 15339/02 (2008). European Court of Human Rights. 
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