Amicus Curiae Brief presented by ClientEarth 21 November 2016 balance between environmental protection and other societal interests, such as economic development.36 46. While human rights treaties do not bind private parties directly, they have consistently been interpreted to require States to take steps to protect these rights from private conduct that interferes with their enjoyment.37 A State may violate its obligations based on its own actions, or through a failure to protect its citizens from the acts of a third party. This principle has been confirmed by several regional human rights bodies, including the European Court of Human Rights (ECHR). 47. The ECHR has found that States have violated their human rights obligations with respect to environmental harm through failures to follow environmental standards, with consequent impacts on human rights.38 48. The Philippines recognises that human rights obligations require States to protect their citizens from harmful climate change, and has advocated in international forums for the strengthening of this obligation. In 2012, the Philippines signed the Geneva Pledge for human rights in climate change, a voluntary pledge which reiterates the importance of addressing the human rights implications of climate change and emphasizes that human rights should inform climate responses. The pledge has now been signed by 32 nations, and states: 36 See note 16 at 222. See note 16 at 223. 38 Lopez Ostra v. Spain (1994) 20 EHRR 277. 37 26