the right to life itself. It is scarcely necessary to elaborate on this, as damage to the environment can impair and undermine all the human rights spoken of in the Universal Declaration and other human rights instruments While, therefore, all peoples have the right to initiate development projects and enjoy their benefits, there is likewise a duty to ensure that those projects do not significantly damage the environment.” 44 68. Although not every violation of environmental law results per se in a violation of a decent life and personal integrity, certain actions that are contrary to environmental law and whose specific consequences may have a serious impact on the habitat of human beings, may be considered as acts that prevent the enjoyment of the right to a decent life and to personal integrity, as well as of other human rights recognized in the Pact. Consequently, an action that is not fully adapted to the rules of environmental law may, owing to its nature, lead to a violation of human rights; specifically, if this action has an impact on the environment that is so significant that it limits or prevents the effective enjoyment of the human rights recognized in the Pact of San José. 69. In this context, the specificity of the norms of environmental law is important not only to provide content to the obligations of the States Parties under the Pact, but also, in general, to ensure a greater effectiveness to the protection of human rights, in accordance with the specific characteristics of our times, and thus reinforce the Inter-American system. 70. Furthermore, it should be underscored that international human rights law regularly refers to the principles and norms of international environmental law. For example, the European Court of Human Rights has frequently referred to the principles and standards of international environmental law. 45 The Inter-American Commission has also recognized the need to interpret human rights norms “with due attention to other pertinent norms of international law applicable to the Member States against which complaints of human violations have been duly lodged.” 46 Similarly, in the Coard case, the Commission stated that “it would not be congruent with the general principles of law if the Commission founded and exercised its Charter-based mandated, without taking into account other international obligations of the Member States that could be relevant.” 47 71. Moreover, in its “Report on the situation of human rights in Ecuador,” the Commission cited the following international agreements supported by Ecuador when referring to the crucial relationship between the survival of the human being and the environment: the Additional Protocol to the American Convention on Human Rights in the Area of Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights and the International 44 I.C.J., case concerning the Gabčíkovo-Nagymaros Project, judgment of September 25, 1997, Rev. 1997, pp 91-92. 45 Council of Europe, Manual on Human Rights and the Environment, Council of Europe Publishing, ed. 2012, p. 149 and ff. 46 IACHR, Case of Lorenzo Enrique Copello Castillo et al. v. Cuba, merits, October 21, 2006, para. 50. 47 IACHR, Case of Coard v. United States, Report No. 109/99, Case No. 10,951, September 29, 1999, para. 40. 60

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