60 programs initiated by the government were not gender-inclusive, recognizing only cisgender orientations.287 The lack of data on the impact of disasters caused by climate change on LGBTQIA+ people worldwide exacerbates their plight, making them “largely invisible in relief and development programs.”288 x. Right to Safe, Clean, Healthy and Sustainable Environment On 8 October 2021, during its forty-eighth session, the United Nations Human Rights Council adopted the resolution on the Human Right to a Safe, Clean, Healthy and Sustainable Environment. The resolution “recognizes the right to a safe, clean, healthy and sustainable environment as a human right that is important for the enjoyment of human rights.”289 This recognition is borne out, among others, of the acknowledgement of the the impact of climate change, the unsustainable management and use of natural resources, the pollution of air, land and water, the unsound management of chemicals and waste, the resulting loss of biodiversity and the decline in services provided by ecosystems interfere with the enjoyment of a safe, clean, healthy and sustainable environment, and that environmental damage has negative implications, both direct and indirect, for the effective enjoyment of all human rights.290 The recognition of this human right affirms the Filipinos’ constitutionallyguaranteed right to a balanced and healthful ecology in accord with the rhythm and harmony of nature.291 However, with climate change, this rhythm and harmony has been disrupted. Lowell Factor recounted how corals, once “big and colorful” and July 30, 2021). 287 Id. at 5. 288 Zoe Tabary, Women, LGBT People ‘Invisible’ Victims of Disasters–Experts, Thomson Reuters Foundation News, Mar. 8, 2018, available at https://news.trust.org/item/20180308114259-otaio/. 289 United Nations Human Rights Council, Draft Resolution: Promotion and Protection of All Human Rights, Civil, Political, Economic, Social and Cultural Rights, Including the Right to Development, A/HRC/48/L.23.1, available at https://undocs.org/a/hrc/48/l.23/rev.1. 290 Id. 291 Phil. Const. art. II, § 16.

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