73 rights from being violated by third parties, particularly businesses (nongrant or denial of subsidies or incentives to carbon-intensive industries, regulation of carbon footprints left not only by private and state-owned companies but also by consumers, and so on are examples of these programs); and 3. Repeal and modify discriminatory policies that target vulnerable groups. Finally, concerning vulnerable sectors, States have a general duty to consider additional protections and apply environmental laws without discrimination. These principles on the three categories of State obligations must govern all of States’ climate actions, including obligations related to mitigation, adaptation, finance, and loss and damage.359 The principles behind the three categories of State obligations are reflected in the Rio Declaration,360 which was adopted in 1992. The Rio Declaration consists of 27 principles defining the people’s right to development and the States’ obligation to protect the shared environment. Though non-binding by itself, the Declaration has been the source of standards to help guide States in fulfilling their obligations towards the environment. The principles in the declaration have been crystallized into a binding treaty, namely the Aarhus Convention.361 The European Union and 47 of the 50 European countries are parties to the convention, which is open to accession by non-EU States. Hence, the three categories of State obligations on the environment are not only obligatory to a good number of powerful States, but can also be binding on other States through the development of norms under customary international law.362 The United Nations High Commissioner for Human Rights363 also enumerates particular human rights obligations of States in the context of climate change. States have an obligation 359 Id. at 18. 360 Rio Declaration, supra note 242. 361 Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters, Depositary, Chapter XXVII-13, available at https://treaties.un.org/doc/ Publication/MTDSG/Volume%20II/Chapter%20XXVII/XXVII-13.en.pdf. 362 Sec. 102 of the Restatement of United States Foreign Relations provides that: “International agreements create law for the states parties thereto and may lead to the creation of customary international law when such agreements are intended for adherence by states generally and are in fact widely accepted.” 363 Relationship Between Climate Change and Human Rights Report, supra note 221.