v. adaptation obligations, requiring States to enact legal and institutional frameworks for protecting people against environmental harm interfering with the enjoyment of human rights.211 The OHCHR has found that, in relation to the human rights impacts of climate change, States’ human rights obligations mean that they must: a) Mitigation - act to limit anthropogenic emissions of greenhouse gases and protect natural carbon sinks (e.g. mitigate climate change), including through regulatory measures, in order to prevent to the greatest extent possible the current and future negative human rights impacts of climate change; b) Adaptation - ensure that appropriate adaptation measures are taken to protect and fulfil the rights of all persons, particularly those most endangered by the negative impacts of climate change such as those living in vulnerable areas (e.g. small islands, riparian and low-lying coastal zones, arid regions, and the Arctic); c) Accountability and Remedies - guarantee effective remedies for human rights violations; d) Business harms - States must take adequate measures to protect all persons from human rights harms caused by businesses; to ensure that their own activities, including activities conducted in partnership with the private sector or by companies under their control, respect and protect human rights; and where such harms do occur, to ensure effective remedies. 212 States have discretion to strike a balance between environmental protection and other legitimate societal interests. As noted by UN Special Rapporteur John Knox in his 2018 report, the environmental standard applied by a State “must not strike an unjustifiable or unreasonable balance between environmental protection and other social goals in light of its effects on the full enjoyment of human rights.”213 In assessing whether a balance is reasonable, national and international health standards may be particularly relevant, with a strong presumption against retrogressive measures. In addition to a general non-discrimination requirement, States owe specific obligations to members of groups particularly vulnerable to harm.214 211 See ClientEarth brief, at ¶ 44 (citing the substantive obligations of states in respect of climate change in UNEP HUMAN RIGHTS AND CLIMATE CHANGE, supra note 205, at 19). See also APF & GANHRI brief, at ¶ 27. 212 UNDERSTANDING HUMAN RIGHTS AND CLIMATE CHANGE, supra note 57 (cited in ClientEarth brief). This matter is also addressed earlier in this joint summary amicus brief in Section I on Jurisdiction, supra, as it is relevant to the Commission’s jurisdiction to conduct an inquiry. 213 Rep. of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment, ¶ 33(e), U.N. Doc. A/HRC/37/59 (Jan. 24, 2018), http://legal.un.org/docs/?symbol=A/HRC/37/59. 214 Rep. of the Independent Expert on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment, U.N. Doc. A/HRC/25/53, supra note 210, at ¶¶ 79-81 (cited in APF & GANHRI brief, at ¶¶ 30-31); see also Rep. of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment, A/HRC/37/59, supra note 213, at principles 14-15. 45