A/HRC/42/47/Add.3 24. The Government’s response regarding the current Strategy did not make mention of the water and sanitation needs of Roma communities in Portugal, instead highlighting that the Strategy was designed and drafted in line with the European Union’s framework for Roma integration policies, which calls on governments to focus on “housing, healthcare, education and employment”, as well as promoting mediation, “valuing Roma history and culture”, and the “combatting of discrimination and gender equality”. It further stated that outcomes under the Strategy are monitored and used to adjust the process where necessary. 25. The National Roma Communities Integration Strategy is due to end in 2020, however currently no information is available regarding whether a new strategy is to be drawn up and, if so, what this will contain, although the Government’s response alludes to the fact that the results of the current Strategy will lead to recommendations, which will, in turn, be used to inform the Roma Integration Strategy in the future. 26. The Special Rapporteur urges the Government to acknowledge the suffering faced by Roma populations in Portugal with regards to water and sanitation and to ensure that this reality is comprehensively considered in its strategies for water and sanitation provision. If, as it clearly must be, the Integration Strategy is extended beyond 2020, he calls upon the Government to include within it dedicated analysis and recommendations regarding water and sanitation. Without doing so, and without acting upon such recommendations, the Government will continue to be in breach of its obligations under the human rights to water and sanitation in respect of Roma communities. PROGRESS NOT STARTED: The Special Rapporteur reiterates his recommendation to include reference to safe drinking water and sanitation in the National Roma Integration Strategy and urges the Government to ensure that the rights to water and sanitation for all Roma people in Portugal are respected, protected and fulfilled. G. Recommendation on regulatory actors RECOMMENDATION 7: “Urge the Water and Waste Services Regulation Authority (“ERSAR”) and the Water and Waste Services Authority for Azores to ensure that their policies, procedures and activities comply with the international human rights obligations of Portugal.” (A/HRC/36/45/Add.1, para. 82(r)) 27. Whilst noting that the regulatory framework for water and sanitation in Portugal represents a positive approach that can be utilised as a reference for regulatory activities in other States, Special Rapporteur highlighted the need for the Government to ensure that the operations, policies and procedures of ERSAR comply with Portugal’s international human rights obligations. In particular, he noted the need for a greater recognition of the normative content of affordability within ERSAR’s work, as the current indicator used to determine affordability looks at the average family expenditure related to the family income in each municipality. 28. The Government noted that “ERSAR has been one of the first regulators to accept the official recognition of water and sanitation as human rights and it has been working with International Organisations … [to produce] several documents on the implementation of these rights.” Furthermore, the Government has stated that ERSAR “has implemented several mechanisms in order to realize the human rights to water and sanitation … . Since 2005, ERSAR regularly assesses the quality of service provided by each operator through a set of indicators, which include access, affordability, and quality, among other (sic). ERSAR analyses and issues an opinion on every written complain made by users of these services. ERSAR issues each year an opinion on the retail tariffs of municipal services that comprises a review of topics such as affordability, cost recovery, sustainability, among other (sic).” 29. The Special Rapporteur thanks the Government for outlining the processes of ERSAR and how these seek to take into account the elements of the normative content of the human rights to water and sanitation. He reminds the Government, however, that simply approaching these principles in an a-la-carte manner does not amount to a consideration of 7