A/HRC/6/3 page 25 62. Beyond the clear basic principle that safe drinking water for personal and domestic uses should be given precedence over other water uses, questions remain regarding the prioritization between various kinds of water use, particularly in situations of water scarcity. Once a sufficient amount of safe drinking water to prevent disease has been secured for all, allocation of water among various uses - water for personal and domestic uses beyond this sufficient amount, water to produce food, water to sustain livelihoods, or water to ensure environmental hygiene - remains unclear. CESCR general comment No. 15 notes that priority in the allocation of water should also be given to water resources to prevent starvation and disease and that attention should be given to ensuring that disadvantaged and marginalized farmers have equitable access to water and water management systems. The Human Rights Council may wish to clarify obligations in this regard. G. Human rights obligations in the context of trade and investment agreements 63. Submissions received during the consultation process highlighted some concerns regarding the relationship between the obligations of States under bilateral investment treaties and their human rights obligations in relation to access to safe drinking water and sanitation. Some of the current proceedings before the International Centre for the Settlement of Investment Disputes (ICSID) opposing private water companies to States, draw attention to the potential impact that obligations arising from bilateral investment treaties can have on the duty of States to regulate companies in the context of private provision of water or sanitation services. It remains unclear whether and how the obligations of Governments under international human rights instruments will be taken into account in ICSID judgements.77 64. While the High Commissioner has already explored aspects of this issue - including in relation to access to safe drinking water - and concluded, inter alia, that the duty of Governments should be guaranteed, this research would benefit from further analysis.78 VI. CONCLUSIONS AND RECOMMENDATIONS 65. Access to safe drinking water and sanitation is an issue of great importance to the international community. The considerable number of submissions received from Governments, intergovernmental organizations, national human rights institutions and civil society are evidence not only of the interest in this issue, but also of the growing recognition that access to safe drinking water and sanitation must be addressed within a 77 For the first time an ICSID tribunal agreed to receive amicus curiae briefs from civil society organizations in a pending case opposing private water providers to Argentina, noting that the circumstances of the case raised issues of public interest as “those systems provide basic public services to millions of people and as a result may give rise to a variety of complex public and international law questions, including human rights considerations”. See ICSID cases No. ARB/03/19 and ARB/03/17. 78 Liberalization of trade in services and human rights: report of the High Commissioner (E/CN.4/Sub.2/2002/9); Human rights, trade and investment: report of the High Commissioner (E/CN.4/Sub.2/2003/9).