A/HRC/43/54 conversation on the option of recognizing the right to a healthy environment through a United Nations resolution because it appeared to be the most timely, pragmatic and effective way to move forward. Global recognition by the United Nations would serve as a catalyst for the 37 States that do not yet legally recognize this right and would also accelerate action to implement the right in all States. Some participants highlighted the recognition of the right as a way to overcome today’s compartmentalized approach to environmental and human rights issues by shifting to a systematic and holistic approach. 64. The Human Rights Council has come a long way since 2012 on the issue of human rights relating to a safe, clean, healthy and sustainable environment. Six years of work by the previous Special Rapporteur, culminating in the landmark framework principles on human rights and the environment, provide a clear and strong foundation. A series of Council resolutions have recognized the interlinkages between human rights and the environment with increasing clarity and precision. All resolutions on human rights and the environment since 2011 have been adopted by consensus (see Council resolutions 19/10, 25/21, 28/11, 31/8, 34/20 and 37/8). 65. Some participants expressed concerns about the potential failure to gain consensus on a resolution to recognize the right to a healthy environment from the Human Rights Council or from the General Assembly. The ideal outcome would certainly be a consensus resolution, as this would foster effective implementation. Participants generally agreed that consensus was optimal but not necessary, pointing to resolutions on the recognition of the rights to water and sanitation as a relatively recent example. When one such resolution came to a vote in the General Assembly in 2010, 122 States voted in favour, none voted against, and 41 States abstained (resolution 64/292). Several months later, the Human Rights Council passed a resolution on the same topic without a vote (resolution 15/9), and future resolutions on the rights to water and sanitation at the General Assembly were adopted by consensus (such as resolution 68/157). 66. Some participants noted that the adoption by consensus in 2019 of Human Rights Council resolution 40/11 on environmental human rights defenders, one of the most politically sensitive issues relating to the environment, was an encouraging sign. The right to a healthy environment does not appear to be a controversial right in the same way as other rights have been. As noted earlier, more than 150 States have explicitly recognized the right to a healthy environment in law through their constitutions, national legislation and regional agreements. This figure includes more than 100 States where the right enjoys constitutional protection, more than 100 States where it is included in environmental legislation and more than 125 States that have ratified regional treaties. Participants observed that it would be difficult for States to justify their opposition to recognizing the right to a healthy environment in a United Nations resolution when they were already legally bound to respect, protect and fulfil the right at the national level through commitments entrenched in constitutions, legislation and/or regional treaties. 67. Some participants acknowledged that the recognition of the human right to a healthy environment had implications for States’ obligations. These obligations were clearly articulated in the framework principles on human rights and the environment developed by the previous Special Rapporteur. The non-binding nature of United Nations resolutions and the principle of progressive realization were also a topic of extensive discussion. 68. Another topic of discussion was the ongoing process relating to the proposed Global Pact for the Environment, an initiative to create a globally binding treaty that articulates a broad range of fundamental principles of environmental law, including the right to a healthy environment. Participants generally felt that the Global Pact was an ambitious longterm initiative, in light of the time it has taken to complete negotiations on other multilateral environmental conventions. A United Nations resolution on the right to a healthy environment was viewed as not only consistent with the Global Pact but also supportive of it. 69. The role of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment in contributing to the recognition of the right to a healthy environment was discussed. Participants encouraged the current Special Rapporteur to continue to build on the work of the first Special 16