A/HRC/28/61 indigenous titles. SUHAKAM decided to address the root causes of the issues comprehensively by taking cognizance of the experiences of indigenous peoples throughout the country. Its National Inquiry resulted in a final report published in April 2013, with detailed findings and 18 recommendations. 67. Some States have officials dedicated to protecting constitutional rights, which provide another avenue for ensuring access to remedies for environmental harm. For example, Brazil’s Ministerio Publico, or public prosecutor, has broad powers to enforce constitutional rights, including the constitutional right to an ecologically balanced environment. The Ministerio Publico has been very active in promoting environmental protection, bringing more than 4,000 environmental cases in the state of Sao Paulo alone. 68. A number of States have ombudspersons who have taken an active role in environmental protection. For example, much of the work of the Costa Rican ombudsperson in recent years has concerned environmental issues. In 2011, about 10 per cent of the more than 3,000 cases received by the office of the ombudsperson concerned the right to a healthy environment. Similarly, since 2013, the Croatian ombudsperson has received 20 complaints relating to environmental protection and another 19 relating to noise pollution. In Portugal, the office of the ombudsperson has also acted on complaints relating to environmental protection, as well as acting on its own initiative, including with respect to illegal construction in a national park. 69. A pathbreaking development was the establishment in 2007 of Hungary’s ombudsperson for future generations. The ombudsperson has the authority to initiate or participate in investigations upon receiving complaints, to submit petitions to the constitutional court, and to initiate intervention in public administrative court cases regarding environmental protection. 70. At the regional level, human rights commissions and courts have been in the forefront of bringing human rights norms to bear on environmental issues. The African Commission on Human and Peoples’ Rights, the Court of Justice of the Economic Community of West African States, the European Court of Human Rights, the InterAmerican Commission on Human Rights and the Inter-American Court of Human Rights have all considered complaints of human rights violations involving environmental harm, and together are developing a detailed jurisprudence on environmental human rights law. 71. Another good practice is the inclusion in regional environmental agreements of procedures that allow members of the public to raise claims for independent investigation and reporting. For example, the Submissions on Enforcement Matters process established by the North American Agreement on Environmental Cooperation allows a resident of any of the three North American countries to file a claim that one of the States is failing to enforce its domestic environmental law. Although the Commission cannot issue binding decisions, its secretariat can investigate the claim and issue a public report. This practice has also been adopted in some bilateral and regional trade agreements between the United States of America and other countries. Similarly, the Aarhus Convention establishes a Compliance Committee with the authority to review the compliance of parties with their obligations under the Convention, including on the basis of communications by members of the public. The Committee can issue reports and make non-binding recommendations. F. Substantive obligations 72. In addition to the procedural obligations described above, States have substantive obligations to adopt and implement legal frameworks to protect against environmental harm that may interfere with the enjoyment of human rights (A/HRC/25/53, para. 46). In an important sense, all environmental laws that set stringent standards for air quality, water 14