A/HRC/25/53 50. Similarly, special rapporteurs have addressed the obligations of States in relation to environmental harm to human rights.44 The Special Rapporteur on the human right to safe drinking water and sanitation, for example, has stated (A/68/264, para. 48): To curb water pollution effectively, regulation must target all sectors and cover the whole country, giving priority to the elimination of the most urgent and serious challenges, which vary from country to country and within countries. They might stem from the use of pesticides and fertilizers in agriculture in rural areas, the nonconfinement and non-treatment of sludge and septage in densely populated urban areas, or from industrial wastewater in areas that experience sudden economic growth. States have to assess the situation at the micro level and prioritize addressing the most urgent challenges. 51. The Special Rapporteur on hazardous substances and wastes has issued a series of reports identifying obligations of States in relation to such substances. To take one example, a 2006 report on the human rights impact of the widespread exposure of individuals and communities to toxic chemicals in food and household goods (E/CN.4/2006/42, para. 45) states: The duties of States in this regard translate into obligations to take steps to regulate carefully the production, storage and use of hazardous chemicals in a way that prevents a level of exposure to hazardous chemicals which may result in human rights violations. States must also provide effective remedies and restitution to victims of those violations occurring as a result of exposure to hazardous chemicals. In other words, States must regulate the production and use of chemicals in a way which is consistent with the full spectrum of their obligations under international human rights law. 52. States have recognized the importance of incorporating human rights considerations into environmental laws. The Human Rights Council has affirmed that “human rights obligations and commitments have the potential to inform and strengthen international, regional and national policymaking in the area of environmental protection” and urged States “to take human rights into consideration when developing their environmental policies” (resolution 16/11). The Council, as well as the parties to the United Nations Framework Convention on Climate Change, has stated that States should, in all climate change-related actions, fully respect human rights (resolution 18/22; and FCCC/CP/2010/7/Add.1, decision 1/CP.16). In the universal periodic review process, many States have described the steps they have taken to create institutions and adopt policies and laws to address environmental protection.45 53. The obligation to protect human rights from environmental harm does not require the cessation of all activities that may cause any environmental degradation. The African Commission, for example, has made it clear that the African Charter does not require States to forego all oil development.46 The European Court has held that States have discretion to strike a balance between environmental protection and other issues of societal importance, such as economic development and the rights of others.47 But the balance cannot be unreasonable, or result in unjustified, foreseeable infringements of human rights. In the Ogoniland case, the African Commission cited the enormous environmental harm to the 44 45 46 47 14 See generally Report on special procedures, sect. III.B. Individual report on the General Assembly and the Human Rights Council, including the universal periodic review process, sect. IV.B.1. Ogoniland case, para. 54. Council of Europe, Manual, p. 20. See, for example, Hatton and others v. United Kingdom, No. 360022/97, 8 July 2003, para. 98.