inhabit. Specific development projects in these regions shall also be designed to promote such improvement. 3. Governments shall ensure that, where appropriate, studies are carried 0111 in cooperation with the peoples concerned to assess the social, spiritual, cultural anil environmental impact that planned development activities may have on them. The results of such studies shall be considered as a fundamental criterion for the implementation of such activities. 4. Governments shall take measures, in co-operation with the peoples concerned, to protect arid preserve the environment iii the territories they inhabit. 210. All these texts and declarations recognise the importance of a healthy environment, as part of economic and social rights, on the understanding that the environment affects the quality of life and the safety of the individual. 211. In the Communication Sorfinl and Economic Rights Action Centre (SERAC) and Centre for Economic and Social Rights (CESR) p Nigeria, the Commission stated that the right to a healthy environment imposes obligations on States to take reasonable and degradation, other to measures promote to prevent environmental pollution and ecological conservation and to ensure environmentally sustainable development and use of natural resources" . In its 2012 Resolution 224 on Natural Resources Governance in the run-up to the Rio+20 Conference on Sustainable Development, the Commission had already considered that the State has the primary responsibility to preserve and protect natural resources, together with and in the interest of the people"1. 212. Thus, for example, in activities related to exploration, extraction, toxic waste management, exploitation and governance of natural resources, States are called upon to ensure that independent social and human impact assessments are carried out, in order to guarantee, inter alia, indigenous and customary rights, and environmental impact assessments92. 213. The Commission therefore considers that in the implementation of its activities, the State must take into account the specificity of the indigenous population in order not to create an unfavourable environment for their fulfillment as human beings. As with all other human rights, States have an obligation to respect, protect and fulfil. In the present case, the Congolese State, 90 Communication 155/96 - op if., para 52. 91 Resolution 224 on a Human Rights-Based Approach to Natural Resources Governance ACHPR/Res.224(LI)2012 92 Resolution 224 on z H,urJ}éln.Rights.Based Approach to Natural Resources Governance ACHPR/Res.224(Ll)20 \€"` -T p. a I +.. I ! 45 8 J ' l. ,ii \; I , Q. \ . » Q . ,r . e