(~C··r\ACH PR " ~oo..tW ;[ African Commission on Human and Peoples' Biqhts Human Rights our Collective Responsibility " offered access to and are able to use the new irrigation channels, these are likely to be far less sustainable. 108. With regard to the Kuraz, the Complainants Submitted that the wholesale conversion of the Complainants' territory to cultivate sugar cane has created an unsatisfactory envirorunent for pastoralists as the plantations have made it virtually impossible for them to pursue their customary way of life. 109. The Complainants submitted that if the Respondent insists that it had due regard to the adverse impacts of the Gibe III and Kuraz on the rights of the Lower Omo peoples, then it must prove through documentary evidence that it assessed the impacts that the Gibe III and Kuraz were likely to have on the Complainants before it decided to embark on these Projects. And that failing which, the Commission will be entitled to make an inference that it acted in violation of the provisions of the African Charter. 110. On the basis of the foregoing, the Complainants prayed the Commission to urge the Respondent to: (1) conduct independent investigations into the effect of Gibe III and Kuraz on the human rights, health and means of subsistence of the Complainants. (2) in the light of the data generated by this communication, make an objective appraisal whether these projects can operate without endangering the lives or livelihoods of the Complainants; and if so, develop a detailed "livelihood development plan" for this purpose. (3) provide all information collated under (1)and (2)to the Complainants to enable them to give their free and informed consent to both projects. 111. The Complainants also prayed for the Commission to urge the Respondent to suspend further work on both the Gibe III and Kuraz and any further villagization of the Complainants while these steps are being undertaken before it is too late. B. Respondent's submissions 112. The arguments below are the submissions of the Respondent State, having regard to their written submissions on the merits dated 27th November 2015, the response to the Complainants' additional observations dated 6th June 2016, and the latest information update information on the projects, together . J e \-IUMAty bundles of documentary evidence respectively attached to th .c.;,"(fr&~ ~lAl1S..o "'<7' e. before the Commission. ~c.;, <:> o~ ~ , 0 I" <fl.• '(') ;z ~ 23 n https:Jachpr.au.inVO 0 a