A/77/290 in the United States in 2020, with a resulting contribution of $28.6 billion to the domestic economy. 91 73. Examples of violations of cultural rights and the right to development through conservation efforts are numerous. Conservation efforts by the Government of Kenya in the Mau Forest required the eviction of members of the Ogiek community, who successfully challenged the State before the African Court on Human and Peoples’ Rights. Among other findings, the Court affirmed that the eviction violated the Ogiek community’s right to economic, social and cultural development. 92 In the United Republic of Tanzania, tens of thousands of indigenous Maasai are reportedly at risk of eviction in the Ngorongoro Conservation Area, a UNESCO World Heritage site. 93 74. In the case of protected areas, donors routinely emphasize the important economic and social development projects instituted in nearby villages and the purported benefits that flow to displaced communities. These benefits may take the form of improved infrastructure, the building of schools, microcredit programmes and small-scale agricultural initiatives, among others. There is a lack of recognition that these same communities are entitled to their right to cultural development, which can only be realized through their access to their lands, territories and resources. 75. Renewable energy initiatives also pose significant risks for cultural rights. Wind, solar and hydropower projects often violate the land, resource and cultural rights of indigenous peoples and other local communities, who experience the negative effects of these projects but often receive few benefits. This experience explains the resistance to energy projects, in particular among indigenous peoples. 76. Domestic courts have shown a willingness to challenge development-related threats to cultural rights stemming from clean or renewable energy projects. In 2021, the Supreme Court of Norway found that a wind farm on the Fosen peninsula encroached on the grazing lands of the Sami people, and thus violated their right to enjoy their own culture under article 27 of the International Covenant on Civil and Political Rights. 94 77. As governments and businesses are increasingly pressured to transition to renewable energy, it is critical that these projects be community led or, at a minimum, designed in consultation with the communities that stand to be affected. A just transition requires that green energy projects prioritize the well -being of local communities and avoid initiatives that would have a negative impact on their cultural rights. C. The requirements of consultation and participation 78. Several States noted the positive effects of consultation and participation in development processes, including Lithuania, Spain, Ghana and Cambodia. In Cyprus, civil society actors are partners in the implementation of the Sustainable D evelopment __________________ 91 92 93 94 22-12659 www.nps.gov/orgs/1207/vse2020.htm. African Court on Human and Peoples’ Rights, African Commission on Human and Peoples’ Rights v. Kenya, Application No. 006/2012, Judgment, 26 May 2017, paras. 207–211. See allegation letter AL TZA 3/2021. Supreme Court of Norway, Appeal against Frostating Court of Appeals’ reappraisal of 8 June 2020, case Nos. 20-143891SIV-HRET, 20-143892SIV-HRET and 20-143893SIV-HRET, Judgment, 11 October 2021. Available at www.domstol.no/globalassets/upload/hret/decisions-inenglish-translation/hr-2021-1975-s.pdf. 19/24