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HUMAN RIGHT TO WATER increase sanitation and water supply services to poor and marginalized groups, especially the rural populations who constitute eighty percent of those without access to improved water, was recognized by the creation of the World Health Organization's International Drinking Water Supply and Sanitation Decade (1981-1990), the United Nations Millennium Conference in 2000,8 the Johannesburg Summit in 2002,1 and the Third World Water Forum in 2003.'Although international governance regimes have begun to recognize a right to water as a means to achieve other human rights," they have not fully considered what such a right might mean in practice for developing countries.Eibe Riedel, the Rapporteur on Water for the United Nations Committee on Economic, Cultural and Social Rights of the United Nations Economic and Social Council (ECOSOC), acknowledged this when he noted that the INT'L CONE.ON POPULATION AND DEV., CAIRO, Ch. 2, princ.2, at 15, U.N. Doc.A/CONF.171/13/Rev.1,Sales No. E.95.XIII.18 (1994) ("[People] have the right to an adequate standard of living for themselves and their families, including adequate food, clothing, housing, water and sanitation.");Recommendation (2001) 14 of the Committee of Ministers to Member States on the European Charter on Water Resources, paras.5, 19,
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