federal government is constantly adopting measures to ensure that the members of those communities enjoy their human rights, especially their economic, cultural and social rights. Through the “Agência Espacial Brasileira” (AEB – Brazilian Space Agency), “INFRAERO” (Aeroportos Brasileiros) and other State agencies, the State has taken alleviative measures to benefit the local communities, such as payment of compensation, improvement and revitalization of the “agrovilas” infrastructure, sustainable development of the populations affected by the CLA’s establishment, and titling of land and homes of 312 families moved to “agrovilas” as a result of the construction of the CLA facilities. 31. Brazil’s Federal Government established a special program in the 2004-2007 “Pluriannual Plan” for development of the remaining quilombo communities, spelling out responsibilities and deadlines for execution. Brazil’s “Quilombo Program” is a combination of measures by various areas of government, all targeting the sustainable development of the quilombo communities, which is tailored to their historical and modern-day distinguishing traits. 32. The Brazilian State reports that starting in 1998, the “Fundação Cultural Palmares” (FCP – Palmares Cultural Foundation)[11] 11 stepped up its efforts in the Alcântara area, partnering with a number of Maranhão state and federal government agencies. The FCP took the initiative of establishing a dialogue with Alcântara’s remaining quilombo communities, their representative entities, support organizations and religious leaders. The State is of the view that while the process of legalizing the communities title to the land has not yet been concluded, the FCP is working hard to complete the work and deed them the land. 33. The Brazilian State therefore contends that it unambiguously adheres to the international consensus as to the indivisibility and interdependence of all human rights, as stated in the 1993 “Vienna Declaration and Program of Action”. However, it explains, the so-called second-generation rights are programmatic aspirations and their realization, especially in a country like Brazil with pronounced regional differences, will necessarily be gradual. 34. The State argues that the public interest purpose of the “Alcântara Launch Center” did not change when Brazil and its technological partners entered into bilateral agreements for commercial exploitation of this station, including the “Agreement on Technological Safeguards” that the Brazilian Government concluded with the United States Government on April 18, 2000. It contends that the social purpose of the CLA was kept entirely intact, as the social, economic and technological development objectives established in the legal documents creating the rocket launch center, and the complete Brazilian space mission were maintained and updated. The State’s position is that the agreement between the Brazilian and United States governments did not cause any deviation from the CLA’s original object and purpose. 35. As for the rule requiring that internal remedies be pursued and exhausted first, the State asserts that the Commission must declare the petition inadmissible on the grounds of a failure to comply with the requirement set forth in Article 46.1.a of the American Convention. It adds that the exception on the grounds of an unwarranted delay in rendering a final judgment under the domestic remedies, provided for in Article 46.2.c, does not apply either. 36. The State points out that the cases prosecuted on the subject are as follows: (a) a Public Civil Action brought by the Federal Public Prosecutor’s Office, [12] 11 The foundation responsible for identifying and issuing title to remaining quilombolo communities pursuant to Transitory 68 of the Constitution the land of the 6

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