68 261. The third guarantee is the carrying out of a prior social and environmental impact 345 assessment by “independent and technically capable entities, with the State’s supervision.” The ultimate purpose of social and environmental impact studies is to “preserve, protect and guarantee the special relationship” of the indigenous peoples with their territories and to guarantee their subsistence as 346 peoples. For the Inter-American Court, Article 21 of the American Convention, in conjunction with Article 1.1, is violated when the State does not conduct or supervise environmental and social 347 assessments prior to the granting of concessions. It has also determined that environmental and social 348 impact studies must be conducted prior to approval of the respective plans, and it requires States to 349 allow indigenous peoples to take part in those prior social and environmental impact studies. In general terms, social and environmental impact assessments “must respect the traditions and culture [of the 350 indigenous or tribal] people concerned,” and their findings must be shared with the communities so that they can make an informed decision. 262. In the instant case, the IACHR has deemed it proven that the Garífuna Community of Triunfo de la Cruz has possessed its ancestral territory ancestrally, a circumstance that was acknowledged by the State when it granted full ownership titles to at least part of this territory, and during this process. The IACHR further notes, based on the proven facts, that a series of decisions have been taken regarding the territory historically occupied by the Garífuna Community which affected or restricted its collective property right. Those measures have to do specifically with planning and execution of tourism projects and mega projects; with the creation of a protected area in part of the ancestral territory; and sales of community land. In none of these cases did the State demonstrate to the IACHR that it had fulfilled the aforementioned minimum requirements established by the inter-American system. 263. Indeed, with respect to the “Club Marbella” tourism project, the IACHR was not informed of any prior, free, and informed consultation process having been carried out with the Community, in accordance with its own customs and traditions. Rather, it has been considered proven that the Community repeatedly opposed the surrender of its ancestral lands to IDETRISA and has brought numerous actions to recover them. Likewise, with respect to the planning and execution of the “Los Micos Beach & Golf Resort,” as we ascertained above, the State asserted that the area’s tourism development master plan was “discussed with and agreed to by the principle stakeholders in the area,” including the Triunfo de la Cruz Community; that it was agreed to give the Garífuna Communities a 7% share in the project, while the Community Councils would be represented as partners in the project; and that the EIA “went through a [series] of consultations, reviews, and environmental audits which meant that the EIA situation of human Rights and fundamental freedoms of indigenous people, Rodolfo Stavenhagen, submitted in accordance with Commission resolution 2001/65 (Fifty-ninth session), United Nations Doc. E/CN.4/2003/90, January 21, 2003, paragraph 66. 345 I/A Court H.R. Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007. Series C No. 172, paragraph 129. I/A Court H.R. Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and Reparations. Judgment of June 27, 2012. Series C No. 245. paragraph 205. 346 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 40. IACHR, Access to Justice and Social Inclusion: The Road Towards Strengthening Democracy In Bolivia. Doc. OEA/Ser.L/V/II, Doc. 34, June 28, 2007, paragraph 254. 347 I/A Court H.R. Case of the Saramaka People v. Suriname. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2007. Series C No. 172, paragraph 154. 348 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 41. I/A Court H.R. Case of the Kichwa Indigenous People of Sarayaku v. Ecuador. Merits and Reparations. Judgment of June 27, 2012. Series C No. 245. paragraph 205206. 349 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 133; I/A Court H.R, Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 16. 350 I/A Court H.R. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 12, 2008 Series C No. 185, paragraph 41.