49 179. In what refers to the obligation to carry out environmental impact studies, Article 7(3) of Convention 169 of the ILO states that “[g]overnments shall ensure that, whenever appropriate, studies are carried out, in cooperation with the peoples concerned, to assess the social, spiritual, cultural, and environmental impact on them of planned development activities. The results of these studies shall be considered as fundamental criteria for the implementation of these activities.” Thus, the Court has previously established that the execution of those studies is one of the safeguards to ensure that the restrictions imposed on indigenous or tribal communities regarding the right to property do not entail a negation of the survival of their survival of the indigenous people as such. 187 180. Additionally, the Court has pointed out that the importance of these studies lies in the fact that they “serve to assess the possible damage or impact a proposed development or investment project may have on the property in question and on the community. [However, their] purpose is not only to have some objective measure of such possible impact on the land and the people, but also, […] ‘ensure that members of the […] people are aware of the possible risks, including environmental and health risks’,” so they may give their opinion on the project in question within an “informed and voluntary” consultation process. 188 Moreover, the Court has stated that the environmental impact studies must: conform to the relevant international standards and best practices in this sense, respect the traditions and culture of the indigenous and tribal peoples, and be completed prior to the granting of the concession or license, as one of the objectives for requiring such studies is that the State guarantee the Community’s right to be informed about all the proposed projects in their territory and to their effective participation in the process of granting concessions or licenses. 189 181. In this case, the State had to guarantee that no activity related with the realization of tourism projects such as the “Marbella” and “Playa Escondida” projects be carried out within the Community’s properties until independent, technically capable entities under the State’s supervision had completed a prior social and environmental impact study. In this sense, the Court points out that it was not proven that the impact study required regarding those projects was carried out. B.5.4. Conclusion 182. The Court has verified that an adequate and effective procedure to guarantee the right to consultation of the Community, through its own institutions and representatives was not carried out in any of the planning or execution of the “Marbella” and “Playa Escondida” tourism projects, the adoption of the Decree that defined the Punta Izopo protected area, and the approval of the Management Plan, with regard to the part that overlaps with the Community’s properties over which the State had issued a title deed in 1993. Therefore, this Court determines that the State has violated Article 21, in relation to Article 1(1) of the Convention for not having carried out a prior consultation process or an environmental impact study, nor ordering that, in the case in question the benefits of the mentioned projects be shared pursuant to international standards, in detriment of the Garífuna Community of Triunfo de la Cruz and its members. Cfr. Case of the Saramaka People v. Suriname, para. 129, and Case of the Kichwa Indigenous People of Sarayaku v. Ecuador, para. 157. 187 Cfr. 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, para. 40. 188 Cfr. Case of the Saramaka People v. Suriname. Interpretation of the Judgment on Preliminary Objections, Merits, Reparations, and Costs, para. 41. 189