us. 9, GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONFLICT of the qualifier “direct” with regard to the incidental civilian harm), as well as the context and humanitarian purpose of the rule" Iris furthermore reflected in State practice.?* ‘The scope of the obligation to take into account the indirect effects of an attack, and the related question as to when an indirect effect is reasonably foreseeable, will depend on the facts of each case based on an assessment of information from all sources available at the relevant time,2”* and informed by past practices and empirical data.” For example, depending on how the attack is carried out, it may be foreseeable that an attack on a facility containing chemical substances may cause the release of such chemicals into the surrounding natural environment.” Depending on the circumstances, it may also be foreseeable that an attack expected to affect the electricity supply, for example by damaging a power plant, could disrupt the sewage or wastewater treatment systems that rely on electricity and, in turn, harm the quality of the water and soil by polluting them with untreated wastewater. In addition, as information regarding the long-term risks attendant to disruption of ecosystems increases, so too does the foreseeability of indirect effects, and assessments of excessiveness of incidental damage to the natural ‘environment must take such information into account >” ‘The UN Environment Assembly has noted that the long-term consequences of environmental degradation resulting from pollution caused by armed conflict “include, inter alia, the loss of biodiversity, the loss of crops o livestock, and lack of access to clean water and agricultural land, and the negative and sometimes irreversible impacts on ecosystem services and their impact on sustainable recovery, contributing to further forced displacement related to ‘environmental factors". These examples relate generally to the effects of armed conflict on the natural environment rather than the effects of attacks. However, to the extent that an attack could foreseeably result in direct or indirect effects such as these, they need to be taken into account when weighing the anticipated concrete and direct military advantage against the expected incidental damage. > See ICRC, Internationa humanitarian Law and the Challenges of Contemporary Armed Confit: Recomiting to Protection in Armed Confit on the oth Anniversary ofthe Geneva Conventions, pp. 8 and 68; TLA Study Group on the Conduet of Hostiitis in the 21st Century, “The conduct of hostilities and international humanitarian law: Challenges of 2st century warfate”, pp. 352-3543, ‘Schmittivibul (eds), Tallinn Manu, commentary on Rule 15, p. £72, para. 6; M. Sassll and L Cameron, "The protection of cvilan objects: Current state ofthe law and issues de lege ferenda” iN. Ronzitt and G. Venturini (es), The Law of Ar Warfare: Contemporary Issues, Eleven International, The Flague, 2006, p. 65; Glsel, "Relevant incidental harm forthe proportionality principle", in 1CRejCollege of Europe, Urban Warfare, Proceedings of 16th Bruges Colloquium, 15-16 October 2015, Cllegium, No, 46, Autumn 2016, pp. 125-127; I. Robinson and E. Noble, “Proportionality and precautions in attack: The reverberating effects of using explosive weapons in popilated areas", International Review ofthe Red Cros, Val. 98, No.1, Apll 2016, pp 121 ‘and Gillard, Preportonality inthe Conduct of Hostilties The Incidental Harm Side af the Assessment, pp. 18-19, patas 62-64. > Foran overview of relevant State practice, see L. Glsel (ed), The Principle of Propotionality nthe Rules Governing the Conduct of ‘sities under International Humanitarian Law, Report ofthe International Expert Meeting, Quebec, 2~23 June 2016, ICRC, Geneva, 2018, pp. 43-51. See aso Roblnson/Nohle, “Proportionalty and precautions in attack: The everberating effects of using ‘explosive weapons in populated areas", pp. 115-16, See fn. 45 above, ‘> For some ofthe parameters that can be taken into account when determining the scope ofthe obligation to take Into account the Indirect effects of an atack, sre Rebinson/Noble, “Proportionality and precautions in attack: The reverberating effects of ‘using explosive weapons in populated areas", pp. 117-131 2 For example, the bornbing of the Pantevo Industral complex and of a petroleum refinery in Novi Sad by NATO forces during. the war in Kosovo in 1999 led ta the release of some 80,000 tons of crude oil Into the soll and of many tons of other toxic substances: Hulme, War Torn Environment p 188. See also UNEF/United Nations Centre for Human Settlements (UNCHS), The Kosovo Confit: Contequences for the Enviarment& Human Settlements, UNEF/UNCHS, Nairobi, 1999, pp. 32=38. > Drocge/Tougas, “The protection of the natural environment in armed conflict: Existing rues and need for further legal protection”, p. 30. Foran example of environmental contamination due to electricity shortages during confit, see UNEP, Environmental Assessment ofthe Gaza Strip following the esclation of hostilities in December 2008~January 2009, UNEP, Nairobi, 98 the electricity supply collapsed, transfer [pumps ceased to function, resulting In sewage being diverted to the nearest avallabe lagoons, Including infiltration lagoons. Second, the limited treatment that had been taking place in sewage treatment plants also ceased due to clectrcity shortages. The eluent leaving sewage treatment plants to’be disposed of inthe sea or by infitration in the froundwater was therefore entirely untreated > proege/Tougas, “The protection ofthe natural environment In armed conflict: Existing rules and need or further legal protection", pp. 31~32. Furthermore, see para 124 ofthe present Guidelines regarding the "precautionary principle” of International environmental law and its relevance tothe obligation to take proper precautionary measures to prevent undue damage. Information regarding confict-related environmental damage is Increasingly avallable as methods develop for {documenting and monitoring this damage; sce eg. W. Zwl)nenburg et al, "Solving the jigsaw of conlit-related environmental intentional Law and oly fate (IL), Prtecton Oso, 201,09. 17-18 = UNE, Technica Note ~ Environmental hes i Arcos Rete rom St: Mosul a NEP Nao, 201, p. 6-9. "Seg United Sates Department ea, leper e Cnges one Conta ne Pe a as pend (on the Role of the Law of War", p. 637; and Schmitt, “Green war", p. 53. . “xo P58. the Natural Environment in Armed Conflict: An Empirical Study, LP, 553. 124. 125. 126. GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONFLICT Rule 8 - Precautions In the conduct of military operations, constant care must be taken to spare the civilian population, civilians and civilian objects, including the natural environment. All feasible precautions must be taken to avoid, and in any event to minimize, incidental loss of civilian life, injury to civilians and damage to civilian objects, including the natural environment. Commentary, ‘The principle of precautions, which is stated here with the addition of an express reference to the natural environment, has been established as a rule of custemary international law applicable in international and non- international armed conflicts with regard to any civilian object. The application of the general principle of precautions specifically to the natural environment is articulated in the second clause of Rule 44 of the ICRC Study. fon Customary Intemational Humanitarian Law." As noted above, on the basis of its civilian character, any part of the natural environment that is not a military objective must be protected against incidental damage. The principle of precautions in attack is codified more generally in Article 57 of the 1977 Additional Protocol 1. As noted in the ICRC Study on Customary International Humanitarian Law, there is practice to the effect that lack. of scientific certainty as to the effects on the environment of certain military operations does not absolve parties to a conflict from taking proper precautionary measures to prevent undue damage. As the potential effect on the environment will need to be assessed during the planning of an attack, the fact that there is bound to be some uncertainty as to its full ampact on the environment means that the “precautionary principle” trom unternational environmental law is of particular relevance to such an attack. The precautionary principle in environmental law haas been gaining increasing recognition. There is, furthermore, practice to the effect that this environmental law principle applies in armed conflict. The study therefore concluded that lack of scientific certainty as to the effects. fon the natural environment of certain military operations does not absolve a party to the conflict from taking, precautions. Constant care in the conduct of military operations ‘The principle of precautions encompasses @ general obligation to take constant care to spare civilian objects (including the natural environment) in the conduct of military operations.“ It operationalizes the obligation to employ methods or means of warfare with due regard to the protection and preservation of the natural environment, Which is addressed in Rule 1 of the present Guidelines." ‘The term “military operation” is broader than “attack” and should be understood to mean “any movements, manoeuvres and other activities whatsoever carried out by the armed forces with a view to combat”."® This is an important distinction, as it means that constant care must be taken in view of the impact of military operations on. the natural environment during, for example, troop movernents or the establishment of military bases, which do hot per se constitute “attacks”, but which can nevertheless cause significant incidental damage to the natural environment. 1 See Henckaerts/Doswald-Beck (eds), ICRC Study on Customery Internationa Humanitarian Law, Vol. 1, Rule 15 and commentary, p51: hps:/ihl-databases ire org/eustomary-thlfeng/docs/vi_tul_tulet5 and related practice. See ibid, second sentence of Rule £4 and commentary, pp. 147 and 149160: hitys://il-databases crc. org/customaty= wldocs/e1_rul_ruleas and related practice. ‘See bid, third sentence of Rule 4g and commentary pp. 147 ad 150: tps. /ihl-databases Jreorgicustomaty. Ahljengidocs/v1_rul_tuleag and related practice. The constant care obligation is set out In Article 57() of Additonal Protocol and in Henckaerts/Doswald-Beck (eds), ICRC Study on Customary international Humanitarian Law, Vol | first sentence of Rule 1, p. St: http://hl databases xc orpfeustomary-thleengidocs(v_ev_tules. ‘The due regard obligation is set out in Henckaerts/Doswald-Beck (eds) ICR Study on Customary International Humanitarian Law, Vol. 1 fist sentence of Rule 44, p. 147: bttps:/ihl-databases.icrcorp/customary-ihlfeng/docs/v1_rul_rule4t. I is restated and discussed in Rule xf the present Guidelines; see the commentary onthe latter regarding the Interaction between these two rules. Sandoz/Swinarskl/Zimmermann (eds), Commentary en the Additional Protcot,p. 680, para 219%; United Kingdom, The Joint ‘Service Manual of the Law of Armed Conflict, 2004, para. §.32, tn. 187; Bothe/Partsch/Solf, New Rule for Vicins of Armed Conflicts, pp- 325-326, para. 223, and p. 408, para. 28.2; ILA Study Group on the Conduct of Hostlities in the 21st Century, "The conduct of hostilities and international humanitarian law: Challenges of 21st century warfae”, p. 380. Despite the title of Article $7 of Additional Protocol I there is no reason forthe obligation to take constant care tobe limited to the attacker, and It should be sen as applying also to the taking of precautions against the effets of attacks; see Boothby, The Law of Targeting, 119; and G. Com and ].A. Schoettler, “Targeting and chilian risk mitigation: The essential role of precautionary measures", Military Law Review, Vol.223, No. January 2035, p. 832. See also Rule 9 ofthe present Guidelines. 56327. 128. 129. 330. 1 GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONFLICT ‘This obligation requires all those involved in military operations to continuously bear in mind the effects of those operations on the civilian population, civilians and civilian objects, take steps to reduce those effects as much as possible and seek to avold any that are unnecessary." For instance, NATO has developed six Environmental Protection Standardization Agreements (STANAGs), which, among others, provide environmental planning guidelines for military activities, to which commanders should, where practicable, adhere.* Experience has also Shown that it is important for parties to a conflict to take into consideration the risk that the use of hazardous substances in the operation of certain means of warfare may contaminate the ground and thereby impact food sources for animals." By contrast, certain obligations which flow from the principle of precautions are relevant especially when conducting attacks, and these are addressed below. All feasible precautions ‘The meaning of the phrase “feasible precautions” has been interpreted by many States as being limited to those precautions which are practicable or practically possible, taking into account all circumstances ruling at the time, including humanitarian and military considerations." The 1996 Amended Protocol II and 1980 Protocol Ill to the Convention on Certain Conventional Weapons (CCW) define the term similarly.” What precautions are feasible in given circumstances will therefore be highly fact specific and may vary depending on factors such as the military Advantage sought by the operation, whether it is time sensitive, the terrain (whether man-made or natural), the situation and capabilities of the parties to the conflict, the resources, methods and means available, and the type, likelihood and severity of the expected incidental civilian harm, including harm to the natural environment.'#* Specifically with regard to incidental damage to the natural environment, the area expected to be affected and the scope of those effects, the fragility or vulnerability of the natural environment in that area, the expected severity of the damage and the expected duration of damage are elements of the humanitarian considerations to be taken into account in assessing the feasibility of a specific precaution. It should also be noted that the mete fact of taking some precautionary measures would not necessarily be enough to satisfy this obligation as defined above; there is an obligation for parties to a conflict to take all those precautions that are feasible in the circumstances. As indicated by several States upon ratification of Additional Protocol 1, feasible precautions must be based on an assessment of information from all sources available to them at the relevant time.” This requires parties to proactively seek out and collect reasonably available information, Specific precautions for attack “The following obligations are specific applications ofthe principle of precautions with regard toattacks.On the basis that the natural environment is civilian in character, these obligations provide general protection to any patt of the natural environment that is not a military objective. ‘™ United Kingdom, The Joint Service Manual ofthe Law of Armed Conflict, 2004, para 5.223; Schmit/Vihul (eds), Tltinn Mana, ‘commentary on Rule 1%, p. 476, para. 4; Oeter, *Methods and means of combat”, p.199; N. Neuman, “A precautionary tale: The theory and practice of precautions in attack”, Israel Yearbook on Human Rights, Vol. 48,2018, pp. 28-29. 1 See eg. NATO, STANAG 71, Joint NATO Doctrine for Environmental retction during NATO-Led Military Activities, pp. 2-1 ‘(0 Mlentify feasible mitigation measures, f applicable, to reduce the risk tothe environment and to human health and safety. ‘Consider alternative locations or activities that still aleve the military objective of the training or operation while reducing or eliminating the rsk to the environment or human health and safety.” Fr other environmental protection STANAGS, 5e€ Inups/ww.tatolibguidesnfo/Environment!NATO-Documents.. >For example, in Astana In Afghanistan, land on which the inhabitants grazed livestock was polluted for years by hazardous ‘chemicals used to fire missles, and this in turn exposed the local population to high risks: UNEP, Post-Conflict Branch, Ground Contamination Assessment Report: Military Waste Storage Sle, Astana, Afghanistan, UNEP, Nalrobl, 2006. See Henckaerts/Deswald-Beck (eds) ICRC Study on Customary international Humanitarien Law, Vl. commentary on Rule 15, Se: https/hl-databasesiercorg/eustomaryihl/eng/does!v4_tal_ruless. ‘= Amended Protocol Ito the CCW (1996), Art. 3(10); Protocol It to the CCW (1980), Art. 15) PHILA Study Group on the Conduct of Hosts in the 21st Century, “The conduct of hostilities and international humanitarian lave: Challenges of 2st century warfare", p. 374. This list isnot exhaustive. See eg the declarations and reservations made upon ralfication or signature ofthe 1977 Additional Protocol I by: Australia, 21 June 1991, para. 4; Ireland, 19 May 1999, para. 9; Haly, 27 February 1986, para. 5; Netherlands, 26 June 1987, para 6; New Zealand, 9 February 1988, para. 2; and United Kingdom, 12 December 1977, para. D. France indicated this understanding, Specifically in relation tothe environment: Declarations made upon ratification of the 1977 Additional Protocol, 11 April 2001, para.6. ' Gisel (ed), The Principle of Propontonaityin the Rules Governing the Conduct of Hostilties under Intemational Humanitarian Law, 48; ICTY, Fine Report tothe Protector by the Committee Fstaliched to Review the NATO Bombing Campaign Against the Federal Republic of Yugoslavia, para. 29; Russian Federation, Appliction of INL Rules: Regulations forthe Armed Forces ofthe Russian Federation, 2001, para 131. 57332, 333 3h 135, 136. GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONFLICT Each party tothe conflict must do everything feasible to verify that targets are military objectives, including that any part of the natural environment has become a military objective before itis attacked #* For example, ifa specific area of foliage hhas been identified as a military objective because itis understood to be obscuring the manoeuvre of opposing troops from view, efforts should be made to verify that the troops are in fact located in that area and that defoliation would offer adefinite military advantage in the circumstances ruling at the time (for example, enable targeting that would “otherwise not have been possible, or forcing them to retreat to aless advantageous area) {AN feasible precautions must be taken in the choice of means and methods of warfare with a view to avoiding, and in any ‘event fo minimizing, incidental los of civilian lif, injury to civilians and damage to civilian objects, including any part of the natural environment that is not a military objective." Parties could comply with this obligation by, for example, assessing the environmental impact of the weaponry to be used and using available alternative weaponry that reduces the risk of damage to specific parts of the natural environment concemed,* Each party to the conflict must do everything feasible to assess whether the attack may be expected to cause incidental loss of ‘civilian life, injury to civilians, damage to civilian objects, including any part ofthe natural environment thats not a military ‘objective, or a combination thereof, which would be excessive in relation to the concrete and direct military advantage ‘anticipated »” In this vein, prior assessments of the potential environmental impact of an attack, including the ‘expected consequences of the weapons and ammunition used, must be conducted whenever feasible 330 When planning attacks in or around areas of major environmental importance ot fragility, the mapping of these areas, for ‘example by reference to existing resources such as the World Heritage List or IUCN’s conservation databases, may also be conducted prior to the launching of an attack, if feasible, to assess the extent of the incidental damage likely ta be caused to the natural environment as a result of the attack. Each party to the conflict must do everything feasible to cancel or suspend an attack if t becomes apparent that the target, including when itis a part of the natural environment, is not a military objective or that the attack may be expected to cause incidental loss of ewvikian life, injury to civilians, damage {0 civilian objects, including the natural environment, or a ‘combination thereof, which would be excessive in relation to the concrete and direct military advantage anticipated. I it ‘were to become apparent during an attack that a target such as a military warehouse ~ thought previously to be storing ammunition, for example — was instead storing toxic substances likely to leak and poison nearby water sources if the warehouse was to be bombed, thereby having a disproportionate impact on the natural environment relative to the military advantage anticipated, then everything feasible must be done to cancel or suspend such an attack Unless circumstances do not permit, effective advance warning of attacks that may affect the natural environment should be given to allow for measures to sofequard it. This is a recommendation rather than an obligation, as HL requires that ‘warming be given only for attacks which may affect the civilian population (rather than civilian objects) However, it is still recommended to consider issuing warnings which would allow the safeguarding of the natural ‘environment. For example, if circumstances permit, giving a warning of an attack on an electricity network that = while also qualifying as a military objective ~ maintains a wastewater treatment system, may allow an opposing party to put in place a temporary generator to support some key sewage treatment facilities and thus avoid serious ‘damage ta the quality of water and soil in the area, even if such damage is not expected to affect the civilian population. additional Protocol (1977), At. 57(2)(a)H); Menckaerts)Doswald-Beck (es), ICRC Study on Customary Intemational ‘Humanitarian Law, Vol. 1, Rule 6, p. 35: bitps:/isl-databases.crcorg/customary-hl/eng/docs/e1_rul_rules6. ¥ Additional Protocol (1972), Att. 57(2)a)(U); Henckaerts/Doswald-Beck (eds), [CRC Study on Customary International ‘Humanitarian Law, Vol. , Rule 7, p. $6: bitps:(/l-datahasesictorg/customaryiil/eng/doesivt_rul_rulet7. See also ii Rule 44, p. 147: https /-databases icrcorgleustomary-ihl/engidocs/v1_rul_ruletd, 1 Droege/Tougas, “The protection of the natural environment in armed conflict: Existing rules and need for further legal protection”, p. 35 1% Additional Protocol (1977), At. 57(2)(a) (il); Henckaerts/Doswald-Beck (eds), ICRC Study on Customary International Mumanitarian Law, Vol. 1, Rule 18, p- 58: hitps(/hl-databases ier orgfeustomiaryilfengldocs/vi_rul_eulet8. ‘i Droege/Tougas, “The protection of the natural environment in armed conflict: Existing rules and need for futher legal [protection p. 3. See also NATO, STANAG 744, Joint NATO Doctrine for Environmental Protection during NATO-Led Military Activities, {and United States Department of Defense, Finnish Ministry of Defence and Swedish Armed Forces, Envinmental Guidebook for ‘Miltary Operations, March 2008, ‘Additional Protocel (1977), Art 57(2Xby; Henckaerts/Doswald-Beck (eds), ICRC Study on Customary Intemational Humanitarian Lave, Vo. 1, Rule 19, p. 60: hts: //ihl-databasesArccorg/eustomary thV/engldocs/vi_rul_rulery "Additional Protocol (1977), Art 57(2)(c); Henckaerts/Doswald-Beck (eds), CRC Study on Customary Intemational Humanitarian Law, Vol. 1, Rule 20, p, 62: btps:/ihl-databases ere org/custesnary len docs/vi_tul_tulez. 1 Droege/Tougas, “The protection of the natural enviconment in armed conflict: Existing rules and need for further legal protection”, p35.BI. GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONELICT When a choice is possible between several military objectives for obtaining a similar military advantage, the objective to be selected must be that the attack on which may be expected to cause the least danger to civilian lives and to civilian objects, including any part of the natural environment that is not a military objective. Parties to a conflict could comply with this obligation by selecting the military objective the furthest from particularly vulnerable parts of the natural ‘environment, such as underground aquifers, sensitive natural habitats or endangered species.» '% Additonal Protocl I (1977), Art. 57(3}; Henckaerts/Doswald-Beck (eds), ICRC Study on Customary Intemational Humanitarian ‘Low, Vol 1, Rule 2, p. 65: hitps/il- databases crc orgjcustomary ihlfengldocs/v1_rul_rule2l, Some States hold the view that ‘the obligation applies only when the advantage is “the same", ' Droege/Tougas, “The protection of the natural environment In armed conflict: Existing rules and need for further legal protection”, p. 34. 59138. 9. Mo. uM 2. 43, GUIDELINES ON THE PROTECTION OF THE NATURAL ENVIRONMENT IN ARMED CONFLICT. Rule 9 - Passive precautions Parties to the conflict must take all feasible precautions to protect civilian objects under their control, including the natural environment, against the effects of attacks. Commentary This general rule, which is stated here with the addition of an express reference to the natural environment, has been established as a norm of customary international law applicable in both international and non international armed conflicts." It reflects the obligation set forth in Article 58(c) of the 1977 Additional Protocol 1, Contrary to Rules 5~8 of the present Guidelines, which impose obligations on parties carrying out attacks, this rule concerns measures to be taken by a party to the conflict to protect the natural environment under its control against the effects of enemy attacks. On the basis that the natural environment is civilian in character, this rule applies to any part of the natural environment that is not a military objective. Even though it is addressed to parties to a conflict, this obligation may have to be implemented through measures taken in peacetime (that is to say, not only in times of conflict), notably when it comes to the choice of location of a fixed military installation.” 4s discussed in the commentary on Rule 8 of the present Guidelines, lack of scientific certainty as to the effects on the natural environment of certain military operations does not absolve a party to a conflict from taking precautions. Feasible precautions 4s noted in the commentary on Rule 8, the meaning of “feasible precautions” has been interpreted by States as being those precautions which are practicable or practically possible, taking into account all circumstances ruling, at the time, including humanitarian and military considerations. Numerous States have indicated that military ‘commanders have to reach decisions concerning what precautions against the effects of attacks are practicable ot Practically possible on the basis of their assessment of the information from all sources available to them at the relevant time. Such assessment will also have to take into account that States and other parties to a conflict owe this obligation not only to the natural environment, but also to civilians and other civilian objects under their control. ‘The transboundary, seemingly limitless nature of the natural environment means that parties to a conflict will in reality be “surrounded” by the natural environment at all times. Even considering that the ebligation to take all, feasible precautions to protect the natural environment is that of the patty to the conflict under whose control it Is, this raises the question as to how onerous the burden of taking such precautions can be In practice. ‘As the natural environment in Its entirety is not a movable object in the traditional sense of the word (though, of ‘course, certain parts of it, such as fauna," may be movable), it cannot be completely “removed” from the vicinity ‘of military objectives. The fact that military operations will necessarily be surrounded by the natural environment does not, however, mean that precautions cannot be taken to protect it from differing degrees of harm. For example, ‘when a choice is possible between stationing troops at several locations, all of which offer similar advantages across the range of pertinent operational factors, the location selected must be that which is expected to cause the least damage to civilian lives and civilian objects, including the natural environment, in the event that the location is, ‘attacked by opposing forces. Thus, given the choice between an open, uninhabited grassland and a zone of particular See Henckaerts/Doswald-eck (eds) ICRC Study on Customary Internationa Humonitarian Law, Vl. Rule 22 and commentary, 68; hitys:/thl-databases icteorg/customary-ihlfenpdoes)v4_rul_rule22 and related practice. 'Sandaz/Swinarski/Zimmermann (eds), Commentary en the Additional Protocols, p. 692, para. 2244. See Henckaerts/Doswald-eck (eds), ICRC Study on Customory International umanitarin Law, Vo. ,thitd sentence of Rule 4 ‘and commentary. p. 150: hitps//ihl-databases iercorg/customaty-thl/eng/docs/vi_rul_ruleza and related practice. See fn, 321 above and related text See fn. 145 above. While organized by private individuals and nota party to the conf, see, for example, the removal of wild animals from a ‘00{n a theme park in Aleppo; . Guynup, “How Syrian Zoo Animals Escaped 3 Wat-Ravaged City", National Geographic, § (October 2017 ips.t/wvew nationalgeogzaphic com/news/2017/s0/wildlfe-watch-tescuin-anitnals-aleppo-sytia. zou, ‘For the obligation to remove chuillan objects from the vicinity of military objectives to the extent feasible, ee Menckaerts/Doswald-teck (eds), ICRC Study on Customary International Humanitarian Law, Vl. 1, commentary on Rule 24, p. 74: Ips: databases icrcorgleustomary-thVfengidocs/¥1_aul -tule24. 60