defenders, especially those related to the environment. There are also indications of the use of COVID-19 pandemic as an excuse to silence human rights defenders' work on the environment. This is a concern, that the work carried out by human rights defenders still needs to be protected.51 Recommendation to the Committee on Economic, Social and Cultural Rights (CESCR): ● To urge the GoI to take measure to protect Human Rights Defenders in the field of economic, social and cultural rights from the risk of intimidation, attacks, and criminalization because of their work; ● To question the GoI about the plan to establish a special legal framework regarding the protection of Human Rights Defenders; and ● To urge the GoI to expadite the revision of the Law No. 11 of 2008 on Information and Electronic Transactions which should be done comprehensively including eliminating the articles on threat of criminal defamation. The Right to Health for Vulnerable Groups 69. In 2020, Indonesia faces four transitions of health problems that provide a double burden, namely the epidemiological transition in the form of communicable and non-communicable diseases, the nutritional transition in the form of malnutrition problems, the demographic transition in the form of increasing life expectancy resulting in an increase in the percentage of the elderly population, as well as the transition of lifestyle behavior. life in the form of a shift to modern life (sedentary life) which has become part of people's daily lives. The four transitions occur simultaneously and are interrelated so that currently hypertension, diabetes mellitus, heart disease, blood vessels, kidney failure, stroke, cancer, and several other chronic diseases are afflicted by the rich population, the population aged over 50 years, as well as the population group from lower middle class/poor and the population under 50 years old.52 70. Conditions for fulfilling the right to health in Indonesia vary widely in each region because government affairs in the health sector are the authority of local governments. The existence of a high disparity in health services between regions in Indonesia is influenced by the availability of resources and differences in conditions in each region. The situation of people in remote/underdeveloped/periphery areas in accessing basic health services is also still facing obstacles. People who live far from the city centre where health services are available, have to travel far and take a long time.53 71. All health facilities and services must be accessible to everyone, especially for vulnerable groups. Vulnerable groups get special treatment or affirmative/protective action more because of their 51 Komnas HAM, Laporan Tahunan 2020, Pemajuan & Penegakan HAM di Era Pandemi Covid 19, 2021, p. 84, can be accessed at: https://www.komnasham.go.id/files/20210830-laporan-tahunan-komnas-ham-ri-$R1X5O.pdf. 52 Komnas HAM RI, Standar Norma dan Pengaturan (Norms and Regulation Standard) Nomor 4 tentang Hak atas Kesehatan (on Rights to Health), Jakarta, 2020, can be accessed at https://www.komnasham.go.id/index.php/peraturan/2021/10/14/37/standar-norma-dan-pengaturan-nomor4-tentang-hak-atas-kesehatan.html. 53 Komnas HAM RI, a Study on the Rights to Health for Vulnerable Groups in Indonesia, 2020, can be accessed at https://www.komnasham.go.id/index.php/publikasi/2021/01/29/114/kajian-pemenuhan-hak-atas-kesehatanbagi-kelompok-rentan-di-indonesia.html.