Joint application seeking authorization for the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law to act as amicus curiae in Arbitration proceedings Odyssey Marine Exploration, Inc. v. United Mexican States (ICSID Case No. UNCT/20/1)

The document is an amicus curiae application and submission in the case of Odyssey Marine Exploration, Inc. v. United Mexican States. The applicants argue that the Don Diego Project, which involves dredging 91 thousand hectares of the Gulf of Ulloa seabed to extract phosphate rock, would cause irreversible ecological damage and violate human rights. They contend that the Mexican State's decision to deny the environmental permit is supported by the precautionary principle and obligations under UNCLOS, the Rio Declaration, and various human rights treaties, including the ICESCR and the American Convention on Human Rights.

• The Don Diego Project involves dredging 91 thousand hectares of the Gulf of Ulloa seabed to extract 7 million tonnes of sand and phosphate rock annually over a 50-year period, operating 24 hours a day, seven days a week.
• The project area overlaps with a fishing refuge zone established on 10 April 2015 and a fishing concession granted to the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. that is valid until 2035.
• Seabed mining in the Gulf of Ulloa poses risks of irreversible biodiversity loss, specifically threatening marine mammals such as humpback, Bryde's, and gray whales, as well as loggerhead sea turtles.
• The submission asserts that approving the project would violate the human right to work and the right to take part in cultural life for the local fishing communities who have operated in the region for over 60 years.
• The applicants claim that the project would violate the right to health and the right to a healthy environment by introducing toxic and radioactive emissions into the marine ecosystem.
• The document notes a global trend of caution toward seabed mining, citing a 2021 IUCN World Conservation Congress motion for a moratorium and a total ban on seabed mining in the Northern Territory of Australia as of 4 August 2021.

APA

Center for International Environmental Law (2021). Joint application seeking authorization for the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law to act as amicus curiae in Arbitration proceedings Odyssey Marine Exploration, Inc. v. United Mexican States (ICSID Case No. UNCT/20/1). https://www.ciel.org/wp-content/uploads/2022/02/Amicus-Curiae-application-for-leave-and-submission-of-CIEL-and-the-Cooperativa-Puerto-Chale-2.pdf

Chicago

Center for International Environmental Law. Joint application seeking authorization for the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law to act as amicus curiae in Arbitration proceedings Odyssey Marine Exploration, Inc. v. United Mexican States (ICSID Case No. UNCT/20/1). 2021. https://www.ciel.org/wp-content/uploads/2022/02/Amicus-Curiae-application-for-leave-and-submission-of-CIEL-and-the-Cooperativa-Puerto-Chale-2.pdf.

Wikipedia

{{cite report |author=Center for International Environmental Law |title=Joint application seeking authorization for the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law to act as amicus curiae in Arbitration proceedings Odyssey Marine Exploration, Inc. v. United Mexican States (ICSID Case No. UNCT/20/1) |date=12 October 2021 |url=https://www.ciel.org/wp-content/uploads/2022/02/Amicus-Curiae-application-for-leave-and-submission-of-CIEL-and-the-Cooperativa-Puerto-Chale-2.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centerforinternationalenvironmentallaw2021joint, author = {{Center for International Environmental Law}}, title = {{Joint application seeking authorization for the Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law to act as amicus curiae in Arbitration proceedings Odyssey Marine Exploration, Inc. v. United Mexican States (ICSID Case No. UNCT/20/1)}}, institution = {Center for International Environmental Law}, year = {2021}, month = oct, url = {https://www.ciel.org/wp-content/uploads/2022/02/Amicus-Curiae-application-for-leave-and-submission-of-CIEL-and-the-Cooperativa-Puerto-Chale-2.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }