APPLICATION FOR PERMISSION TO PROCEED AS AMICI CURIAE

The Center for International Environmental Law, on behalf of La Mesa, requests amicus curiae status in the Pac Rim v. El Salvador case. They argue that the dispute is a political disagreement over sustainable development and public policy rather than a legal dispute over a specific government measure. The document highlights severe environmental risks associated with the proposed El Dorado mine, including threats to the Rio Lempa basin and local aquifers, and alleges that Pac Rim's activities have contributed to community violence and the murder of environmental defenders. Legally, the amici contend that Pac Rim's last-minute corporate reorganization to gain CAFTA benefits is an abuse of process and that the tribunal lacks jurisdiction under the ICSID Convention and CAFTA.

• The prospective amici argue that the case does not involve a 'legal dispute' under Article 25 of the ICSID Convention or a 'measure' under Article 10.1 of CAFTA, but is instead a reflection of Pac Rim's dissatisfaction with shifts in Salvadoran public policy regarding metals mining and sustainable development.
• The document asserts that the only potential legal dispute expired in 2004 when Pac Rim failed to appeal the Ministry of Environment and Natural Resources (MARN) denial of its Environmental Impact Assessment (EIA), opting instead for unofficial back-channel negotiations with government officials.

APA

Center for International Environmental Law (2011). APPLICATION FOR PERMISSION TO PROCEED AS AMICI CURIAE. https://www.ciel.org/wp-content/uploads/2015/04/PAC_RIM_Amicus_2Mar11_Eng.pdf

Chicago

Center for International Environmental Law. APPLICATION FOR PERMISSION TO PROCEED AS AMICI CURIAE. 2011. https://www.ciel.org/wp-content/uploads/2015/04/PAC_RIM_Amicus_2Mar11_Eng.pdf.

Wikipedia

{{cite report |author=Center for International Environmental Law |title=APPLICATION FOR PERMISSION TO PROCEED AS AMICI CURIAE |date=2 March 2011 |url=https://www.ciel.org/wp-content/uploads/2015/04/PAC_RIM_Amicus_2Mar11_Eng.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centerforinternationalenvironmentallaw2011application, author = {{Center for International Environmental Law}}, title = {{APPLICATION FOR PERMISSION TO PROCEED AS AMICI CURIAE}}, institution = {Center for International Environmental Law}, year = {2011}, month = mar, url = {https://www.ciel.org/wp-content/uploads/2015/04/PAC_RIM_Amicus_2Mar11_Eng.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }