Coral Reefs and Legal Obligations for Coastal Developments in the Caribbean
The reef as a legal asset and subject of multilevel protection
The Mesoamerican Reef System, the second most extensive reef system on the planet with approximately 1,000 kilometers in length from the Yucatán Peninsula to Honduras, constitutes simultaneously the ecological foundation of the Quintana Roo coastline and a legal asset protected by at least four concurrent regulatory levels: federal environmental, federal patrimonial, state, and international conventional. For a coastal developer in the Mexican Caribbean, this normative overlap is not an academic technicality: it is the principal determinant of the time, cost, and legal certainty of any real estate or tourism project in areas of reef influence. The legal exposure generated by non-compliance operates in administrative, criminal, and civil forums simultaneously, without an electio fori mechanism that permits the operator to choose between regimes.
Federal regulatory framework: overlapping obligations
Mexico lacks a law dedicated exclusively to the protection of coral reefs. Protection emerges, instead, from the articulation of multiple ordinances whose parallel application generates complex and, at times, contradictory obligations. Mastery of the applicable framework begins by identifying which law governs each aspect of the projected activity.
LGEEPA and Environmental Impact Statement
The General Law on Ecological Balance and Environmental Protection (LGEEPA, DOF January 28, 1988, with reforms in effect at the close of this analysis) constitutes the central axis of the regime. Its article 28 establishes the obligation to obtain authorization regarding environmental impact prior to the execution of works or activities that may cause ecological imbalance or exceed the limits and conditions established in applicable provisions. For coastal developments in the Mexican Caribbean, this obligation is activated without exception: the Regulation of the LGEEPA on Environmental Impact Assessment (DOF May 30, 2000) contemplates in its article 5 hydraulic and coastal infrastructure works, land use changes in terrain with native vegetation, and real estate developments that affect coastal ecosystems, all subject to an Environmental Impact Statement, in its regional modality when the surface area or complexity of the ecosystem warrants it.
The EIS for projects with potential impact on reef ecosystems must include, pursuant to article 12 of the Regulation, the bionomic characterization of the reef system present or adjacent, the evaluation of direct and indirect impacts on coral communities, and the proposal of technically sustainable mitigation measures. SEMARNAT may impose conditions or deny authorization when impacts are not technically mitigable, in application of the precautionary principle enshrined in section II of article 15 of the LGEEPA. The failure to obtain authorization or non-compliance therewith constitutes an administrative infraction under article 171 and may generate the nullity of all municipal licenses and permits derived therefrom.
NOM-059-SEMARNAT-2010: coral species in risk category
The Mexican Official Standard NOM-059-SEMARNAT-2010 (DOF December 30, 2010, modified by agreement published November 14, 2019) is the normative instrument that classifies native species under risk categories with direct legal effects. Various coral species that comprise the Mesoamerican reef are catalogued under the category P (in danger of extinction), including Acropora palmata (elkhorn coral) and Acropora cervicornis (staghorn coral), while species of the Orbicella annularis complex appear under category A (threatened).
This classification activates the prohibitions of articles 55 and following of the General Law on Wildlife (LGVS, DOF July 3, 2000), which prohibit any act that destroys, damages, or affects specimens of wildlife in risk category without express authorization from SEMARNAT. The connection with the criminal regime is immediate: article 420, section IV of the Federal Penal Code typifies as a crime the destruction or collection of wild flora or fauna specimens listed in official standards in risk categories, with penalties of one to nine years imprisonment and a fine of three hundred to three thousand days of minimum wage. Criminal liability may extend to legal entities through direct imputation to legal representatives and executives who have authorized the damaging activity.
Federal Maritime-Terrestrial Zone and public domain
The General Law on National Assets (LGBN, DOF May 20, 2004) establishes in its article 9 that the federal maritime-terrestrial zone (ZOFEMAT) comprises a strip of twenty meters in width transversal to the line of ordinary maximum high tide, while lands gained from the sea and beaches are assets of federal public domain in accordance with article 3, section IV of that law. The operational reference of ZOFEMAT is complemented by the Regulation for the Use and Exploitation of Territorial Sea, Navigable Waterways, Beaches, Federal Maritime-Terrestrial Zone and Lands Gained from the Sea (DOF August 21, 1991), which regulates concession procedures, conditions of use, and grounds for revocation applicable to any permanent installation within that strip. Any work in ZOFEMAT requires a concession from the Secretariat of Infrastructure, Communications and Transportation (SICT), regardless of environmental authorizations.
The seabed where the reefs are located falls under the regime of the Federal Law of the Sea (DOF January 8, 1986), whose article 6 establishes territorial waters at twelve nautical miles. The exclusive economic zone is delimited at two hundred nautical miles measured from the baseline in accordance with article 48 of that same law, which is the provision that establishes the extension of said maritime space. Article 51, for its part, enumerates the sovereign rights of the Mexican State over living and non-living resources in the EEZ, a relevant distinction because it is the foundation of inspection and enforcement powers in that space with respect to activities affecting the reef ecosystem. Within these spaces, the State exercises full sovereignty, so any damage to the reef ecosystem constitutes an affectation to assets of the national public domain, with the patrimonial and criminal consequences that this entails.
Federal Environmental Liability Law
The Federal Environmental Liability Law (LFRA, DOF June 7, 2013) introduced strict liability for environmental damage of notable relevance for the coastal real estate sector. Its article 6 establishes that whoever causes damage to the environment is obligated to repair it and, when repair is wholly or partially impossible, to provide environmental compensation. Article 2 defines environmental damage as the loss, change, deterioration, impairment, affectation, or adverse and measurable modification of habitats, ecosystems, natural elements and resources, a definition sufficiently broad to encompass any structural or functional alteration of a coral reef. The LFRA also created collective environmental actions with expanded standing, enabling civil society organizations and the Federal Procuratorate for Environmental Protection (PROFEPA) to seek reparation directly before federal courts.
Protected Natural Areas in the Mexican Caribbean
The coast of Quintana Roo concentrates an exceptional number of Protected Natural Areas (ANP) that drastically restrict development possibilities, each with its own constitutive decree, management program, and binding zoning. The most relevant for the real estate and tourism sector are:
- Puerto Morelos Reef National Park (decree DOF February 2, 1998): 9,067 hectares of reef ecosystem in front of the Cancún-Playa del Carmen corridor; its management plan establishes core zones of absolute protection and restricted-use zones where all activities require CONANP authorization.
- Western Coast National Park of Isla Mujeres, Punta Cancún and Punta Nizuc (decree DOF July 19, 1996): directly affects the maritime front of the Cancún hotel zone and its nautical accesses, conditioning port infrastructure and anchoring works.
- Banco Chinchorro Biosphere Reserve (decree DOF July 19, 1996): the largest coral atoll in the northern hemisphere, with a strictly regulated use regime that limits human activity to low-impact tourism modalities certified by CONANP.
- Sian Ka’an Biosphere Reserve (decree DOF January 20, 1986, UNESCO World Heritage Site since 1987): its buffer zone extends over the Tulum-Mahahual corridor, affecting numerous tourism real estate development projects.
Article 48 of the LGEEPA prohibits in national parks the extractive exploitation of natural resources and any act that alters ecosystems. The management plans of each ANP are legally binding instruments that determine the permitted, conditioned, and prohibited activities in each subzone. Their non-compliance generates administrative sanctions under article 171 of the LGEEPA and may result in the revocation of related concessions, including ZOFEMAT concessions and construction authorizations.
Territorial ecological planning in Quintana Roo
The Territorial Ecological Planning Program of the State of Quintana Roo (POET-QR) is a legally binding instrument that establishes Environmental Management Units (UGA) with guidelines, criteria, and coastal land use capabilities. The UGAs for conservation and restricted sustainable use in the coastal zone impose stricter standards than federal ones for the granting of construction licenses. The Urban Development Plans of the coastal municipalities—Benito Juárez, Solidaridad, Tulum, and Othón P. Blanco—must be consistent with the POET-QR, so the developer must verify project compatibility at all three levels of government. Incongruence between a municipal license and the POET-QR may result in its nullification for breach of superior regulatory provisions, generating a legal contingency that is difficult to remedy after the fact.
Sanctioning regime: administrative, criminal, environmental, and civil liability
The sanctioning scheme applicable to reef damage operates in four concurrent forums that do not exclude each other. In the administrative forum, SEMARNAT and PROFEPA may impose fines of up to fifty thousand times the Measurement and Update Unit (UMA), order temporary or permanent closure of works, and require costly restoration measures with uncertain execution. In the criminal forum, Article 420 of the Federal Criminal Code in its sections I and IV establishes prison sentences of one to nine years for those who destroy or damage specimens of flora or fauna in risk categories, including corals listed in NOM-059. In the civil-environmental forum, the LFRA enables actions before district courts with the possibility of precautionary measures suspending works, even prior to the issuance of a final judgment.
The fourth seat of liability, frequently overlooked in the risk analysis of coastal projects, is classic tort liability derived from Articles 1910 and 1913 of the Federal Civil Code. Article 1910 establishes subjective liability for fault or negligence, while Article 1913 establishes objective liability for risk created through the use of mechanisms, instruments, apparatus, or dangerous substances that cause harm to third parties. These actions are independent of the LFRA regime, which does not repeal ordinary civil remedies. Fishing communities, coastal ejidos, and groups of users with fishing rights or ancestral use of the reef ecosystem may exercise them directly before federal civil courts, claiming the patrimonial value of lost resources and damages to community productive patrimony. For the developer, this fourth avenue represents an additional exposure that is not settled by compliance with the LFRA or by obtaining administrative authorizations, and must be specifically evaluated in the due diligence phase of the project.
The First Chamber of the Supreme Court of Justice of the Nation has held in the jurisprudential thesis 1a./J. 31/2017 (10a.), published in the Judicial Weekly of the Federation, that the right to a healthy environment enshrined in the fifth paragraph of Article 4 of the Constitution is a fundamental right with a collective dimension that binds both authorities and private parties, producing horizontal effect in relations between private subjects. This thesis is mandatory reading for any developer because it extends environmental damage liability beyond vertical State-administered relationships and places it in the realm of conflicts between private parties, including claims by affected communities.
Regarding non-retrogression, the criteria derived from amparo in revision 307/2016, resolved by the First Chamber of the SCJN and published in the Judicial Weekly of the Federation in the Tenth Epoch, establish that the principle of environmental non-retrogression, incorporated into the Mexican legal system through the inter-American legal corpus and Article 1 of the Constitution, prevents administrative authorizations from reducing the level of protection already achieved for fragile ecosystems. This criterion reinforces the validity of the stricter restrictions contained in the management plans of Protected Natural Areas against permissive interpretations of general legislation, and constitutes a central argument in any challenge to conditions imposed in an Environmental Impact Statement or in a Protected Natural Area management program.
Legislative evolution and regulatory perspective
The legal regime applicable to coral ecosystems has experienced progressive densification since the enactment of LGEEPA in 1988. The 1996 reforms to LGEEPA had as their central objective the strengthening of the regime of Natural Protected Areas and the modification of the environmental impact assessment procedure, without including at that time specific provisions on mangroves. The express protection of this ecosystem, adjacent and interdependent with the reef, came later: article 60 Ter of LGEEPA, which prohibits the removal, filling, transplantation, pruning, or any work or activity that affects the integrity of the hydrological flow of mangroves, was added through reform published in the DOF on February 1, 2007. This chronological distinction is relevant because it determines the moment from which express legislative protection of the mangrove as an ecosystem linked to the reef became integrated into the federal legal system. The publication of LFRA in 2013 marked a turning point by establishing objective liability and expanding standing for environmental actions. The modification of NOM-059 in 2019 updated the list incorporating new coral species under categories of greater protection. In 2024, reforms to the General Law on Wildlife strengthened PROFEPA’s inspection tools in the marine zone. At the international level, the Kunming-Montreal Global Biodiversity Framework —adopted at COP15 of the Convention on Biological Diversity in December 2022— establishes the goal of protecting 30% of marine ecosystems by 2030 (Target 3). Mexico has committed to its implementation, which anticipates additional restrictions on coastal developments within a regulatory horizon of three to five years.
Comparative Analysis: Belize and Florida
Comparison with legal frameworks of neighboring jurisdictions reveals the structural advantages of specific and centralized protection models that Mexico has not adopted.
Belize operates its reef protection through the Coastal Zone Management Authority and Institute Act (Cap. 329) and the Environmental Protection Act (Cap. 328), complemented by the Integrated Management Plan of the Belize Barrier Reef, UNESCO World Heritage Site since 1996. The Coastal Zone Management Institute acts as a single centralized window for all coastal activity, eliminating the interinstitutional fragmentation that characterizes the Mexican model. Any project within the reef influence zone must be submitted to a specific Environmental Impact Assessment with independent coral health evaluation. Belize went further by prohibiting through constitutional amendment in 2018 the exploration and extraction of hydrocarbons in coastal waters, a level of restriction that Mexico has not adopted and which reinforced the removal of the site from the List of World Heritage in Danger that same year.
Florida, United States, has the Florida Coral Reef Protection Act (Section 403.93345, Florida Statutes) as an autonomous and specific instrument for reef protection. This law establishes obligations for prior notification, damage assessment, and payment of compensation to the State Coral Restoration Fund when a work causes quantifiable damage, even accidentally. The Florida Keys National Marine Sanctuary system (NOAA, regulated under 15 C.F.R. Part 922, Subpart P) adds a layer of federal protection with specific permits for each category of aquatic activity. The characteristic that distinguishes the Florida model is the existence of a regulated methodology for valuing coral damage per unit area and colony typology, which establishes with legal certainty the quantum of reparation required, drastically reducing litigation over the scope of the restoration obligation.
Both models share a structural characteristic absent in the Mexican legal system: mechanisms for legally binding quantification of coral damage and organisms with a specific mandate for reef protection, which reduce legal uncertainty and accelerate effective damage repair.
Regulatory Gaps and Operational Risks for Investors
Raúl Brañes Ballester, in his Manual of Mexican Environmental Law (2nd ed., FCE-SEMARNAT, 2000), identified institutional fragmentation as the structural deficit of the Mexican environmental legal system, a diagnosis that remains current with particular intensity in the protection of marine ecosystems. José Juan González Márquez, in his New Mexican Environmental Law: Policy Instruments (UAM, 1997), pointed out the insufficiency of instruments for economic valuation of environmental damage as a condition for the effectiveness of liability for ecological damage. Gustavo Alanís Ortega, from the Mexican Center for Environmental Law (CEMDA), has documented in successive law implementation reports the gap between the formal normative framework and the effectiveness of its implementation in coastal marine ecosystems.
The principal regulatory gaps identified, with direct impact on legal risk management of coastal projects, are as follows. First: the LFRA does not establish a regulated federal methodology to quantify reef damage, leaving the determination of quantum to non-standardized expert criteria and generating considerable litigation uncertainty. Second: there are no mechanisms for anticipated environmental compensation equivalent to coral mitigation banking available in other countries, which prevents the promoter from internalizing the cost of irreducible residual damage from the planning stage. Third: the dispersion of competencies among SEMARNAT, CONANP, SEMAR, SICT and state authorities generates multiple service windows without regulated formal coordination, producing inconsistencies between authorizations that are difficult to resolve without litigation. Fourth: the absence of a specific criminal offense for the destruction of coral reefs—which is currently pursued through the generic route of article 420 of the CPF with ambiguous accreditation standards—creates uncertainty both for the accused and for the environmental victim. Fifth: ZOFEMAT concessions do not currently contemplate continuous monitoring requirements for coral health as a condition of validity, allowing accumulated damages to remain undetected until they become irreversible.
For the investor or developer, these gaps represent a bidirectional risk: the possibility of incurring liability without having obtained clear regulatory guidance on applicable standards and, simultaneously, exposure to damages claims of indeterminate scope in the absence of regulated damage valuation methodologies. Proper management of this risk requires specialized legal advice from the due diligence stage, before land acquisition or the MIA request.
Minimum environmental due diligence protocol
Faced with the risk map described, the CFO of an investment fund or the legal manager of a real estate promoter needs an operational sequence that allows identifying and quantifying exposure before committing capital. The following five steps constitute the minimum non-waivable core of any environmental due diligence process in coastal projects in the Mexican Caribbean.
First — Verification of overlap with ANPs and POET-QR before signing the purchase promise agreement. All negotiations must be conditioned on cartographic confirmation that the property does not overlap with federal or state ANP polygons, nor with UGAs of conservation or restricted use under the POET-QR. This verification cannot be replaced with seller declarations or prior municipal licenses, which may have been granted in contravention of higher-order regulations. The consultation must be conducted through CONANP’s geographic information system and the official POET-QR registry, with documentary evidence integrated into the transaction file.
Second — Independent bionomic reef survey of the property and its area of influence. Regardless of the survey that must be submitted in the MIA at the appropriate time, the acquirer must commission before closing the transaction its own bionomic study documenting the current condition of coral communities present or adjacent. This survey has two legal functions: establishing the baseline condition of the ecosystem at the time of acquisition, which allows determining responsibility for pre-existing damages under the LFRA, and determining whether the presence of species listed in NOM-059 makes the project technically unfeasible before incurring MIA costs.
Third — Coherence analysis between prior municipal licenses and the POET-QR. Coastal developments frequently have a record of municipal licenses or authorizations whose compliance with the POET-QR was never audited. The existence of these licenses does not generate acquired rights against federal environmental regulations and may instead represent an additional liability if they were granted irregularly. The analysis must include review of all prior administrative acts and identification of any inconsistency that could support a nullity action by federal authorities or affected third parties.
Fourth — Evaluation of the need for MIA in regional versus particular modality. The choice of modality is not discretionary for the proponent: it depends on the project’s surface area, the presence of fragile ecosystems in the area of influence, and the existence of ANPs or RAMSAR sites in the surroundings. A particular MIA submitted when the project requires regional modality is sufficient cause for denial of authorization or its subsequent challenge for nullity. This evaluation must be made based on the criteria of article 11 of the LGEEPA Regulations on EIA and, when proximity to an ANP is a factor, must be previously coordinated with the regional delegation of SEMARNAT in Cancún to establish the expected scope of the procedure.
Fifth — Estimated quantification of inherited environmental liabilities under the LFRA. When the property has a history of construction, hotel or nautical activity, accumulated environmental liabilities that the acquirer could inherit must be identified and estimated. The LFRA does not expressly establish the transmission of environmental responsibility to the acquirer of a property, but the administrative practice of PROFEPA and emerging judicial criteria point towards joint and several liability in certain circumstances. The quantification, although approximate at this stage, must be reflected in the acquisition price or in specific warranties from the seller, and must guide the decision on whether the project is viable before the buyer assumes the legal position of the owner.
IBG Legal: position and operational differentiator
The difference between identifying regulatory risk before acquisition or facing it in a PROFEPA closure does not depend solely on regulatory knowledge: it depends on institutional proximity with the authorities that execute that framework in the specific territory where the project operates. IBG Legal is based in Cancún, which means daily presence before the regional delegation of SEMARNAT in Quintana Roo, the Regional Directorate of CONANP-Yucatan Peninsula and Mexican Caribbean, and the sub-delegation of PROFEPA-Quintana Roo: the three bodies that in practice determine the success or failure of an authorization procedure or an inspection procedure in the Mexican Caribbean.
This geographic and institutional position translates into concrete capabilities for the client: updated knowledge of the criteria applied by the regional delegation of SEMARNAT in the evaluation of EIAs for projects with potential impact on reefs, direct experience in PROFEPA inspection and verification procedures in the coastal zone of Quintana Roo, and ability to act simultaneously in the administrative seat before SEMARNAT and CONANP and in the federal judicial seat before the district courts with jurisdiction in the region. We advise developers, investment funds and national and international investors from prior due diligence to acquisition through defense in environmental liability litigation, including comprehensive EIA management and structuring of feasible compliance conditions. For advice on this matter, please contact us.
Sources and References
Federal Legislation
- Political Constitution of the United Mexican States, article 4, fifth paragraph (right to a healthy environment).
- General Law on Ecological Equilibrium and Environmental Protection (LGEEPA), Official Gazette (DOF) January 28, 1988, with current amendments. Articles 15 section II (precautionary principle), 28 (environmental impact assessment), 44, 46, 48 (protected natural areas), 60 Ter added by amendment DOF February 1, 2007 (mangrove protection), 171 (administrative penalties).
- Regulation of the LGEEPA on Environmental Impact Assessment, DOF May 30, 2000. Articles 5 (works and activities subject to EIA), 11 (modality criteria), 12 (EIA content).
- General Law on Wildlife (LGVS), DOF July 3, 2000, with current amendments. Articles 55 et seq. (protection of species at risk).
- General Law on National Assets (LGBN), DOF May 20, 2004. Articles 3 section IV (assets of the public domain), 9 (federal maritime-terrestrial zone, twenty-meter strip transversal to ordinary maximum high tide), 121, 126.
- Regulation for the Use and Exploitation of Territorial Sea, Navigable Waterways, Beaches, Federal Maritime-Terrestrial Zone and Land Gained from the Sea, DOF August 21, 1991 (operational regime of ZOFEMAT: concessions, conditions of use, grounds for revocation).
- Federal Law on Environmental Responsibility (LFRA), DOF June 7, 2013. Articles 1, 2 (definition of environmental damage), 6 (obligation to repair), 13.
- Federal Law of the Sea, DOF January 8, 1986. Articles 6 (territorial sea, twelve nautical miles), 48 (exclusive economic zone, two hundred nautical miles), 51 (sovereign rights of the State over living and non-living resources in the EEZ).
- Federal Criminal Code, articles 418 to 421 (crimes against the environment), with special reference to article 420, sections I and IV.
- Federal Civil Code, articles 1910 (subjective tort liability based on fault or negligence) and 1913 (strict liability for risk created through the use of mechanisms, instruments, apparatus or dangerous substances).
Official Mexican Standards
- NOM-059-SEMARNAT-2010, Environmental Protection — Native Species of Mexican Wild Flora and Fauna — Categories of Risk and Specifications for Their Inclusion, Exclusion or Change, DOF December 30, 2010; modified by agreement published in the DOF on November 14, 2019.
- NOM-022-SEMARNAT-2003, Specifications for the Preservation, Conservation, Sustainable Use and Restoration of Coastal Wetlands in Mangrove Zones, DOF April 10, 2003.
Protected Natural Areas Decrees
- Decree of the Arrecife de Puerto Morelos National Park, DOF February 2, 1998.
- Decree of the Costa Occidental de Isla Mujeres, Punta Cancún and Punta Nizuc National Park, DOF July 19, 1996.
- Decree of the Banco Chinchorro Biosphere Reserve, DOF July 19, 1996.
- Decree of the Sian Ka’an Biosphere Reserve, DOF January 20, 1986.
State legislation and planning
- Territorial Ecological Planning Program of the State of Quintana Roo (POET-QR), published in the Official Journal of the State of Quintana Roo.
Case law
- Supreme Court of Justice of the Nation, First Chamber. Case law thesis 1a./J. 31/2017 (10a.), Judicial Journal of the Federation, Tenth Epoch: fundamental right to a healthy environment, its collective dimension and horizontal effect between private parties (Article 4, fifth paragraph of the Constitution).
- Supreme Court of Justice of the Nation, First Chamber. Amparo in review 307/2016, Tenth Epoch, published in the Judicial Journal of the Federation: principle of non-regression in environmental matters; prohibition of administrative authorizations reducing the level of protection already achieved for fragile ecosystems; integration of the inter-American corpus iuris into the Mexican constitutional environmental standard via constitutional article 1.
Comparative law
- Belize: Coastal Zone Management Authority and Institute Act, Cap. 329; Environmental Protection Act, Cap. 328; Integrated Management Plan for Belize’s Barrier Reef.
- United States — Florida: Florida Coral Reef Protection Act, Section 403.93345, Florida Statutes; Florida Keys National Marine Sanctuary, NOAA regulations, 15 C.F.R. Part 922, Subpart P.
International instruments
- Convention on Biological Diversity (CBD), ratified by Mexico through decree published in the DOF on May 7, 1993.
- Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), Appendix II (Anthozoa); in force for Mexico since 1991.
- Kunming-Montreal Global Biodiversity Framework, adopted at COP15 of the CBD, Montreal, December 2022 (Target 3: protection of 30% of marine ecosystems by 2030).
- UNESCO: World Heritage List — Sian Ka’an Biosphere Reserve (1987); System of Reserves of the Belize Barrier Reef (1996).
Legal doctrine
- Brañes Ballester, Raúl. Manual of Mexican Environmental Law. 2nd edition. Mexico: Fondo de Cultura Económica / SEMARNAT, 2000.
- González Márquez, José Juan. New Mexican Environmental Law: Policy Instruments. Mexico: Universidad Autónoma Metropolitana, 1997.
- Alanís Ortega, Gustavo (coord.). Diagnostic on the Application of Environmental Legislation in Mexico. Mexico: Mexican Center for Environmental Law (CEMDA), institutional publications.