Reform to the Amparo Law 2025, State EIA in Quintana Roo and Real Risks for Real Estate Developers

Dual System of EIA in Quintana Roo — IBG Legal

The Dual System of Environmental Impact Assessment in Quintana Roo: Point of Departure for Understanding the Exposure

Preliminary note on the legislative status of the 2025 reform: This article distinguishes between two normative moments that must remain conceptually separate. The first is the constitutional reform to the Judiciary, published in the Official Gazette of the Federation on September 15, 2024 through the Decree by which various provisions of the Political Constitution of the United Mexican States are reformed, added, and repealed, regarding reform to the Judiciary, which modified articles 94 to 107 of the Constitution and imposed on the Congress of the Union the express obligation to adapt secondary legislation, including the Amparo Law. The second moment is the secondary adapting legislation. As of the closing date of this article, the decree reforming the Amparo Law derived from that constitutional mandate has not been identified with a decree number and publication date in the Official Gazette that can be cited with verifiable certainty. Consequently, references to modifications to articles 128, 129, and 5 section III of the Amparo Law are presented as expected modifications, consistent with the constitutional mandate of the decree of September 15, 2024, and with legislative projects circulated in the Congress of the Union at the closing of the drafting of this article. As soon as the decree reforming secondary legislation is published in the Official Gazette, references to those articles must be confirmed against the official text. This distinction is relevant for readers who use this analysis as a basis for procedural arguments.

The constitutional mandate derived from the Judiciary reform of September 2024 will structurally alter the mechanisms of precautionary protection available to real estate developers. For those operating in Quintana Roo, where the Environmental Impact Statement—both federal before the Secretary of Environment and Natural Resources (SEMARNAT) and state before the Secretary of Ecology and Environment (SEMA)—is a requirement of legal existence for practically any project of magnitude, the implications are immediate and of high operative consequence.

The point of departure is the dual architecture of the environmental impact assessment system in Mexico. Article 28 of the General Law on Ecological Equilibrium and Environmental Protection (LGEEPA) establishes the catalog of works and activities subject to federal authorization: real estate developments affecting coastal ecosystems, works in wetlands and mangroves, changes in land use in tropical forests, and projects within or adjacent to Protected Natural Areas under federal jurisdiction. The delegation of jurisdiction to the federal entities over projects not included in that federal listing rests on two provisions that must be read jointly: article 7 section III of the LGEEPA, which constitutes the affirmative grant of competence to the states to evaluate works and activities not reserved to the federation, and article 35 BIS 2 of that same law, which governs the procedural regime applicable to those state evaluations. Omitting the reference to article 7 section III when invoking the jurisdiction of SEMA generates an incomplete citation that may be exploited by whoever argues that state competence is not properly founded against a possible claim of federal competence by SEMARNAT; consequently, when reference is made to the basis of SEMA’s jurisdiction, the complete citation is articles 7 section III and 35 BIS 2 of the LGEEPA. In Quintana Roo, that second level of evaluation is exercised through SEMA in accordance with the Law on Environmental Protection of the State of Quintana Roo (LPAEROO) and its Regulation on Environmental Impact.

The practical relevance of this duality is immediate: a medium-scale residential development in the Riviera Maya that does not directly modify mangroves nor is located within a federal Protected Natural Area may evade the jurisdiction of SEMARNAT, but not that of SEMA. The state resolution, far from being a minor formality, is an act of authority susceptible to amparo by the developer, by third parties with legitimate collective interest, and by environmental organizations. The legislative modifications that the constitutional mandate of 2025 imposes will radically reconfigure the procedural possibilities of each of those actors.

The Reform to the Amparo Law Derived from the Constitutional Mandate of 2024-2025: Structure of the Normative Change

The constitutional reform published in the DOF on September 15, 2024, which modified, among others, articles 94 to 107 of the Political Constitution of the United Mexican States, imposed on Congress the obligation to adapt the Amparo Law, Regulatory of Constitutional Articles 103 and 107. The legislative projects for adaptation in circulation at the close of this article contemplate three first-order modifications for environmental-real estate litigation, which are analyzed below as expected modifications in accordance with the current constitutional mandate.

The Categorical Restriction on Suspension in Environmental Matters

Article 128 of the Amparo Law, in its current text, establishes as a condition for the granting of suspension—both provisional and definitive—that no harm be caused to the social interest nor that provisions of public order be contravened. Article 129 contemplates situations of mandatory suspension. The expected modifications to this structure, consistent with the constitutional mandate and with the legislative projects in circulation, would expressly and enumeratively broaden the hypotheses in which suspension per se is deemed to contravene public order. Categorical inclusion would extend to orders for closure or suspension of works issued by competent environmental authorities when the challenged act involves damage to mangroves—whose protection has had quasi-absolute status since the reform to article 60 TER of the LGEEPA—and to high-biodiversity ecosystems within the polygon of the Mesoamerican Reef System.

With respect to buffer zones of cenotes and biological corridors recognized in ecological planning programs, their protection does not currently derive from a specific Mexican Official Standard for cenotes as an autonomous instrument—no such NOM exists at the close of this article—but rather from an articulated set of instruments: article 88 of the National Waters Law, which classifies federal zones of water bodies and their banks; hydrological classification resolutions issued by the National Water Commission (CONAGUA) regarding the cenote system in the state of Quintana Roo as federal water heritage; and the applicable Ecological Planning Programs, in particular the Regional Ecological Planning Program for the North Coast of the State of Quintana Roo. The legislative projects for adaptation of the Amparo Law refer generically to ecosystems protected by federal normative instruments and planning programs, without citing a specific NOM for cenotes, which confirms that precautionary protection in this matter is constructed upon that normative set and not upon a single normative instrument.

The expected practical effect is the reversal of the weighing standard: where today the developer has access to an almost automatic provisional suspension while demonstrating imminent harm to their project, with the anticipated modifications they will bear the burden of proof that individual harm exceeds in magnitude and irreversibility the collective environmental interest. Given the evidentiary difficulty that such standard entails, suspension would become for developers an exceptionally difficult remedy to obtain when the challenged act originates from SEMA or SEMARNAT regarding sensitive ecosystems.

The Scope of Collective Legitimate Interest Post-Reform

Article 107, section I, of the Constitution, in its text current since the 2011 reform that introduced legitimate interest as a broad standing standard, has been interpreted by the First Chamber of the SCJN in the sense that environmental organizations and communities with territorial presence in the area of influence of a project have legitimate interest to challenge the MIA approved in favor of the developer. The expected legislative adaptation would consolidate this interpretation in the express text of the Amparo Law through modifications to article 5 section III, eliminating the uncertainty that subsists regarding the appropriateness of the suit in these situations and reducing the threshold for accreditation of the differentiated impact required by the jurisprudence of the Pleno of the SCJN.

The First Collegial Court in Administrative and Civil Matters of the Twenty-Seventh Circuit, with seat in Cancún, has constructed a consistent line of criteria recognizing the active standing of ejidos, coastal communities and civil organizations to challenge in amparo the MIA resolutions that affect the cenote system of the Tulum-Cobá corridor and the coastal zones of the Cancún-Playa del Carmen corridor. The legislative adaptation derived from the 2024 constitutional mandate would convert that circuit jurisprudence into express legal mandate, with the consequent risk of multifrontal challenges against projects that already have approved MIA.

Doctrinal Perspective: Three Positions that Frame the Debate

This section is deliberately placed before the analysis of operational risks because the doctrinal positions described constitute the intellectual framework that explains why the legislator made the normative choices it made, and allow anticipation of how judges will read the new precautionary structure when developers litigate suspensions.

Héctor Fix-Zamudio, in his seminal work on the Mexican amparo trial, constructed the suspension as an instrument of preventive justice inseparable from the right of access to justice enshrined in constitutional article 17: without effective provisional relief, amparo becomes an illusory remedy that arrives too late. Eduardo Ferrer Mac-Gregor, in his comparative analysis of Latin American amparo, has identified the tension between effective provisional relief and public order restrictions as the unresolved node of the region’s constitutional control systems, warning that the categorical expansion of the concept of “social interest” as a bar to suspension erodes the protective nature of amparo without offering compensatory procedural guarantees. Arturo Zaldívar Lelo de Larrea, in his analysis on the constitutionalization of amparo, cautioned that the legislative use of absolute presumptions of affectation to public order —instead of case-by-case balancing— sacrifices effective judicial protection in favor of an automatic application policy that judges cannot nuance.

From the environmental law perspective, José Juan González Márquez has held that the efficacy of the Mexican system of environmental responsibility depends precisely on the fact that closure measures and Environmental Impact Assessment resolutions cannot be neutralized by amparo during their challenge, given that environmental damage is frequently irreversible and not susceptible to specific performance once consummated. This position, articulated from the environmental academic sphere, is what the 2025 legislator appears to have adopted as a normative premise, although without incorporating the compensatory mechanisms that González Márquez himself considers necessary for system balance.

Understanding this doctrinal debate is indispensable for the litigant advising a developer not only to argue the individual case, but to anticipate the interpretive framework from which the judge of the Twenty-Seventh Circuit will read the suspension request, calibrating whether the court will lean toward the position of Fix-Zamudio and Ferrer Mac-Gregor —favorable to provisional relief as a guarantee of access to justice— or toward the position of González Márquez, which the legislator incorporated as a normative premise.

The SEMA Resolution as a Vulnerable Act of Authority: The New Risk Map

The environmental impact resolution issued by SEMA is, from the amparo perspective, a definitive administrative act of authority that creates, modifies, or extinguishes rights of the developer. Before the reform, the developer could use amparo —and the suspension derived from it— as both an offensive tool (to challenge a denial or excessive conditioning) and a defensive one (to protect the favorable resolution against third-party challenges). The modifications arising from the 2024-2025 constitutional mandate affect both dimensions.

On the offensive plane, the developer’s challenge against an unfavorable SEMA resolution remains viable, but the suspension of the challenged act —which would allow him to continue advancing the project while amparo is resolved— will face the new standard of reformed article 128. On the defensive plane, the developer’s capacity to resist the challenge to his favorable Environmental Impact Assessment by third parties will be reduced because the reform will also limit suspension mechanisms in that context: once an amparo suit by a community or NGO is admitted, the developer faces the risk that the judge will opt not to grant suspension in his favor and leave the operative validity of the resolution in legal uncertainty throughout the entire procedure.

This vulnerability has cascading consequences: the municipalities of Benito Juárez, Solidaridad, Puerto Morelos, Tulum, and Bacalar condition the validity of construction licenses on the legal subsistence of the Environmental Impact Assessment resolution. An amparo pending resolution against the Environmental Impact Assessment, without definitive suspension that preserves the status quo, can de facto paralyze the developer’s capacity to build, even if the project has all other permits in order.

Comparative Analysis: The Brazilian and Colombian Models as a Predictive Mirror

Latin American comparative law offers two especially relevant experiences to anticipate the direction that post-reform Mexican jurisprudence will take.

Brazil adopted, through CONAMA Resolution 237/1997 and Complementary Law 140/2011, a tripartite environmental licensing system—federal (IBAMA), state, and municipal—that replicates the logic of the dual-window system of the Mexican system. The jurisprudence of the Superior Court of Justice has consolidated the principle that environmental licenses do not generate vested rights when issued in violation of environmental protection standards, making them susceptible to revocation without right to compensation except in cases of fraud or negligence by the administration. More relevant to the precautionary matter: the Code of Civil Procedure (Law 13.105/2015), in articles 300 to 310, requires for anticipated precautionary relief a demonstration of fumus boni iuris and periculum in mora, but the Public Civil Action Law (Law 7.347/1985) permits the Public Ministry and civil organizations to obtain preliminary injunctions suspending works with a markedly lower evidentiary standard when environmental damage is prima facie plausible. This dual standard—easy for environmental challengers, strict for developers—is precisely the balance that the Mexican constitutional mandate of 2024-2025 tends to replicate.

Colombia provides a second lesson from the constitutional sphere. Judgment T-622/2016 of the Colombian Constitutional Court, which recognized the Atrato River as a subject of rights, inaugurated a line of jurisprudence in which the precautionary principle—enshrined in Decree 1076/2015, Unified Regulatory Decree of the Environmental Sector—operates as sufficient grounds to suspend industrial or development activities without need to establish direct causality between the activity and the damage. The popular action established in Law 472/1998 has been recurrently used to suspend environmental licenses granted to tourism real estate projects on the Colombian Caribbean Coast, in a dynamic that will predictably reproduce itself in Quintana Roo once Mexican jurisprudence fully assimilates the new legal regime. The comparison is especially pertinent because the SCJN, through criteria of its First Chamber, has recognized the applicability of the precautionary principle in environmental matters as a parameter of constitutional review, bringing the Mexican model closer to the Colombian model even before the 2025 legislative mandate codified it.

The Five Concrete Operational Risks for Developers in Quintana Roo

1. Closures without automatic suspension: A work closure order issued by SEMA based on alleged non-compliance with the MIA resolution —a measure that has proliferated on the Tulum-Cobá and Playa del Carmen-Chemuyil axes— can no longer be provisionally neutralized through the nearly reflexive mechanism of indirect amparo. The developer must litigate the closure while the work remains paralyzed, bearing the financial and contractual costs this generates.
2. Third-party challenges with paralyzing effect: The expansion of collective legal interest and the restriction on suspension create a window in which an NGO can file an amparo against the favorable MIA resolution, obtain admission of its claim and, in the absence of suspension for the developer, generate uncertainty about the validity of the base act underlying the entire chain of permits during the time it takes the court to resolve.
3. Broken chain of municipal permits: Construction licenses in municipalities of Quintana Roo are granted conditioned on the validity of the MIA resolution. An impugned MIA without confirmatory suspension compromises the legal basis of the municipal license, exposing the developer to eventual nullity of derived permits.
4. Environmental responsibility with differentiated scope according to activity: The Federal Environmental Responsibility Law establishes a mixed liability regime that the legal operator must apply with precision. Article 6 of the LFRA distinguishes between objective liability and subjective liability: the former operates only when the developer’s activity is within the catalog of highly risky activities provided for in article 28 of that same law; for activities not listed in that catalog, liability requires proof of fault or negligence. This distinction is operatively critical for developers in Quintana Roo: many medium-scale residential projects in the entity do not qualify as high-risk activities under article 28 LFRA, which substantially modifies the risk calculation. That said, the developer who continues operations following a closure order —even if impugned and prima facie illegal— assumes the risk that its activity be classified as generating objective liability if it falls within the scope of article 28 LFRA, or subjective liability for the voluntary decision to continue despite the suspension order, without the eventual success in amparo automatically extinguishing such liability already accumulated.
5. Risk of dual federal-state challenge: Projects with components under federal jurisdiction (SEMARNAT) and components under state jurisdiction (SEMA) face two independent fronts of challenge. The precautionary restrictions of the 2025 reform mandate will apply to both jurisdictions —because amparo remains federal— without any coordination mechanism or unified suspension having been provided to shield the developer on both flanks simultaneously.

Normative Gaps: What the 2025 Reform Did Not Resolve

The reform presents significant gaps that generate additional legal uncertainty. First, it did not establish a mechanism for patrimonial liability of the State to compensate developers whose projects are paralyzed by closure orders that are subsequently annulled for illegality. Unlike the Colombian system —where Law 472/1998 expressly provides for patrimonial liability of the State when precautionary measures prove unfounded— the Mexican system lacks a robust mechanism for reparation of economic damage caused by illegal closures that lasted months or years while amparo was being processed.

Second, the reform did not resolve the jurisdictional ambiguity between SEMARNAT and SEMA in borderline projects. The SCJN has held, in criteria of its Plenary, that when a project has any functional connection with ecosystems of federal interest —including hydrological linkage with the cenote system, whose classification as federal water heritage has been recognized by the National Water Commission pursuant to article 88 of the National Waters Law— federal jurisdiction prevails. But that doctrine has not been codified, leaving developers in a gray area where both SEMA and SEMARNAT can claim jurisdiction, generating the risk of parallel challenges and contradictory resolutions.

Third, the reform remained silent on the treatment of projects with approved EIA before its entry into force. The principle of non-retroactivity established in article 14 of the Constitution in principle protects consolidated legal situations; however, the doctrine of the SCJN on procedural rules distinguishes between the affectation of substantive acquired rights—protected by article 14—and the immediate application of new procedural rules to ongoing proceedings, which Mexican jurisprudence has considered admissible insofar as it does not retroactively deprive of material rights already incorporated into the petitioner’s legal patrimony. This distinction, consistent with the general principle regarding procedural rules of immediate application that has been expressed in the doctrine of the Plenary and Chambers of the SCJN at various times in the Semanario Judicial de la Federación, means that an amparo petition filed by a developer before the entry into force of the reform may see the conditions of the suspension already granted modified if the court applies the new standard of article 128 to the pending proceedings. It must be cautioned, however, that it has not been possible to identify with verifiable certainty a number of theses or specific record in the Semanario Judicial de la Federación that establishes this criterion expressly for the suspension regime in environmental matters. The litigant requiring to sustain this point before the Twenty-Seventh Circuit must conduct a search of applicable theses in the Semanario Judicial de la Federación and its Digital Gazette, particularly under the headings of immediate application of procedural rules and temporal efficacy of reforms to the suspension regime, and cite the specific thesis or jurisprudence located, since an assertion without a verifiable thesis number is not sufficient as authority in the context of litigation.

Mitigation Strategy: Indispensable Operational and Procedural Adjustments

Faced with this new environment, developers with operations in Quintana Roo must adopt concrete adjustments that are no longer optional but a condition for the legal survival of the project.

The first line of defense is the technical soundness of the EIA file from its initial presentation. Given that suspension can no longer function as a procedural shield during challenge, the resolution must be unassailable in substance: complete impact studies, biodiversity sampling in accordance with NOM-059-SEMARNAT-2010, hydrological analyses of the cenote system with express reference to CONAGUA classifications under article 88 of the National Water Law, and specific and verifiable mitigation measures that anticipate the most foreseeable challenge arguments. The architecture of the file must be constructed from the outset with awareness that it will be examined by a judge of the Twenty-Seventh Circuit trained in the environmental legitimacy criteria that this Collegiate Tribunal has developed for the Tulum-Cobá corridor and the Cancún-Playa del Carmen coastal zone.

The second line is early management of the project’s social environment. Identifying, before initiating the EIA procedure, the ejidos, communities, environmental organizations and interest groups with presence in the area of influence of the development, and building with them mechanisms of genuine participation, significantly reduces the risk of challenges based on collective legitimate interest post-approval.

The third line is the review of construction, financing and development contracts to incorporate clauses for management of the risk of parallelization due to environmental causes: mechanisms for suspension of deadlines, distribution of losses from interruption not attributable to the parties, and protocols for response to closure orders that preserve the chain of responsibilities without exposing the developer to accumulated damages. This contractual review must also contemplate the distinction between strict liability—for activities listed in article 28 LFRA—and fault-based liability for the others, given that the allocation of risks in a real estate financing contract has different consequences depending on which regime of environmental liability is applicable to the specific project.

Finally, the administrative appeal procedure before SEMA—provided for in the Administrative Procedure Law of the State of Quintana Roo—and the administrative-contentious proceeding before the State Administrative Court of Justice retain their validity as alternative channels of challenge where the restrictions on the suspension of amparo do not operate with the same scope, although they also do not offer the most robust precautionary guarantees of the federal system.

IBG Legal has the technical capacity to accompany developers in each of these dimensions from an integrated perspective. In EIA matters, we advise on the architecture of the technical-legal file from the project prospecting stage, with specific attention to the environmental legitimacy criteria of the First Collegiate Court in Administrative and Civil Matters of the Twenty-Seventh Circuit that have established the case law line in the Tulum-Cobá corridor and in the coastal strip of the Mexican Caribbean, so that the decision has sufficient strength to withstand challenges by collective legitimate interest without depending on suspension as a containment mechanism. In contractual matters, we structure construction and financing contracts incorporating risk management clauses for environmental paralysis—including the calibration between the regime of strict liability under article 28 LFRA and the regime of fault-based liability for activities outside that catalog—so that the contractual chain does not collapse before a closure order or before an EIA challenge in process. In matters of jurisdictional conflicts, we navigate the gray area between SEMARNAT’s jurisdiction and SEMA’s jurisdiction in borderline projects—especially those with hydrological linkage to the cenote system classified by CONAGUA under article 88 of the National Waters Act—building the jurisdictional foundation strategy that shields the project against a concurrent federal jurisdiction claim. With offices in Cancún and branches in Mexico City and Querétaro, we serve national and international clients in the structuring, defense, and recovery of projects exposed to the new risks of the post-reform regulatory environment. For specialized advice, contact us.

Sources and References

Federal Legislation

• Political Constitution of the United Mexican States: articles 4 (fifth paragraph, right to a healthy environment), 14 (non-retroactivity and due process), 16 (acts of harassment), 17 (effective judicial protection), 25 (economic steering), 27 (property and land regime), 103 and 107 (amparo), in its text in force following the September 2024 reform.
• Decree reforming, adding and repealing various provisions of the Political Constitution of the United Mexican States, regarding judicial branch reform: published in the Official Gazette of the Federation on September 15, 2024. This decree constitutes the constitutional mandate requiring Congress to adapt the Amparo Law. The decree reforming the Amparo Law derived from this mandate has not been identified with a decree number and verifiable publication date as of the closing of this article; references to modifications to articles 128, 129 and 5 section III of the Amparo Law correspond to expected modifications in accordance with legislative projects in circulation and shall be confirmed against the official text once published in the DOF.
• Amparo Law, Regulatory of Articles 103 and 107 of the Political Constitution of the United Mexican States (published in DOF on April 2, 2013, with subsequent reforms): articles 1, 5 section III (collective legitimate interest), 61 (grounds for inadmissibility), 107 (requirements for suspension), 127 to 138 (suspension regime), 170 to 172 (amparo in administrative matters).
• General Law on Ecological Balance and Environmental Protection (LGEEPA): article 7 section III (affirmative grant of competence to states to evaluate works and activities not reserved to the federation); article 28 (works and activities subject to federal Environmental Impact Assessment); article 30 (content of the statement); article 35 (SEMARNAT resolution); article 35 BIS (conditions and denial); article 35 BIS 2 (procedural regime applicable to state evaluations, in conjunction with article 7 section III); article 60 TER (absolute protection of mangroves). Note: to establish the jurisdiction of SEMA, the complete citation is articles 7 section III and 35 BIS 2 of the LGEEPA; omitting article 7 section III generates incomplete legal foundation.
• Regulation of the LGEEPA on Environmental Impact Assessment: articles 5 (works and activities in coastal zones), 9 (minimum content), 13 (Environmental Impact Assessment modalities).
• Federal Law on Environmental Liability (published in DOF on June 7, 2013): article 6 (mixed liability regime: strict for activities in the article 28 catalog, fault-based for others) and article 28 (catalog of highly risky activities as prerequisite for strict liability). Precision note: the regime is not uniformly strict; the distinction between article 6 and article 28 FLEL is operationally critical to determine whether strict liability applies to a specific project or whether proof of fault or negligence is required.
• National Waters Law: article 88 (classification of federal zones of water bodies and their banks, basic instrument for protection of the cenote system in Quintana Roo in the absence of a specific NOM for cenotes).
• NOM-059-SEMARNAT-2010: Environmental protection, native species of Mexican flora and fauna, risk categories and specifications for their inclusion.
• NOM-022-SEMARNAT-2003: Establishing specifications for the preservation, conservation, sustainable use and restoration of coastal wetlands in mangrove zones.

State Legislation — Quintana Roo

• Law on Environmental Protection of the State of Quintana Roo (LPAEROO): provisions relating to state Environmental Impact Assessment and the powers of SEMA.
• Regulation on Environmental Impact of the State of Quintana Roo.
• Administrative Procedure Law of the State of Quintana Roo: provisions on administrative remedies and precautionary measures in the administrative forum.
• Regional Ecological Planning Program for the Northern Coast of the State of Quintana Roo (POERTC): territorial planning instrument with effects on the admissibility and conditions of state Environmental Impact Assessment; one of the basic regulatory instruments for the protection of biological corridors and cenote buffer zones in the absence of a specific NOM.

Mexican Judicial Criteria

General note on thesis citation: The criteria of the SCJN and the Twenty-Seventh Circuit are identified below with a description of their content and, where the data could be verified with certainty, with reference to the body and period. For theses whose registration number in the Judicial Bulletin of the Federation and Digital Gazette could not be verified with certainty as of the closing of this article, this circumstance is expressly indicated. The litigant who requires citing these theses in judicial proceedings shall verify and complete the registration numbers in the Digital Judicial Bulletin of the Federation (sjf.scjn.gob.mx) under the rubrics indicated. Generic descriptions without verifiable thesis number do not constitute a functional citation for litigation purposes.

• First Chamber of the SCJN: criteria regarding collective legal interest in environmental matters, recognizing the active legitimation of communities and civil organizations to challenge acts of environmental authority that affect their environment. Developed primarily in the Tenth Epoch of the Federal Judicial Gazette. Thesis number and specific registration pending verification in SJF Digital; search under the heading: COLLECTIVE LEGAL INTEREST, ENVIRONMENTAL MATTERS, CIVIL ORGANIZATIONS.
• Plenary of the SCJN: jurisprudence on the application of the precautionary principle in environmental matters as a parameter for constitutional and conventional control. Tenth Epoch. Thesis number and specific registration pending verification in SJF Digital; search under the heading: PRECAUTIONARY PRINCIPLE, ENVIRONMENTAL MATTERS, CONSTITUTIONAL CONTROL.
• Plenary of the SCJN: criteria regarding jurisdictional conflicts between federal and state environmental authorities in ecosystems of federal interest, including the doctrine of prevalence of federal jurisdiction when there exists functional connection with the hydrological system of cenotes classified by CONAGUA. Thesis number and specific registration pending verification in SJF Digital; search under the heading: ENVIRONMENTAL JURISDICTION, FEDERAL-STATE CONFLICT, ECOSYSTEMS OF FEDERAL INTEREST.
• First Chamber of the SCJN and Plenary: criteria on immediate application of procedural norms to proceedings in course, in the context of constitutional article 14 and the distinction between substantive acquired rights and procedural norms of immediate efficacy. Criterion present in various theses of the Ninth and Tenth Epochs. Thesis number applicable to the suspension regime in environmental matters pending verification in SJF Digital; search under the heading: PROCEDURAL NORMS, IMMEDIATE APPLICATION, PROCEEDINGS IN COURSE, SUSPENSION IN AMPARO. Warning for litigants: it has not been possible to identify with certainty a thesis number or registration that establishes this criterion specifically for the suspension regime in environmental matters; the assertion of immediate application must be supported by the specific thesis that is located in the aforementioned search.
• First Collegiate Court in Administrative and Civil Matters of the Twenty-Seventh Circuit (Cancún): criteria regarding environmental legitimation in the Tulum-Cobá cenotes corridor; criteria regarding legitimation of coastal communities to challenge EIA resolutions in the Cancún-Playa del Carmen corridor. Criteria developed in the Tenth and Eleventh Epochs of the Federal Judicial Gazette. Thesis numbers and specific registrations pending verification in SJF Digital; search under the headings: TWENTY-SEVENTH CIRCUIT, ENVIRONMENTAL LEGAL INTEREST, ENVIRONMENTAL IMPACT STATEMENT, COASTAL COMMUNITIES.

Comparative Legislation and Jurisprudence

• Brazil: Public Civil Action Law (Law 7.347/1985); Civil Procedure Code (Law 13.105/2015), articles 300-310 (anticipated cautionary relief); CONAMA Resolution 237/1997; Complementary Law 140/2011 (concurrent environmental jurisdictions and tripartite system of environmental licensing).
• Colombia: Political Constitution of Colombia, article 86 (tutela action); Law 472/1998 (popular action and patrimonial liability of the State for unfounded precautionary measures); Decree 1076/2015 (Single Regulatory Decree of the Environmental Sector, precautionary principle); Constitutional Court of Colombia, Judgment T-622/2016 (Atrato River — subject of rights; application of the precautionary principle as autonomous grounds for suspension of development activities).

Legal Doctrine

• Fix-Zamudio, Héctor: The Amparo Judgment. Editorial Porrúa, México. Reference work on suspension as an instrument of preventive justice inseparable from the right of access to justice under constitutional article 17; argument that without effective interim relief the amparo becomes an illusory remedy.
• Ferrer Mac-Gregor, Eduardo y Fix-Zamudio, Héctor: The Right of Amparo in the World. Editorial Porrúa / UNAM, México. Comparative analysis on effective interim relief, public order restrictions and the erosion of the protective nature of amparo through categorical expansion of the concept of social interest.
• Zaldívar Lelo de Larrea, Arturo: Toward a New Amparo Law. UNAM, México. Critical analysis of absolute presumptions of public order affectation as a restriction to suspension and their compatibility with constitutional article 17; warning about the sacrifice of effective judicial protection through automatic application policies that judges cannot modulate.
• González Márquez, José Juan: Liability for Environmental Damage in Mexico. UAM / Grupo Editorial Miguel Ángel Porrúa, México. Doctrinal basis for interim relief restriction in environmental closure matters; argument that the irreversibility of environmental damage justifies that closure measures not be neutralized by amparo during their challenge, without prejudice to the need for compensatory mechanisms for system balance.
• Ferrer Mac-Gregor, Eduardo (coord.): The Amparo Judgment in the World. UNAM, México. Comparative perspective on the design of restrictions to interim relief amparo in Latin American constitutional control systems.

Official Sources and Planning Instruments

• Official Gazette of the Federation: Constitutional Reform Decree on Judicial Power, September 15, 2024. Full text available at dof.gob.mx.
• National Water Commission (CONAGUA): cenote hydrological system classification resolutions in Quintana Roo as federal water patrimony, issued in accordance with article 88 of the National Waters Law. Instrument