Suspension of legal terms for federal energy and environmental authorities

Yesterday, the Federal Ministry of Environment and Natural Resources ("SEMARNAT") published in the Federal Official Gazette the "Agreement by which is informed the days that will be considered as non-business days for administrative acts and procedures before the Federal Ministry of Environment and Natural Resources and its administrative-decentralized agencies.” ("Agreement").


The Agreement provides that, due to force majeure events arising from the COVID-19 pandemic, all days from March 23 to April 17, 2020 are considered non-business days. Note that this does not entail a suspension of everyday activities at SEMARNAT.


During the mentioned days, legal terms will not be computed for administrative acts and procedures initiated before SEMARNAT and its administrative decentralized agencies (National Water Commission, Federal Environmental Protection Agency, National Commission for Protected Natural Areas, National Commission for the Knowledge and use of Biodiversity and the National Institute of Ecology).


Likewise, in yesterday’s evening version of the Federal Official Gazette, the Energy Regulatory Commission (“CRE”) published the “Agreement number A/010/2020 providing the suspension of deadlines and legal terms in the Energy Regulatory Commission” which, also suspends the legal terms for all procedures and acts initiated before the CRE, from the publication of the agreement until April 17, 2020.


Furthermore, the National Forestry Commission published today in the Federal Official Gazette the "Agreement by which it is established the days of March and April 2020, which will be considered as non-business days for the referred acts and procedures”, such agreement provides that for administrative acts and procedures related to appeal procedures, administrative terminations, patrimonial claims, and procedures of the Forestry Sustainable Development General Law (Land Use Change on Forestry Lands), will not be considered as business days from March 23 to April 17, 2020.


Finally, the Ministry of Energy ("SENER"), and the National Hydrocarbons Commission ("CNH"), published in the website of the Federal National Commission for the Administrative Improvement the projects of the agreements where all the days up until April 17, 2020, will be considered non-business days and thus, legal terms will not be computed.


SENER’s and CNH’s agreement drafts have not been published in the Federal Official Gazette. We will follow up and promptly inform when that happens, and such agreements enter into force.


To obtain additional information contact our experts:


Edmond Grieger, Partner: +52 (55) 5258 1048 | egrieger@vwys.com.mx


Rebeca Márquez, Associate: +52 (55) 5258 1048 | rmarquez@vwys.com.mx


Roberto Flores, Associate: +52 (55) 5258 1048 | rflores@vwys.com.mx