Extension of Term Granted to Submit the Procedure for the Extension of Concession Titles, Assignment and / or Download Permits.

Holders of a concession title, assignment or discharge permit, who intend to conserve the rights of exploitation, use or exploitation of national waters, must apply to the National Water Commission for an extension of the respective discharge titles or permits for what at least six months in advance of their expiration, through the procedure identified as "CONAGUA-01-021".

However, as is generally known, since March of this year, it was declared a health emergency due to force majeure to the pandemic caused by the SARS-CoV2 virus (COVID-19), therefore, with the aim of preventing the spread of said virus, as well as avoiding the agglomeration of people in various Federal Public Administration Dependencies, including the National Water Commission, from March 23 to August 24 of this In a year, legal terms and deadlines were suspended to carry out procedures that were not considered essential by said Commission, that is, the aforementioned period was considered non-working.

Derived from the above, during this period, more than 3,000 titles and permits expired, so on September 7, 2020, the “Agreement by which the term for the presentation of the procedure CONAGUA-01-021 Extension of concession titles, assignment and / or discharge permits, which during the indicated period expired the term contained in article 24 of the National Water Law ”.

In this sense, through the agreement in question, the General Director of the Ministry of Environment and Natural Resources grants to the individuals affected by the impossibility of presenting the CONAGUA-01-021 procedure, an extension of the term to present said procedure until the October 30 of this year for the purpose of conserving the rights that have been granted to them through concession titles, assignment or discharge permits to exploit, use or take advantage of national waters.

Therefore, it is possible to consider that, the National Water Commission must resolve in a favorable sense the procedure "CONAGUA-01-021", which is promoted by individuals during the extension of the term granted, without making any kind of objection due to extemporaneity issues. of the presentation of the process in question, being that as has already been commented, due to the suspension of the Commission's work, it was impossible to carry out the process of requesting the extension of concession titles, assignment and discharge permits during the period considered as unskilled for that purpose.

By virtue of the foregoing, the BRIFFAULT ABOGADOS, SC team is at your service to provide appropriate and timely advice in relation to all the procedures and administrative acts carried out by the National Water Commission regarding said procedures, which it is considered that they may cause damage in the exploitation, use and use of national waters, as well as the development of means of defense against any act of abuse by said authority.