a. Fundación Pachamama (Pachamama) is an Ecuador-based autonomous indigenous organization, independent of political parties, or any State, foreign or religious institution. Since 1997, Pachamama has been working to promote of alternative models of development based on recognition and respect of human rights and the environment in order to generate the conditions necessary for the indigenous peoples of the Ecuadorian Amazon and other groups in the Andean Region to preserve their traditional ways of life and strengthen their processes of self-determination. In furtherance of these goals, Pachamama has assisted indigenous communities to develop their administrative capacities, demarcate their traditional lands, and articulate their developmental goals. It has also supported international and domestic legal cases to promote indigenous people's rights. More information on Pachamama can be found in Spanish at http://pachamama.org.ec/.; and
b. The International Institute for Sustainable Development (IISD) is a Canadian-based international NGO with a mandate to foster local, regional, and international policies and practices in support of the achievement of sustainable development. IISD has been actively engaged in international trade law issues since 1991 and investment law issues since 1998. With respect to investment law, IISD is primarily concerned with the relationship between international investment agreements and sustainable development. The rights of local communities to use domestic courts to help safeguard the environment is a key element in promoting safe investor conduct, and hence directly relevant to promoting sustainable investments. IISD has intervened previously in investor-State arbitrations, including the first amicus curiae petition accepted in Methanex Corp v United States (NAFTA), and its amicus submissions in that case were expressly cited with approval by the tribunal Most recently, IISD filed an amicus submission in Biwater v Tanzania (ICSID), which also drew significant references in the final award. IISD is currently engaged in advising developing countries on international investment law negotiations, training on investment law, as well as working on a next generation of international investment agreements. More information can be found at www.iisd.org.
1.2. The Petitioners [...] seek the following orders:
1. Leave to file a written submission with the Tribunal regarding matters within the scope of the dispute. This submission is attached for immediate consideration;
2. Permission to attend and present the Petitioners’ submission at the oral hearings when they take place, or in the alternative, attend the oral hearings as observers or to reply to any specific questions of the Tribunal on the written submission; and
3. In order to make the preceding order effective, access to the key arbitration documents, subject to the redaction of any commercially confidential or otherwise privileged information that is not relevant to the concerns of the Petitioners as non-disputing parties.
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