Jaguar Park Built Without Environmental Permits

TULUM — The Ministry of Environment and Natural Resources (Semarnat) has confirmed that the Ministry of Agrarian, Territorial and Urban Development (Sedatu) carried out the construction of the infrastructure for the Jaguar Park in Tulum without having obtained an environmental authorization. This permit was only just issued in July 2025, nearly a year after the works were completed within the Protected Natural Areas of the Tulum National Park and the Jaguar Flora and Fauna Protection Area.

The request for authorization, accompanied by the Environmental Impact Statement (MIA) that supports the construction of complementary areas—such as access portals, interconnections, walkways, a bike path, a lookout point, walls, service modules, and sanitary facilities—was submitted by Sedatu on July 30, 2023. However, Semarnat did not grant the authorization until July 30, 2025. In contrast, the construction work began in August 2022 and was delivered in September 2024.

Authorization Granted Extemporaneously

This information is contained in the Ecological Gazette published by Semarnat last week. The transaction record indicates that the process, which lasted two years, was suspended at least once and was delayed due to requests for additional information from Sedatu. The evaluation period also had to be extended, with the final stage of the process completed in July of this year.

The resolution further states that the works were carried out with provisional permits covered by the so-called "decretazo" (big decree) of President Andrés Manuel López Obrador. During the processing of the permit, Sedatu informed Semarnat that the construction had already concluded.

Another notable point is that Semarnat authorized the operation and maintenance of the infrastructure for 40 years, not the 99 years that were requested. Any extension is conditional upon compliance with the stipulations imposed in the extemporaneous authorization. These include adhering to all prevention, mitigation, and compensation measures proposed by Sedatu itself, as well as other corrections indicated by the National Commission of Natural Protected Areas (CONANP) following the conclusion of the works.

Furthermore, Semarnat warned Sedatu that it is not exempt from processing and obtaining a change of land use for forested terrain affected by its works, as this authorization does not cover that requirement.

Construction Under Provisional Permits

While the evaluation of the MIA took two years, the Jaguar Park Master Plan project was executed without the definitive environmental authorization, protected by President López Obrador's "decretazo." This decree allowed federal agencies to obtain provisional permits to advance the federal government's strategic works, citing public interest and national security, while the definitive environmental authorizations were being processed.

Sedatu did precisely that, commencing work in August 2022 with provisional permits issued by Semarnat under the cover of López Obrador's decree. These permits were extended in March and May of 2023 to include more works. The formal environmental request with the corresponding MIA attached was finally submitted on June 30, 2023, and was resolved extemporaneously on July 30, 2025, with notification sent to Sedatu on August 8.

"The works carried out with provisional permits consist of: south access, service modules and bike path on Cobá Avenue; trails and internal mobility in the south zone; beach accesses and equipment in the south zone; service center and equipment in the north zone; trails and internal mobility in the north zone; and perimeter walls," the authorization specifies.

Project Cost and Public Discontent

The estimated investment for the project was 1.6 billion pesos, including taxes, to be implemented through a conventional public works investment scheme with an expected completion time of 18 months. However, upon completion of the works, Sedatu reported that more than 2.7 billion pesos had been spent.

The environmental authorization for the complementary works of the Jaguar Park is published at a time of significant discontent in Tulum among both residents and national and international tourists. This is due to the high fees imposed by the Jaguar Park administration for access. These fees are now not only for the park's infrastructure but are also conditional for those who merely wish to visit the Tulum archaeological zone or the beaches of the Tulum National Park. Costs can reach up to 255 and 600 pesos for national and foreign visitors, respectively, as since August, payment for the entire package is mandatory.

Arbitrary Fees and Operational Justification

This situation arises because the public company Grupo Aeroportuario, Ferroviario, Servicios Auxiliares y Conexos Olmeca-Maya-Mexica (GAFSACOMM), dependent on the Ministry of National Defense (Sedena) and now operating under the brand Grupo Mundo Maya, established its own additional fees on top of those charged for access to the archaeological zone and the Tulum National Park. The company argues that these fees cover maintenance for the Jaguar Park's infrastructure of walkways, lookouts, bridges, and services. However, these fees are considered arbitrary as they are set unilaterally and are not regulated by the Law of Fees, unlike those for the archaeological zone and the Tulum National Park.

For its part, Sedatu justified this investment in infrastructure and equipment as an opportunity to protect the Mayan biocultural heritage and jaguar habitat—a heritage with high natural value due to the diversity of its ecosystems, safeguarding the migratory movements of endemic species. It was also presented as a conservation mechanism to contain urban expansion into areas of environmental value, specifically irregular settlements aimed at tourism, mitigating the gradual privatization of beaches through public spaces, with a focus on sustainability and human rights.

Scope of the Authorized Works

The extemporaneous authorization covers the following architectural elements: A first element consists of the access on the south side of the Jaguar Park, which is a roofed, open, and semi-open portal developed along the two urban fronts of the property facing Cobá Avenue and Costera Avenue, housing most of the constructed services.

The services housed within this portal include: ticket offices, information modules, commercial premises, operational offices, offices for the Navy and security, a nursing station, public bathrooms, family bathrooms, lockers, drinking fountains, and commercial premises of various types.

A second element is a tower-lookout that functions as a landmark and an ascending gallery to identify the access to the Tulum National Park; the lookout consists of five levels with views of the sea and the project area.

A third element is a large interior cover that serves to roof and provide waiting space for visitors. It begins at the corner with the tower and culminates as a large open lookout facing the Tulum National Park.

The authorization also includes the construction of a segregated, unidirectional bike path on Cobá Avenue (2.10 meters wide), with 1.8 kilometers of cycling roadway, which will also feature a pedestrian walkway (1.70 m wide) and a buffering zone with vegetation (a 1.30 m wide planter).

Similarly, it contemplates the construction of two service modules (A and B) or habitable walls on Cobá Avenue.

Also included is the repaving of a section of Costera Avenue to improve vehicular access to the archaeological zone, hotels, and beaches on the coastal strip, and a module for access to Mangle, Maya, Pescadores, Santa Fe, and Faro Mirador beaches. Additionally, it covers the construction of a sacbé-type trail at the South Lookout, the remediation of the Lighthouse, and the construction of a new access building to the archaeological zone.

Other works on the north side include a bridge where the old Tulum airstrip was located, service modules, pedestrian trails, and perimeter walls.