Dear Members of the Tribunal:

Renco respectfully requests that the Tribunal (i) reinstate that portion of its December 18, 2014 Decision on the scope of Article 10.20(4) which required Peru to bring its preliminary objections on the Tribunal’s competence together with its Counter-Memorial on Liability in accordance the timetable set out in Annex A to Procedural Order No. 1, and in doing so, (ii) reconsider that portion of its June 2, 2015 Decision Regarding Respondent's Requests for Relief, in which the Tribunal reversed its prior ruling with respect to Respondent's jurisdictional “waiver” objection.

I. Summary Overview

On December 18, 2014, the Tribunal issued its Decision on the Scope of Article 10.20.4 (the “Scope Decision”) in which the Tribunal noted that Respondent sought to bring its jurisdictional objections as a preliminary questions pursuant to Article 10.20.4 of the Treaty, or alternatively, pursuant to Article 23(3) of the UNCITRAL Rules. (see, e.g., Scope Decision, ¶85: "[T]he Respondent requests that the Tribunal determine all of its preliminary objections under the authority granted to it by Article 10.20(4) of the Treaty or, alternatively, pursuant to Article 23(3) of the UNCITRAL Arbitration Rules.").