2.

3 Tools of interpretation: Referring to principles set forth by the European Court of Human
Rights
To support its use of the proportionality test in determining whether the Environmental Protection
Agency’s decision not to renew the Permit effected an expropriation, the TecmedTribunal relied
entirely on four different decisions of the European Court of Human Rights (paras. 122–123). This
approach signals that tribunals can look to and rely upon other fields of law, such as human rights,
labour law and environmental law, when relevant to interpreting parties’ rights and obligations
under international investment agreements.