PULP MILLS (JUDGMENT) 28 22. In its Application, the following claims were made by Argentina : “On the basis of the foregoing statement of facts and law, Argentina, while reserving the right to supplement, amend or modify the present Application in the course of the subsequent procedure, requests the Court to adjudge and declare : 1. that Uruguay has breached the obligations incumbent upon it under the 1975 Statute and the other rules of international law to which that instrument refers, including but not limited to : (a) the obligation to take all necessary measures for the optimum and rational utilization of the River Uruguay ; (b) the obligation of prior notification to CARU and to Argentina ; (c) the obligation to comply with the procedures prescribed in Chapter II of the 1975 Statute ; (d) the obligation to take all necessary measures to preserve the aquatic environment and prevent pollution and the obligation to protect biodiversity and fisheries, including the obligation to prepare a full and objective environmental impact study ; (e) the obligation to co-operate in the prevention of pollution and the protection of biodiversity and of fisheries ; and 2. that, by its conduct, Uruguay has engaged its international responsibility to Argentina ; 3. that Uruguay shall cease its wrongful conduct and comply scrupulously in future with the obligations incumbent upon it ; and 4. that Uruguay shall make full reparation for the injury caused by its breach of the obligations incumbent upon it. Argentina reserves the right to amplify or amend these requests at a subsequent stage of the proceedings.” 23. In the written proceedings, the following submissions were presented by the Parties : On behalf of the Government of Argentina, in the Memorial : “For all the reasons described in this Memorial, the Argentine Republic requests the International Court of Justice : 1. to find that by unilaterally authorizing the construction of the CMB and Orion pulp mills and the facilities associated with the latter on the left bank of the River Uruguay, in breach of the obligations resulting from the Statute of 26 February 1975, the Eastern Republic of Uruguay has committed the internationally wrongful acts set out in Chapters IV and V of this Memorial, which entail its international responsibility ; 2. to adjudge and declare that, as a result, the Eastern Republic of Uruguay must : (i) cease immediately the internationally wrongful acts referred to above ; (ii) resume strict compliance with its obligations under the Statute of the River Uruguay of 1975 ; 18