Acompanhamento de impactos ambientais: avaliação da etapa de follow-up na regional Sul de Minas Gerais

Abstract

The monitoring stage of the Environmental Impact Assessment (EIA) in Brazil, or follow-up stage, as used in this research, is still seen in the scientific community as the weakest area of the EIA instrument and one that needs to overcome limitations, such as an insufficient workforce to meet the demands and deficits in the environmental authorities' action strategies. With this in mind, the state of Minas Gerais implemented the Núcleo de Controle Ambiental (NUCAM) in September 2016, generating expectations among the staff of the Secretaria de Estado de Meio Ambiente e Desenvolvimento Sustentável (SEMAD) about improvements in this intrinsic stage of the EIA process. Some time after its creation, questions have arisen as to how NUCAM has been working and whether it has been able to correct the limitations pertinent to the follow-up stage in the Minas Gerais environmental agency, as well as whether it has been able to guarantee effective monitoring of projects in accordance with good EIA practices. This is the context of this research, which aims to evaluate the practice of EIA follow-up of hydroelectric projects conducted under the responsibility of the Superintendência Regional de Meio Ambiente do Sul de Minas Gerais (SUPRAM SM), in order to identify the main challenges and contributions to the use of international good practices. The major scientific contribution of the research lies in the evaluation of the follow-up stage in terms of the following dimensions: (i) monitoring; (ii) evaluation; (iii) management; (iv) engagement and communication; and (v) governance. This has not yet been done in the Brazilian context or in the state of Minas Gerais. The method chosen involves triangulating data between the selection of ten case studies, analysing documents and comparing the information with 22 specific criteria to assess the conduct of follow-up and a semi-structured questionnaire applied to the coordinator of NUCAM at SUPRAM Sul de Minas to supplement the information. As a result, the research shows that the follow-up stage of hydroelectric projects licensed by SUPRAM SM is not yet in line with good international impact assessment practices, since: (i) the self-monitoring model applied makes it possible for proponents to carry out systematic data collection without the monitoring dimension being conducted by appropriate and well-defined methods; (ii) data evaluation, when applied, only makes comparisons by quality indices or with current regulations, disregarding important aspects of the diagnosis that would make it possible to critically evaluate the environmental accommodation process and its state of stability; (iii) information management, where the decision is made to learn and adapt programmes in the face of adversity in the environment, is only possible when the case studies include actions by the Public Prosecutor's Office or pressure from the population upset by the impacts of the project on their health and quality of life. This also includes data relating to dimension (iv) engagement and communication. NUCAM, the regulator that is the subject of the research because it is responsible for the governance dimension of projects in the follow-up stage, although it is active in aspects such as compliance with environmental parameters by comparing them with current regulations or analysing compliance with conditions established in environmental licence opinions, needs to overcome SEMAD's structural challenges, as well as procedural and technical challenges in order to deal with the follow-up of projects submitted for its analysis with criteria. Without adapting follow-up according to good EIA practices, the state of Minas Gerais will not be able to fulfil its obligations to manage the impacts of economic activities and maintain environmental quality.