Complementary information in EIA process with simplified studies: causes and implications

Abstract

The request for complementation by the Environmental Agencies is pointed out as a cause for the delay in issuing licenses. This work investigated the complements requested by the Environmental Institute of Santa Catarina (IMA), verifying if they come from a legal basis or from the discretion of the reviewers. We analyzed nineteen environmental licensing processes with Environmental Impact Assessment (EIA) carried out by simplified studies. The absence of documents clearly described in the Normative Instructions of IMA represents 66% of the supplementary requests, being caused by inattention of the consultants. In environmental studies, the description of the project/activity and the environmental impacts/mitigating measures were the items most questioned by the reviewers. The generic terms of reference of CONSEMA Resolutions and/or Normative Instructions, which do not even require the efficiency of environmental controls, were identified as the cause of some requirements. The reviewers' discretion affected only 34% of the requests, which suggests that the reviewers' questions are predominantly foreseen in the legislation. The predominance of complements clearly described in the legislation/normative acts indicates that the delay in EIA processes with simplified studies has a great contribution from the consultants, being not exclusively caused by the environmental agency. The dialogue between consultants and reviewers may be promising to make licensing less subjective and unpredictable.