Hydroelectric plants environmental viability: Strategic environmental assessment application in Brazil

Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

Contents lists available at ScienceDirect

Renewable and Sustainable Energy Reviews journal homepage: www.elsevier.com/locate/rser

Hydroelectric plants environmental viability: Strategic environmental assessment application in Brazil André de Lima Andrade a,c, Marco Aurélio dos Santos b,c,n a

IBAMA, Brazil CNPq, Brazil c Energy Planning Program (COPPE/UFRJ), Brazil b

art ic l e i nf o

a b s t r a c t

Article history: Received 14 November 2014 Received in revised form 22 May 2015 Accepted 29 July 2015

Brazil has a predominantly renewable origin electricity generation matrix, with hydro generation accounting for about 69% of the supply. This paper promotes hydropower projects in Brazil environmental licensing procedure critical assessment, with the aim of identifying and assessing possible solutions to enhance the process, especially through Strategic Environmental Assessment (SEA) application to hydroelectric generation expansion planning processes. It was concluded that impact assessment has led to significant environmental improvements, as it is capable of preventing, controlling and compensating significant – and very often irreversible – environmental impacts, especially through projects optimization and environmental programs that were not initially foreseen in the EIA inclusion. However, as has been expounded throughout this study, there are still several gaps and limitations in the current process, both in power generation expansion planning aspect and project environmental impact assessment aspect. SEA application in the planning phase could contribute to facilitate and simplify hydroelectric plants licensing. Many currently compulsory stages that are carried out after the request for a prior license, such as the consultation made to involved entities and the area environmental diagnosis could already be commenced in the planning phase. & 2015 Elsevier Ltd. All rights reserved.

Keywords: Hydropower Environment Brazil Impact

Contents 1. 2. 3. 4.

5. 6.

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1413 Material and methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1415 Recent advances in hydroelectric plants environmental licensing process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1415 Present environmental licensing model limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417 4.1. EIA carried out in the planning phase low efficacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417 4.2. Lack of objective parameters to determine environmental viability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417 4.3. Limited alternative analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1418 4.4. Difficulty to integrate EIA with other environmental instruments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1419 4.5. Presented information sluggishness and low quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1419 4.6. Limited public participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1420 SEA application in hydropower energy expansion planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1420 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1421

Annex 1. Table with laws and regulations related to Hydroelectric Power Plants in Brazil environmental impact assessment. . . . . . . . . . . . . . . . . . . . . . . . . . 1422 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1423

n Corresponding author at: Energy Planning Program COPPE/UFRJ, Centro de Tecnologia, Bloco C, sala 211, Cidade Universitaria, Rio de Janeiro, Brazil. Tel.: þ 55 21 39388763. E-mail addresses: [email protected] (A.d.L. Andrade), [email protected] (M.A. dos Santos).

http://dx.doi.org/10.1016/j.rser.2015.07.152 1364-0321/& 2015 Elsevier Ltd. All rights reserved.

1414

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

1. Introduction Brazil has a predominantly renewable origin electricity generation matrix, with hydro generation accounting for about 69% of the supply [27]. This source is considered the best option for electric power generation, because it is cheaper [47] emits a lower greenhouse gases quantity [35] and Santos et al. [40]. However, if on the one hand hydro energy has several advantages, building hydroelectric plants can cause highly significant environmental impacts, which are very often irreversible [51], such as biodiversity loss and species extinction due to native vegetation and planted forest areas flooding, habitats destruction, farmland loss, the need to move a large number of people, interference in indigenous territories or traditional populations, alterations in the water regime and water bodies morphology, fish fauna impact, etc. The most significant impacts occur during reservoir construction, but long-term impacts, especially on aquatic ecosystems and on rivers water regime should also be considered [23]. An important aspect to be observed is that negative environmental impacts resulting from a hydroelectric project are even more substantial if the reservoir is situated in environmentally significant or sensitive areas [22]. Thus, the fact that hydroelectric generation expansion in Brazil will be highly concentrated (86% in terms of installed capacity) in the Amazon region makes it even more relevant, as it is considered a very sensitive area from the ecological viewpoint, representing the planet's largest biodiversity reserve [19]. The ten-year Energy Plan [26] provides for new hydroelectric plants installation until 2022, in addition to the plants that are being already built. Fig. 1 shows the geographical localization of planed hydroelectric plants until 2022. It is fundamental, therefore, that activities related to new hydroelectric plants planning and construction should take place within a broad and robust process of Environmental Impact Assessment (EIA). The most important laws and regulations related

to Hydroelectric Power Plants environmental impact assessment in Brazil were detailed in Table A1, included in Annex A. In Brazil, EIA is carried out in order to provide elements for the environmental licensing instrument, provided by Law no. 6.938/ 1981. To put it simply, Brazil's EIA procedure is characterized by the following elements, which distinguish it from effected processes in most countries: i. It focuses on projects environmental impacts assessment, and is not mandatory or regulated in the planning phase. ii. It is effected in 3 (three) stages, and in each of which it is necessary to obtain specific licenses: (i) prior license, when the project environmental viability is discussed, as detailed below; (ii) installation license, when the work is authorized to start; and (iii) operating license, when the enterprise is authorized to operate, which, in the case of hydroelectric plants, includes filling the reservoir and power generation start-up (Law no. 6.938/1981). iii. In the 1st stage, or prior licensing stage, the project is assessed in terms of location and concept, based on EIR (Environmental Impact Assessment Report) analysis. If the environmental body certifies the project environmental viability, the Prior License is issued and requirements to be fulfilled in the process next phases are established (CONAMA Resolution no. 237/97). iv. The assessment should cover not only natural environment, but also anthropic environment. Cumulative impacts should be assessed, as well as alternative technologies and project locations, comparing them to the hypothesis that the project is not carried out. v. The process is conducted by the environmental institution (federal or state) that is responsible for taking decisions regarding licenses issuing. The federal agency (IBAMA) is responsible for hydroelectric processes located in more than one state, in protected areas by the union, on indigenous lands in the Brazilian border, and in plants with capacity exceeding

Fig. 1. Planned Hydroelectric Power Plants. .

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

300 MW (Complementary Law no. 140/2011 and Federal Decree no. 8.437/2015). The remaining dams are licensed by states. vi. It provides for the participation of affected communities and other institutions involved in indigenous people and quilombola populations protection, the National Institute of Historic and Artistic Heritage, and preserved areas. According to this context, this study sought to evaluate the present hydroelectric plants impact assessment model, focusing on the procedure prior licensing stage adopted by the Brazilian Federal Environmental Agency (IBAMA), with the aim of identifying and assessing possible solutions to enhance the process, especially the possibility of Strategic Environment Assessment (SEA) application to the planning process, for hydroelectric generation expansion in Brazil.

2. Material and methods The environmental licensing procedure critical evaluation was carried out by means of a bibliographical review of already published studies in the area: ROHDE [33]; Bursztyn et al. [9]; Oliveira and Bursztyn [30]; Glasson and Salvador [16]; MPF [29]; TCU [45]; Banco Mundial [6]; Unger [49]; Acende Brasil [2]; Abema [1]; and CNI [12]; and also by reviewing 24 (twenty-four)1 out of all the 29 (twenty-nine) federal environmental licensing processes for hydroelectric plants that had been through the prior licensing phase.2 When reviewing hydroelectric plants federal environmental licensing processes, this study looked for: the time length it took for the processes to be carried out, the frequency with which complementary information was requested, which complementary information items were usually requested, the most important criteria adopted in the EIA when discussing viability, the most significant aspects or impacts taken into account on IBAMA viability opinion, the reasons to declare a project environmentally unviable, and environmental improvements or significant improvements in the project resulting from impact assessment process.

3. Recent advances in hydroelectric plants environmental licensing process Up to the seventies, Brazilian electric power concessionaires concerns regarding environmental impacts were practically limited to the relocation of the infrastructure that would be flooded, new access roads construction and towns' relocation [34]. In 1972, the first environmental assessment was carried out for Sobradinho dam (1050 MW) in Northeastern Brazil, due to a demand from the World Bank [18]. Since then, hydroelectric plants construction impact assessment has greatly evolved, with the creation of various provisions and laws that enhanced dams planning and building process. The main identified advances regarding planning and environmental viability assessment, starting in the last decade, are listed below: 1

In 5 (five) processes the information was not available for research. It is important to explain that the great majority of hydroelectric plants that IBAMA currently grants licenses for and that are operating have not gone through the prior environmental licensing process, since they started being built before the National Policy for the Environment (Law no. 6938/1981) was adopted, and before the authority for the federal environmental licensing process was regulated by means of CONAMA Resolution no. 237/97. Currently, there are 93 (ninety-three) processes for hydroelectric plants undergoing federal licensing. 2

1415

a) The obligation to pay environmental compensation in order to support preservation units setting up and maintenance (Law 9985/2000) and to offset impacts that cannot be minimized, caused by the installation of projects with a significant environmental impact. b) Entrepreneur's obligation to acquire, to protect and to very often reforest permanent preservation areas created around reservoirs (Federal Provisional Measure 2166/2001). c) The Energy Research Company (Empresa de Pesquisa Energética – EPE) creation, under Law 10847/2004, which determined the company responsibility to carry out studies on electric power plants social impacts, technical-economic and socio-environmental viability; to draw up necessary studies for electric power generation expansion plans development (10-year and national energy plans); and to develop studies to determine river basins optimal use (Hydroelectric Inventories and IEAs, or Integrated Environmental Assessments). d) The need, from 2004 on, to obtain a prior license for holding a power auction (Decree no. 5.163/2004). According to the new model, the Brazilian government will be only able to hold a hydroelectric plant concession auction after a prior license is obtained. e) The obligation to carry out a prior socioeconomic register of the population that will be affected (Federal Decree no. 7.342/ 2010). f) The regulation of the authority for environmental licensing (Complementary Law no. 140/2011 and Federal Decree no. 8.437/2015). g) The regulation of the way in which federal public administration bodies and entities involved in environmental licensing should operate (Inter-ministry Administrative Order no. 60/ 2015). In this period, several advances have also occurred in the federal environmental licensing process. Currently, pre-implementation actions, aimed to prepare the region that will be affected by large hydroelectric plants installation social impacts, may be executed. A significant improvement has been observed in impact prediction models, such as reservoir water quality modeling studies, what has already helped environmental institutions in determining corresponding mitigation measures. Other important advances resulted from fish transfer systems (stairs, elevators and channels) installation in new projects and defining clear rules for carrying out expropriations and people and communities that are directly affected relocation. There has also been a strong trend towards building run-ofthe-river plants, using ever-smaller reservoirs with a good ratio between installed capacity and the area to be flooded. If, on the one hand, such plants generate lower environmental impacts, on the other hand they lead to a lower energy storage capacity, which is necessary for critical drought periods, and to a lower floodwater storage capacity in flooding periods [41]. At present, “platform style” plants construction in the Amazon region is being studied. This proposal means a significant change from the concept of hydroelectric plants as a factor for affected regions development to the concept of such plants as a factor for preserving areas that are considered to be of ecological interest. Inspired by oil platforms, this model foresees plant construction almost exclusively based on provisional structures for building work support, with workers taking turns in shifts. When the construction work is concluded, the building site is expected to be removed and the area to be reforested, leaving the plant to be operated almost entirely by remote means [32]. There has also been an increase in transparency during the period. At present, all technical opinions and environmental licenses issued by

1416

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

the federal body may be seen in its internet page, and environmental studies return or license applications refusal are made public, what makes it easier for the nation to follow what is being done. As pointed out by Kumar et al. [22] and Sánchez and MorrisonSaunders [37], another aspect that has helped making the process more effective is the experience acquired by entrepreneurs, consulting companies and environmental institutions in already installed enterprises environmental licensing processes. This experience has been reflected in improvements when drawing up environmental studies, holding public consultations, carrying out mitigating measures, and establishing environmental licensing norms and procedures. These advances and learning were the result of efforts on the part of society different sectors, the federal government and also other licensing bodies, which, over the years, have greatly improved environmental impacts assessment and control tools (Fig. 2). In the case of Belo Monte Hydroelectric Plant, with planned installation capacity of 11.233 MW, for example, decades of discussion

about its environmental viability, and strong criticism from the Brazilian and world communities led to a very significant improvement in the project, and resulted in several environmental improvements, among which the following will be mentioned: alteration in the reservoir maximum elevation and configuration, with a reduction in the flooded area from 1.225 km2 to 516 km2 (excluding Indian territories from the area to be flooded); pre-implementation actions being taken in order to adapt the infrastructure; detour channel construction, in order to enable fish migration; some of the reservoir and channel inlets reshaping, in order to reduce eutrophication risk; and an ecological hydrograph adoption, with a 8.000 m3/s flood flow release in the reduced flow stretch, which is sufficient to achieve hydrological pulses maintenance, rock shoals total flooding and alluvial forests partial flooding [21]. Fig. 3 enables to compare the original project with the one that was approved. When analyzing the processes that were evaluated for environmental viability by the federal licensing body, it was found that in 85% of hydroelectric plant processes in which the prior license was granted, significant environmental improvements were identified

Fig. 2. Flow Chart of the procedure to assess hydroelectric projects environment viability. .

Fig. 3. Belo Monte Hydroelectric Plant original and approved project. .

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

Number of Processes

9

1417

8

8 7

6

6

6

5

5

5 4 3

2

2 1 0 Anticipatory Maximum reservoir level actions or programs change, in order to reduce inclusion, in the flooded order to support local area infrastructure

Fishermen Instream Flow Fish Negotiation support increase populations forums program restocking establishment with the program community

Fig. 4. Environmental improvements identified in hydroelectric plants licensing processes. .

due to environmental viability discussion. Such improvements resulted in project alterations or in the inclusion of mitigating programs or measures that were not initially present. The most frequently identified environmental improvements are shown in Fig. 4. Environmental improvements do not exclusively occur due to environmental bodies participation, but are very often proposed in response to pressure exerted by society in general (local communities, NGOs and Public Prosecution Service). In many cases, there were project alterations even before the process was filed at the environmental body or as a consequence of an initial refusal by the federal licensing body to issue the respective license. All these factors cause new projects to be increasingly in tune with environmental issues. However, despite all the advances listed above, even if all the mitigating and compensating measures currently envisaged are introduced, the environmental impact resulting from these enterprises installation and operation is still very high, what significantly increases the planning process complexity and makes it more difficult to arrive at a decision as to whether or not a project is environmentally viable.

enterprises installation, lack of transparency and lack of a robust evaluation of alternatives for hydroelectricity expansion in Brazil. There are also conflicts in hydroelectric plants planning and construction vis-à-vis priority areas for biodiversity preservation, preservation units and indigenous territories. In the carried out Ten-year Plans review, several cases were found in which enterprises considered suitable in the planning phase have not obtained a prior license and had to be abandoned in project phase. As recommended by the World Commission of Dams – WCD [51], the Brazilian government should identify river basins with a vocation and aptitude for hydroelectric potential development, and rivers and basins that should be protected. 4.2. Lack of objective parameters to determine environmental viability There is a great deal of discussion about environmental viability concept in Brazil. From the legal viewpoint, at present, a hydroelectric plant cannot be built if

 it directly affects indigenous territories that have been 4. Present environmental licensing model limitations Next, the main limitations identified in hydroelectric plant licensing processes diagnosis that included environmental viability discussion are presented. The aim was to assess the way these limitations are reflected, from a practical viewpoint, in the licensing processes, and how strategic environmental assessment could make a positive contribution to overcome or minimize the deficiencies found. 4.1. EIA carried out in the planning phase low efficacy At present, it is possible to say that the environmental variable is considered in some way in new hydroelectric projects planning process initial stages, as the National Energy Plans (PNEs), the Tenyear Energy Plans (PDEEs), the River Basins Hydroelectric Inventories, and the River Basins Integrated Environmental Analyzes (IEAs) are drawn up. However, despite the positive aspects, several gaps and limitations prevent these studies from decisively contributing to EIA carried out in the project phase [50]. Some limitations mentioned above are due to the lack of participation and integration of the different agents involved in

  



marked out, going against Art. 231 of the Federal Constitution, until the respective regulations are issued – e.g., Marabá Hydropower Plant; it directly affects Full Protection Preservation Units, going against Law 9985/2000 – e.g., Itumirim Hydro Power Plant3; it causes irreversible impacts to highest importance caves; it causes the elimination of primary vegetation, or vegetation in advanced and medium recovery stages, of the Atlantic Rainforest biome, with characteristics detailed in Art. 11 of Law 11428/2006 – Atlantic Rainforest Law; it causes irreversible losses to a historical, cultural or scenic nature beauty protected heritage;

Environmental viability analysis should involve evaluating the effects caused by anthropic actions, in order to verify their compatibility with the environment capacity to assimilate such effects without detriment to environmental system productivity, that is, to assess whether the environment is able to withstand the 3 In some cases, the Brazilian government has altered protection preservation unit borders, in an attempt to make hydroelectric projects viable (e.g., São Luiz do Tapajós and Tabajara hydroelectric plants).

1418

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

Unidentified

8

Pressure on the infrastructure of the region

4

Impact on indigenous population

3

Low relative installed power / flooded area

3

Damage to migratory fish and affectation of marginal lagoons Affectation of protected areas or priority areas for biodiversity conservation

9 3

Impact on fishing activity

2

Flooding of fertile lands

2

Concern about future water quality

3

Loss of wildlife habitats

3

Reduced flow instream flow passage insufficient to allow maintenance of aquatic ecosystems

4

Low lifetime of the project

2

Increase in the risk of species extinction

3

Deforestation

2 0

1

2

3

4

5

6

7

8

9

10

Number of Processes Fig. 5. Most significant negative impacts types considered in IBAMA's technical opinions. .

impact caused by the activity [28]. Along the same lines, in order to reach a conclusion about environmental viability, it is necessary to check whether the foreseen impact from the actions in a certain plant would result in thresholds stipulated in the legislation or in established quality standards breach. This procedure is well applied in the case of impacts expected to occur mostly on the physical medium. In such cases, the task is made easier by established quality standards (quality of air, water, soil, etc.) existence, and when impacts are easy to foresee – in several cases they can be forecast and measured using mathematical models. Another way to assess environmental viability is through a comparison between positive and negative environmental impacts. This view is better applied in cases of complex activities that affect not only the physical medium, but also the biotic and socioeconomic media (as in hydroelectric plants). In this case, it is necessary to find a way to compare or to add up the impacts, in order to conclude whether gains exceed environmental costs. Several techniques have been developed to work out this balance: intuitive methods, weighted matrixes and multi-criteria analyses. However, despite all this evolution, all techniques are invariably based on subjective assessments [7] and depend on a value judgment [39]. At some point, it is necessary for one or more participants to attribute weights to the impacts, comparing them to each other; and as a result of the same impact assessment, different conclusions may be reached about impacts importance, and consequently, about the project environmental viability. It is also necessary to compare impacts with totally distinct characteristics and scopes: positive and negative; short, medium and long-term; reversible or irreversible; that may or may not be mitigated. This makes it very difficult to take decisions regarding a project development. Fig. 5 depicts the most important negative impacts considered by the technical licensing body to determine hydroelectric dams' environmental viability. As it can be seen, impacts have very different nature. Therefore, it is difficult to compare negative impacts, like the migratory fish damaging possibility and impacts on indigenous people, with positive impacts, like employments raise and income generation. The decision regarding environmental viability is even more complex when the activity affects assets with existence values (e.g., cultural assets), when there are ethical issues involved (e.g.,

species extinction) and when there are uncertainties related to impacts foreseeability and magnitude, which occurs especially in the case of biotic medium impacts [17]. In diagnosing hydroelectric plants licensing processes where environmental viability was discussed, it was found, in practice, that there is lack of objective criteria both in the EIA and in the licensing body technical opinion to determine an enterprise environmental viability and to evaluate EIA quality. In none of the cases it was found that a quantitative balance between positive and negative impacts had been carried out, nor a cost/benefit evaluation, which is not demanded by the federal environmental body either. In the Terms of Reference,4 it is normally required that the conclusion regarding environmental viability should be based on a comparative evaluation between future scenarios for the region where the project would be carried out considering hypotheses of the project being or not being implemented. Therefore, the final decision, even if based on information and prognoses evaluated in the EIA, is qualitative, subjective and discretionary. A method including objective criteria to determine a project environmental viability has yet to be created. In the analyzed EIRs, emphasis was given to the possibility of minimizing negative impacts forecast by adopting environmental programs and mitigating measures, followed by the possibility of generating income and boosting the region's economy. 4.3. Limited alternative analysis Alternative technologies and locations for enterprises evaluation should be included in EIRs. This is a fundamental element in drawing up a creative and proactive impact assessment that is relevant for decision-making [52]. As identified in this study, there are several examples where discussing alternatives enabled alterations and improvements in the project (alterations in flooding elevation, project configurations, 4 Term of Reference is a document issued by the environmental agency that details all EIR requirements and scope.

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

building site location, etc.). However, these changes are limited to one project context. Alternative analyzes are limited to the river basin and are partial, because each company is interested in making its own project viable. In a survey carried out by the Federal Public Prosecution Service(MPU, 2004), where dozens of EIRs were analyzed, no situation was found in which the team responsible for drawing up the EIR had concluded that the alternative proposed by the entrepreneur was not the most suitable. According to Sanches [38,39], it is not realistic to demand the environmental impact study to consider other alternatives with a similar detail degree. Normally, EIAs are carried out when the engineering project is sufficiently outlined (which is usually a basic project) and when economic evaluations already indicate its viability. This means that funds have already been spent in preparing the project and in its economic evaluation, so going back to a strategic condition of analyzing alternatives means questioning decisions that have already been taken. Broader alternatives are not compared within an EIA or a Technical and Economic Feasibility Study (TEFS) as to identify the most attractive ones from the environmental and economic viewpoint. It is not possible to evaluate, for example, whether it is more attractive, from the environmental and economic viewpoint, to build hydroelectric plants on Tapajós River or on Tocantins River. According to Brazil's federal water management body, ANA [3], hydroelectric generation planning in sensitive areas requires two additional analysis levels: the first, considering a river basin as the analysis unit, and comparing different uses (electricity generation or water supply); and the second, analyzing all the proposed projects in the basin in relation to the other basins, and the possible trade-offs between basins, considering each one's potential and vulnerabilities. However, alternatives evaluation within an EIA occurs after the decision to build was taken by the institutions that execute the energy policy. Therefore, the environmental damage caused by hydroelectric plants construction is often diagnosed when it is no longer possible to significantly alter the paths taken by the country's energy policy. In the project phase, it is even more difficult to alter decisions related to projects linked to policies or plans that were formerly approved without the necessary analyses. It is therefore necessary for alternatives analysis to occur also in the planning phase. Without alternatives evaluation in the planning phase, the environmental licensing processes established in EIAs are based on the principle of adapting nature preservation to the existing economic logic [8], and thus aim to reconcile power plants installation with the local environment, what is not always possible. 4.4. Difficulty to integrate EIA with other environmental instruments A large project installation, especially in regions with poor infrastructure, requires other environmental instruments (environmental zoning, protected spaces creation, land ownership legalization, legal reserves, water usage grants, etc.) to be also effective, as they are complementary. This allows environmental impacts to be absorbed and mitigated. However, the current model makes it difficult for the environmental licensing instrument to be integrated with other instruments provided by the legislation. Many of these instruments require long-term actions on the part of the government in order to become effective. However, at present, the dialog among the various ministries occurs at a later phase than planning, when conflicts have already been created, what makes the process of integrating development policies and plans with environmental preservation policy even more difficult. Because of this lack of dialogue, national parks and indigenous reserves have been created in planned areas to be affected by reservoirs.

1419

The integration between project planning, soil use and occupation policies is also very weak. People migration to areas that are affected by projects can lead to many social hazards if not well managed. Another example refers to the conflict generated by large hydroelectric plants installation in regions that are traditionally inhabited by indigenous peoples whose land has not yet been marked out. At present, this conflict is making several plants installation, such as São Manuel (700 MW), Teles Pires (1820 MW) and São Luiz do Tapajós (8040 MW) unfeasible or difficult. In order to reduce such conflicts, prior action by the government would be needed, marking out Indian territories and improving the existing tribes' social structure. Huge projects installation in regions without an adequate social structure requires pre-implementation actions execution. However, in order to adjust the timing between pre-implementation measures execution and the beginning of the construction work, it is necessary to define these actions as early as the planning phase, in order to enable the government to prepare the region. In the Belo Monte process, for example, there was a great impact on the region directly affected by the dam caused by the fact that foreseen pre-implementation measures (construction of schools, water and sewerage systems, etc.), which were to be executed before the construction work began, were not carried out [20]. It is also hard to establish effective mitigating actions that can be carried out by a specific entrepreneur, because such measures are long-termed and broader or more strategic in nature, and are normally dependent on the State or are under its responsibility. An example is sewage treatment to prevent a future dam water eutrophication. In the opinion of Abema [1], without other instruments provided in the Environmental Policy support, licensing loses its purpose as an instrument to measure impacts, increasingly becoming a bureaucratic practice, in detriment to environment protection. Higher integration between economic and social development sectorial policies and environmental policy is necessary [48]. 4.5. Presented information sluggishness and low quality A recurrent criticism made about hydroelectric plants environmental licensing process is how long it takes. In the environmental licensing processes diagnosis in which environmental viability was discussed, it was found that the time taken to complete the processes in the federal licensing body, from the initial opening request to the decision regarding the project's viability, was on average of 5 years and 4 months, divided according to Fig. 6. Many factors contribute to this delay. It can be partly justified by the process democratic nature, which should provide for the public and all other involved entities participation, as well as the information complexity that has to be gathered and analyzed in the EIA, which requires, in the case of hydroelectric plants, carrying out detailed seasonal studies regarding the local environment conditions. The federal licensing body and other entities involved in the process deficient structure, and the absence of a standard Reference Term for drawing up the EIRs highly increase the response delay. Anyway, in the carried out processes diagnosis, the main factor responsible for the process sluggishness was identified as the need for EIR and complementary information resubmission. In 67% of the cases (16 out of 24 projects), the licensing body returned the EIR due to absence of the minimum content set out in the Reference Terms. Some cases were found in which as many as four EIR versions had been submitted, which contributed to the time required for EIR acceptance being of months to on average 2 years and 9 months. It is worth pointing out that it is determined, under the licensing body's internal regulations, that public hearings can be held only after EIR acceptance. After public participation, the EIR is sent to other

1420

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

Reference Term definition

10

EIR delivery after Reference Term definition

6

Time length for IBAMA to accept EIR

33

Prior License application final answer after EIR and after IBAMA acceptance

14

Prior license application final answer time length

64

0

10

20

30

40

50

60

70

Fig. 6. Average term to complete processes.

involved institutions involved for analysis, and then the period commences for the technical team to evaluate the study content and give their response regarding the presented information. Even so, even after environmental studies acceptance, in 79% of the cases (19 out of 24 projects), complementary information was requested, what contributes to the delay in the entity's final position announcement regarding the enterprise's prior license issuing. According to this research, it takes, on average, 5 years and 4 months to the federal agency to give the final answer to the prior license request.5 In the processes in which environmental viability was discussed in the licensing institution diagnosis, it was found that certain information types are very often requested, among which the need for information resubmission related to water quality diagnosis and prognosis, fish species impacts prognosis, and fauna and flora inventory, can be highlighted. This is depicted in Fig. 7. In only one case (Santo Antônio do Jari Hydropower Plant – 373 MW) was the Prior License issued without the need of EIR return and additional information submission. In this case, the total time taken for carrying out the process in the Prior License phase was of 2 years and 1 month. The Prior License was issued four months after EIR approval. With the aid of well-constructed diagnoses, it is possible to predict the effects of actions resulting from these projects planning, installation and operation. The diagnosis and prognosis are very often non-conclusive, so the licensing institution frequently resorts to the precautionary principle as a justification for an environmental license request rejection, or the need for additional information to complement the study. IBAMA reasons to reject or suspend the Prior License were listed in Table A2 (Annex A).

of people who are affected, as well as the participation of entities involved in the licensing process that defend the interests of indigenous populations, protected areas, African slaves descendants, etc. Other participation forms frequently take place during the period when the EIR itself is drawn up, when the participative diagnoses are carried out, when environmental studies Reference Terms are drafted, and throughout the process, especially with the intent of providing elements for environmental programs execution. Participation in public hearings aims at showing to the interested parties the report content, clarifying questions and gathering criticism, as well as suggestions. However, public participation can be considered limited, given that it takes place mostly in only one process phase, and it is based on a format that does not allow much freedom to alter important decisions that have already been made. Little or no participation takes place in the initial planning phases, when the inventory is made, or during the National or Ten-year Energy Plans drawing up, when energy generation several alternatives are discussed in a broad context [5]. In general, public consultation occurs at a stage that is too late to allow it to influence best alternatives selection [44], and it is much more a mean of informing the community than of considering the opinions of the various interest groups in the decision-making process. According to Rovere [36], society as a whole should debate the alternatives for the hydroelectric sector's global planning, this is, however, a closed planning process. As CANTER [10] reminded, it is not enough for people to be heard; it is necessary to incorporate the opinions gathered from them into the decision-making process.

5. SEA application in hydropower energy expansion planning 4.6. Limited public participation Public participation is a fundamental requirement in an Environmental Impact Assessment process. It is one of the most important environmental principles, according to which citizens should participate in the proceedings and in the environmental decisions, not only because they are directly affected by them, but also because of the commitment that everyone should have to the environment defense and protection [43]. In the project phase, public participation occurs in a regulated manner, by means of Public Hearings, which provide the participation 5

Time necessary to elaborate the EIR is included in this period.

Recognized limitations in the present Brazilian environmental licensing process caused several institutions and researchers to suggest that the Strategic Environmental Assessment (SEA) should be generally applied in Brazil to assess the impacts of Programs, Plans and Policies – TCU [45], Teixeira [46], Ayres [5], Unger [49] and Assis et al. [4]; or more specifically, to provide information for planning hydroelectricity expansion in Brazil – Pires [31], MMA [24], MMA [25], Burian [8], and Westin [50]. In global terms, SEA application is also seen as an alternative to promote higher sustainability in policies related to the energy sector [15]. In Portugal, for example, the SEA was employed in 2007 in the National Program for Dams, with a High Hydroelectric Potential (PNBEPH). Using this tool, energy, socioeconomic and

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

15

16 NUMBER OF PROCESSES

1421

14 12 10 8 7

8 6

7 5

5 4

5 4 3

4

3

2 2 0

Fig. 7. Usually requested complementation.

environmental criteria were considered in order to select 10 out of a universe of 25 dams under study, so as to achieve the previously chosen goal of increasing the country's potential to 7.000 MW by 2020 [11]. Similar study was conducted in Vietnam [42]. In recent years, strategic environmental assessment implementation voluntary initiatives have multiplied in Brazil. These initiatives have not occurred to meet any legal requirement, but in many cases due to the difficulties encountered in large projects environmental licensing (Sanches [38,39]). As an example, in 2004, Madeira River Complex hydropower plants SEA was held to enable the environmental licensing of Santo Antônio (3.150 MW) and Jirau (3.450 MW) hydroelectric power stations. In this study opinion, a SEA with the purpose of improving the hydropower generation expansion process could: (a) promote various public entities and other stakeholders integration; (b) discuss strategic alternatives for the expansion of the country's hydroelectric generation; (c) identify river basins to be protected or to be prioritized for projects installation; (d) identify conflicts that may arise in the event of hydroelectric plants construction; (e) establish guidelines and actions that can facilitate the project licensing process; (f) identify pre-implementation actions that are needed for the projects installation; (g) integrate the impact assessment tool with other instruments; and (h) increase the sector's decision-making process transparency. In this respect, carrying out an SEA in the planning phase for power generation capacity expansion would be important in order to include the various points of view in the decision-making process. It would not be possible, however, to effectively enable the participation of people and communities that could be directly affected by hydroelectric plants installation. Hence, public participation in the planning phase should not be a substitute for the participation of local agents, which takes place during the project phase. SEA application would not exclude the subjectivity and discretionary aspect of the decision-making process relative to hydroelectric plants environmental viability. Even so, this tool would contribute to the process by causing the plants that are considered most appropriate in the planning phase to advance to the project EIA phase. This projects directing would only be effective if the

hydroelectric expansion planning process is carried out in a transparent manner, with the participation of the various interested agents, including environmental entities. Strong resistance can be observed on the part of the productive sector against a SEA formal execution for the National and Ten-year Energy Plans; there is the fear that the time required for obtaining licenses for hydroelectric plants would increase. On the contrary, it is believed that the fact that the impact assessment tool is carried out in a regulated manner only in the project phase makes the process more sluggish. It is suggested that SEA should be applied in the process of formulating the National Energy Plan (PNE 2050), which is currently in the initial drafting phase, and whose purpose is to underpin the formulation of public policies and the energy supply expansion national strategy [13,14]. The SEA could be applied at least in the chapter related to hydroelectric generation, which does not exclude the possibility of applying this tool to the other energy sources. As has already been discussed and detailed in this paper, SEA application in the planning phase could contribute to facilitate and simplify hydroelectric plants licensing. Many currently compulsory stages that are carried out after the request for a prior license, such as the consultation made to the entities involved and the environmental diagnosis of the area, could already be commenced in the planning phase.

6. Conclusion Brazil's hydroelectric plants environmental viability assessment represents a formidable challenge, and overcoming this challenge is fundamental to the pursuit of more sustainable development in the related fight against global warming. Though imperfect and sluggish, it is considered that impacts assessment has led to significant environmental gains, as it is able to prevent, control and compensate significant – and very often irreversible – environmental impacts, especially through projects improvement and the inclusion of environmental programs that are not initially foreseen in the EIA.

1422

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

However, as has been expounded throughout this paper, there are still several gaps and limitations in the current process, both in the aspect of power generation expansion planning, as in the aspect of project environmental impact assessment. These gaps and limitations make hydroelectric plants environmental viability assessment processes even more difficult; and their complexity tends to increase with the prospects of increasing exploitation of the Amazon Region's hydroelectric potential. It is believed that a SEA applied in the process of formulating the National Energy Plan (PNE 2050) could be useful for the incorporation of the environmental variable, in a systematic, transparent and democratic manner, in the selection of the best

strategy for the expansion of the country's hydro energy generation. It would reduce the number of conflicts and bring more speed, credibility and efficiency to hydroelectric plants environmental viability assessment phase.

Annex 1. Table with laws and regulations related to Hydroelectric Power Plants in Brazil environmental impact assessment See Annex Tables A1 and A2.

Table A1 Main laws and regulations related to Hydroelectric Power Plants in Brazil environmental impact assessment. Main laws and regulations

Objectives

Law no. 6.938/1981 CONAMA Resolution no. 01/86 CONAMA Resolution no. 237/97 Law no. 9985/2000

Creates and defines elements for the environmental licensing instrument. Details the characteristics and define the requirements of the Environmental Impact Assessment Report – EIR. Details the characteristics of the environmental licensing instrument. Creates and defines projects with the obligation to pay environmental compensation, in order to support the setting up and maintenance of preservation units. Defines hydroelectric power plants power auction procedure. Details the federal environmental licensing process implemented by IBAMA

Law no. 10847/2004 IBAMAs Administrative Order no. 184/2008 Federal Decree no. 7.342/2010 Complementary Law no. 140/2011 Federal Decree no. 8.437/2015 Inter-ministry Administrative Order no. 60/2015

Defines the obligation to carry out a prior socioeconomic register of the population that will be affected by Hydroelectric Power Plants Defines the main characteristics of projects that should be licensed by the federal agency or state agencies Details activities and projects that should be licensed by the federal agency Defines the participation of institutions involved in the protection of indigenous people and quilombola populations, the national historical and artistic heritage, and preserved areas in the federal licensing process

Table A2 Power plants with suspended or refused Prior License application. Hydroelectric power plant

Reasons for Prior License suspension or rejection

Couto Magalhães (150 MW) – Araguaia River Ipueiras (460 MW) – Tocantins River Itumirim (60 MW) – Corrente River Marabá (2160 MW) – Tocantins River Pai Querê (292 MW) – Pelotas River Santa Isabel (1087 MW) Araguaia River Serra Quebrada (1328 MW) – Tocantins River Tijuco Alto (144 MW) – Ribeira River

Reduced flow instream flow passage does not allow aquatic ecosystems maintenance. Flooding of large areas of cerrado with significant importance, flooding of marginal lagoons, unfavorable power/flooded area ratio, intention of establishing a protected area in the area to be flooded. Direct interference in Emas National Park. Flooding of indigenous land. Possibility of endemic species extinction, interference in the priority area for biodiversity. Conservation, intention of establishing a protected area in the area to be flooded, interference in archeological heritage area (Passo de Santa Vitória). Potential impact in a Conservation Área Serra dos Martirios State Park, interference in caves, areas of endemism and scenery of the Araguaia Guerrilla. Flooding of indigenous land. Reason for the initial rejection: Interference in caves, quilombola communities, Atlantic Forest remnants, risk of species extinction, poor diagnosis of vegetation to be removed, fish populations to be affected. Possibility of lead contamination. Lack of integrated impacts assessment. Affects indigenous land.

Tupiratins (620 MW) – Tocantis River Uruçui (134 MW) – Parnaiba River Unfavorable installed capacity/flooded area ratio. Need for removal of riparian populations and flooding of large cerrado fragments with importance to local wildlife. Interference area of great importance for Ichthyofauna breeding (flooding of marginal lagoons).

A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 1413–1423

References [1] Abema. Novas propostas para o licenciamento ambiental no Brasil/Associação Brasileira de Entidades Estaduais de Meio Ambiente; organização José Carlos Carvalho – Brasília. Available at 〈www.abema.org.br〉; 2013. [2] Acende Brasil. Aprimoramentos para o setor elétrico: propostas aos candidatos (Mandato 2015–2018). Instituto Acende Brasil. Available at 〈http://www. acendebrasil.com.br/media/estudos/2014_WhitePaperAcendeBrasil_13_Pro postas_aos_Candidatos_Rev1.pdf〉; 2014. [3] ANA, 2010. Plano Estratégico de Recursos Hídricos da Bacia Amazônica – Afluentes 16 da Margem Direita. Brasília – DF, set. 2010. Avaiable at 〈http:// margemdireita.ana.gov.br/default.asp〉. [4] Assis, Raslan Alexandre, Siqueira Emerson. O Ministério Público e o caso 20 das PCHs da Bacia do Alto Paraguai (Pantanal) in Hidrelétricas e a atuação do Ministério Público na América Latina/Maia, Leonardo Castro. Porto Alegre: Letra & Vida: Red Latinoamericana de Ministério Público Ambiental; 2013 Cappelli, SÌlvia; Pontes Júnio, Felício (Org.), 225–256. [5] Ayres, Madalena Junqueira. O processo decisório de implantação de projetos hidrelétricos no Brasil. Análise dos Casos Referência da Usina de Barra Grande e do Complexo Hidrelétrico do Rio Madeira à Luz da Avaliação Ambiental Estratégica. Master Degree Thesis, PUC-Rio. 2009. [6] Mundial, Banco. Licenciamento Ambiental de Empreendimentos Hidrelétricos no Brasil: Uma Contribuição para o Debate; 2008. [7] Bruce Christopher. Can contingent valuation resolve the ―adding-up problem in environmental impact assessment? Environ Impact Assess Rev 2006;26: 570–85. [8] Burian Paulo Procópio. Do estudo de impacto ambiental à avaliação ambiental estratégica: ambivalências do processo de licenciamento ambiental do setor elétrico. Doctorate thesis. Campinas: Universidade Estadual de Campinas; 2006 SP : [s.n.],. [9] Bursztyn et al (2001). A politica sustentabilidade –politica energética e conflitos ambientais. Garamond Universitária. [10] Canter Larry. Participación pública en la toma de decisiones ambiental. Madrid: Mc Graw Hill; 1998. [11] COBA & PROCESL (). Programa Nacional de Barragens com Elevado Potencial Hidroelétrico: Available at 〈http://pnbeph.inag.pt/np4/np4/?newsId=4& fileName=PNBEPH_RA_Memoria.pdf〉; 2007. [12] CNI, 2014. Licenciamento ambiental: propostas para aperfeiçoamento – confederação Nacional da Industria. Available at 〈http://www.portaldaindus tria.com.br/〉. [13] EPE. Plano Nacional de Energia para 2030. Empresa de Pesquisa Energética – EPE. Available at 〈http://www.epe.gov.brhttps://ben.epe.gov.br/downloads/ Resultados_Pre_BEN_2012.pdf〉; 2006. [14] EPE. Termo de Referência (TDR) para elaboração do PNE 2050. Empresa de 10 Pesquisa Energética. Available at 〈http://www.epe.gov.br〉; 2013. [15] Fischer T. Strategic environmental assessment in post-modern times. 74 Bedford Street South, Liverpool L69 7ZQ, UK: Department of Civic Design, The University of Liverpool; 2003. [16] Glasson J, Salvador NNB. EIA in Brazil: a procedures–practice gap. A comparative 20 study with reference to the European Union, and especially the UK. Environ Impact Assess Rev 2000;20:191–225. [17] Gontier M, Balfors B, Mortberg U. Biodiversity in environmental assessment— current practice and tools for prediction. Environ Impact Assess Rev 2006;26:268–86. [18] IBAMA. Avaliação de impacto ambiental: agentes sociais, procedimentos e ferramentas. Brasília: IBAMA; 1995. p. 1995. [19] IBAMA. GEO Brasil 2002. Perspectivas do Meio Ambiente no Brasil/Organizaed by Thereza Christina Carvalho Santos e João Batista Drummond Câmara; 2002. [20] IBAMA. Parecer Técnico no. 143/2011 – Análise do 1º Relatório de Andamento do Plano Básico Ambiental da UHE Belo Monte. Avaiable at 〈www.ibama.gov. br/licenciamento〉; 2011. [21] IBAMA. Processo de Licenciamento Ambiental da Usina de Belo Monte – 02001.001848/2006-75. Available at 〈http://www.ibama.gov.br/licenciamento/〉; 2014. [22] Kumar A, Schei T, Ahenkorah A, Caceres Rodriguez R, Devernay J-M, Freitas M, et al. Hydropower. Cambridge, United Kingdom and New York, NY, USA: Cambridge University Press; 2011. [23] Manyary Waleska, Carvalho Osmar. Environmental considerations in energy planning for the amazon region: downstream effects of dams. Energy Policy 2007;35:3473–82. [24] MMA. Manual de Avaliação Ambiental Estratégica. . Brasília: MMA/SQA; 2002. p. 92. [25] MMA. Caderno setorial de recursos hídricos. Brasília: geração de energia hidrelétrica/Ministério do Meio Ambiente – Secretaria de Recursos Hídricos; 2006. [26] MME/EPE. Plano Decenal de Expansão de Energia 2022/Ministério de Minas e Energia. Empresa de Pesquisa. Available at 〈http://www.epe.gov.br〉; 2013.

1423

[27] MME/EPE. Minuta do Plano Decenal de Expansão de Energia 2023/Ministério de Minas e Energia. Empresa de Pesquisa. Available at 〈http://www.epe.gov. br〉; 2014. [28] Montano Marcelo, Ranieri Victor. Análise de Viabilidade Ambiental in Engenharia Ambiental Conceitos, Tecnologia e Gestão. Elsevier; 2013 p. 741−765. [29] MPF. Deficiência em estudo de impacto ambiental. Síntese de uma experiência. Ministério Público Federal. 4ª Câmara de Supervisão e Coordenação. Brasília: Escola Superior do Ministério Público da União; 2004. [30] Oliveira, Bursztyn. Avaliação de impacto ambiental de políticas públicas. Rev Int Desenvolv Local 2001(3):45–56. [31] Pires. Planejamento ambiental da expansão da oferta de energia elétrica: ―Subsídios para a discussão de um modelo de desenvolvimento sustentável para 47 Amazônia”. Parcerias Estratégicas – Ibid 2001:160–84. [32] RIMA SLT. Relatório de Impacto Ambiental da Hidrelétrica São Luiz do Tapajós . CNEC e WorleyParsons. Available at: 〈www.ibama.gov.br/licenciamento〉; 2014. [33] ROHDE Geraldo Mário. Estudos de impacto ambiental: a situação brasileira. In: Verdum, Roberto, Medeiros, Rosa Maria Vieira, editors. ampl. Porto Alegre: Universidade/UFRGS; 1995. p. 20–36. [34] ROSA Luis Pinguelli, et al. Impacto de grandes projetos hidrelétricos e nucleares. Rio de Janeiro: Marco Zero/CNPq, AIE/COPPE; 1988. [35] Rosa Luiz Pinguelli, Schaeffer Roberto. Global warming potentials – the case of emissions from dams. Energy Policy 1995;23(2):149–58. [36] Rovere ELL. A Sociedade Tecnológica, o Planejamento e a Democracia. In: Goldemberg M, editor. Rio de Janeiro: Editora REVAN; 1992. p. 77–104. [37] Sánchez, Morrison-Saunders. Learning about knowledge management for improving environmental impact assessment in a government agency: The Western Australian experience. Journal of Environmental Management 2011;92:2260–71 2011. [38] Sánchez. Avaliação Ambiental Estratégica e sua aplicação no Brasil. Texto preparado como referência para o debate ―Rumos da Avaliação Ambiental Estratégica no Brasil realizado em 9 de dezembro de 2008 no Instituto de Estudos Avançados da Universidade de São Paulo. Available at 〈www.iea.usp. br〉; 2008. [39] Sánchez Luis Henrique. Avaliação de Impacto ambiental: conceitos e métodos. Oficina de Textos 2008:287–311. [40] Santos MA, Rosa LP, Sikard B, Sikar E, Oliveira Ednaldo. Gross greenhouse gas fluxes from hydro-power reservoir compared to thermo-power plants. Energy Policy 2006;34:481–8. [41] Soito João Leonardo, Freitas Marcos Aurélio. Amazon and the expansion of hydropower in Brazil: vulnerability, impacts and possibilities for adaptation to global climate change. Renew Sustain Energy Rev 2011;15 316:3165–77. [42] Soussan, John, Nilsson, Mans, 2009. Strategic Environmental Assessment of the Hydropower Master Plan in t Context of Development VI. [43] Staffen, Marcio, Bodnar, Zenildo. Audiência judicial participativa como instrumento de acesso 44 à justiça ambiental: diálogo com Elio Fazzalari. Planeta Amazônia: Revista 45 Internacional de Direito Ambiental e Políticas Públicas. Macapá, n. 2, p. 89-104, 46 47 2010. Available at file:///C:/Users/03795809690/ Downloads/127-1460-1-PB.pdf. [44] Steinemann Anne. Improving alternatives for environmental impact assessment. Elsevier Science Inc. Environ Impact Assess Rev 2001;21:3–21. [45] TCU, 2004. Tribunal de Contas da União. Acordo 464/2004. Disponível em 〈www.tcu.gov.br〉. [46] Teixeira, Izabella Teixeira Mônica . O Uso da Avaliação Ambiental Estratégica no Planejamento de Oferta de Blocos para Exploração e Produção de Petróleo e Gás Natural no Brasil: uma proposta. Tese de Doutorado. Available at 〈http:// www.coppe.ufrj.br/〉; 2008. [47] Tolmasquim, Mauricio. O modelo institucional do setor elétrico brasileiro e seus resultados. Palestra realizada no seminário internacional abce – fepac – sinaenco, Rio de Janeiro (RJ). Available at 〈http://www.sinaenco.com.br/downloads/Tolmas quim.pdf〉; 2012. [48] Tucci, Carlos E. M. e Mendes, Carlos A. Curso de Avaliação Ambiental Integrada 10 de Bacia – Ministério do Meio Ambiente. Secretaria de Qualidade Ambiental; 2006. [49] Unger, Mangabeira. Licenciamento Ambiental – Reformas Institucionais e Ações para a 13 Geração de Oportunidades. Brasília, junho de 2009. Available at 〈http://www.law.harvard.edu/faculty/unger/portuguese/pdfs/11_Licencia mento_ambiental1.pdf〉. [50] Westin, Fernanda Fortes. Análise do uso da avaliação de impacto ambiental estratégica e integrada no contexto da expansão da hidroeletricidade e da política nacional de recursos hídricos: proposta para a efetividade. Doctorate thesis, Energy Planning Program/COPPE/UFRJ. Rio de Janeiro; 2014. [51] WCD. The World Commission on Dams. Dams and Development – A new framework for decision-making. The report of the Word Commission of Dams. Earthscan Publications; 2000. [52] Wood C. Environmental impact assessment: a comparative review. 2nd ed.. London: Person – Prentice Hall; 2003. p. 2003.