Renewable and Sustainable Energy Reviews 52 (2015) 14131423

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Renewable and Sustainable Energy Reviews

journal homepage: www.elsevier.com/locate/rser

Hydroelectric plants environmental viability: Strategic environmental

assessment application in Brazil
Andr de Lima Andrade a,c, Marco Aurlio dos Santos b,c,n
a
IBAMA, Brazil
b
CNPq, Brazil
c
Energy Planning Program (COPPE/UFRJ), Brazil

art ic l e i nf o a b s t r a c t

Article history: Brazil has a predominantly renewable origin electricity generation matrix, with hydro generation
Received 14 November 2014 accounting for about 69% of the supply. This paper promotes hydropower projects in Brazil environ-
Received in revised form mental licensing procedure critical assessment, with the aim of identifying and assessing possible
22 May 2015
solutions to enhance the process, especially through Strategic Environmental Assessment (SEA)
Accepted 29 July 2015
application to hydroelectric generation expansion planning processes. It was concluded that impact
assessment has led to signicant environmental improvements, as it is capable of preventing, controlling
Keywords: and compensating signicant and very often irreversible environmental impacts, especially through
Hydropower projects optimization and environmental programs that were not initially foreseen in the EIA inclusion.
Environment
However, as has been expounded throughout this study, there are still several gaps and limitations in the
Brazil
current process, both in power generation expansion planning aspect and project environmental impact
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.

Contents

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1413
2. Material and methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1415
3. Recent advances in hydroelectric plants environmental licensing process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1415
4. Present environmental licensing model limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417
4.1. EIA carried out in the planning phase low efcacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417
4.2. Lack of objective parameters to determine environmental viability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1417
4.3. Limited alternative analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1418
4.4. Difculty to integrate EIA with other environmental instruments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1419
4.5. Presented information sluggishness and low quality. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1419
4.6. Limited public participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1420
5. SEA application in hydropower energy expansion planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1420
6. 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.: 55 21 39388763.
E-mail addresses: andreandrade02@hotmail.com (A.d.L. Andrade), aurelio@ppe.ufrj.br (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) 14131423
1. Introduction
Brazil has a predominantly renewable origin electricity genera-
tion 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 green-
house 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 signicant environ-
mental impacts, which are very often irreversible [51], such as
biodiversity loss and species extinction due to native vegetation and
planted forest areas ooding, 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, sh fauna impact, etc.
The most signicant impacts occur during reservoir construc-
tion, 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 environ-
mental impacts resulting from a hydroelectric project are even
more substantial if the reservoir is situated in environmentally
signicant 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
Fig. 1. Planned Hydroelectric Power Plants. .
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 pro-
cesses 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 specic 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
lling 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
certies the project environmental viability, the Prior License is
issued and requirements to be fullled 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 loca-
tions, 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
 A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 14131423
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 quilom-
bola 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 identify-
ing and assessing possible solutions to enhance the process,
especially the possibility of Strategic Environment Assessment
(SEA) application to the planning process, for hydroelectric gen-
eration 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 complemen-
tary information items were usually requested, the most impor-
tant criteria adopted in the EIA when discussing viability, the most
signicant aspects or impacts taken into account on IBAMA
viability opinion, the reasons to declare a project environme-
ntally unviable, and environmental improvements or signicant
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 lim-
ited to the relocation of the infrastructure that would be ooded,
new access roads construction and towns' relocation [34]. In 1972,
the rst 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 assess-
ment has greatly evolved, with the creation of various prov-
isions and laws that enhanced dams planning and building
process. The main identied advances regarding planning and
environmental viability assessment, starting in the last decade, are
listed below:
1
In 5 (ve) processes the information was not available for research.
2
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.
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 signicant envir-
onmental 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 Energtica
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-environ-
mental 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 administra-
tion 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-implem-
entation actions, aimed to prepare the region that will be affected
by large hydroelectric plants installation social impacts, may be
executed.
A signicant improvement has been observed in impact pre-
diction models, such as reservoir water quality modeling studies,
what has already helped environmental institutions in determin-
ing corresponding mitigation measures. Other important advances
resulted from sh transfer systems (stairs, elevators and channels)
installation in new projects and dening 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-of-
the-river plants, using ever-smaller reservoirs with a good ratio
between installed capacity and the area to be ooded. 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 oodwater
storage capacity in ooding periods [41].
At present, platform style plants construction in the Amazon
region is being studied. This proposal means a signicant 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) 14131423

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 Snchez and Morrison-
Saunders [37], another aspect that has helped making the process
more effective is the experience acquired by entrepreneurs, con-
sulting companies and environmental institutions in already
installed enterprises environmental licensing processes. This
experience has been reected 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 signicant improve-
ment in the project, and resulted in several environmental improve-
ments, among which the following will be mentioned: alteration in
the reservoir maximum elevation and conguration, with a reduction
in the ooded area from 1.225 km2 to 516 km2 (excluding Indian
territories from the area to be ooded); pre-implementation actions
being taken in order to adapt the infrastructure; detour channel
construction, in order to enable sh 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 ood ow
release in the reduced ow stretch, which is sufcient to achieve
hydrological pulses maintenance, rock shoals total ooding and
alluvial forests partial ooding [21]. Fig. 3 enables to compare the
original project with the one that was approved.
When analyzing the processes that were evaluated for environ-
mental viability by the federal licensing body, it was found that in
85% of hydroelectric plant processes in which the prior license was
granted, signicant environmental improvements were identied

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) 14131423
9
8
8
Number of Processes
7
6
5
4
3
2
1
0
Maximum
reservoir level actions or
change, in
order to reduce inclusion, in
the flooded
area
infrastructure
Fig. 4. Environmental improvements identied 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 identied 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 commu-
nities, NGOs and Public Prosecution Service). In many cases, there
were project alterations even before the process was led 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 signicantly increases the planning process
complexity and makes it more difcult to arrive at a decision as
to whether or not a project is environmentally viable.
4. Present environmental licensing model limitations
Next, the main limitations identied in hydroelectric plant
licensing processes diagnosis that included environmental viabi-
lity discussion are presented. The aim was to assess the way these
limitations are reected, from a practical viewpoint, in the licen-
sing processes, and how strategic environmental assessment could
make a positive contribution to overcome or minimize the
deciencies found.
4.1. EIA carried out in the planning phase low efcacy
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 Ten-
year Energy Plans (PDEEs), the River Basins Hydroelectric Inven-
tories, 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 con-
tributing 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
1417
6 6
5 5
2
Anticipatory Fishermen Instream Flow Fish Negotiation
support increase populations forums
programs program restocking establishment
program with the
order to community
support local
enterprises installation, lack of transparency and lack of a robust
evaluation of alternatives for hydroelectricity expansion in Brazil.
There are also conicts in hydroelectric plants planning and
construction vis--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 enter-
prises 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
marked out, going against Art. 231 of the Federal Constitution,
until the respective regulations are issued e.g., Marab
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 Rain-
forest 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., So Luiz do
Tapajs and Tabajara hydroelectric plants).
1418 A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 14131423
Unidentified
Pressure on the infrastructure of the region
Impact on indigenous population
Low relative installed power / flooded area
Damage to migratory fish and affectation of marginal
lagoons
Affectation of protected areas or priority areas for
biodiversity conservation
Impact on fishing activity
Flooding of fertile lands
Concern about future water quality
Loss of wildlife habitats
Reduced flow instream flow passage insufficient to allow
maintenance of aquatic ecosystems
Low lifetime of the project
Increase in the risk of species extinction
Deforestation
0 1
Fig. 5. Most signicant 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 impa-
cts. 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 nd 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 difcult 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 difcult to compare negative impacts, like the migratory sh
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.,
8
4
3
3
9
3
2
2
3
3
4
2
3
2
2 3 4 5 6 7 8 9 10
Number of Processes
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/benet 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 cons-
idering hypotheses of the project being or not being imple-
mented.
Therefore, the nal 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 evalua-
tion 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 identied in this study, there are several examples where
discussing alternatives enabled alterations and improvements in
the project (alterations in ooding elevation, project congurations,
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) 14131423
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 sufciently 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 Tapajs 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 rst, 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 poten-
tial 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
signicantly alter the paths taken by the country's energy policy. In
the project phase, it is even more difcult 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 plan-
ning 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. Difculty to integrate EIA with other environmental instruments
A large project installation, especially in regions with poor
infrastructure, requires other environmental instruments (envir-
onmental 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 difcult 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 conicts have already been created, what makes the
process of integrating development policies and plans with environ-
mental preservation policy even more difcult. 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 occupa-
tion 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 conict generated by
large hydroelectric plants installation in regions that are tradi-
tionally inhabited by indigenous peoples whose land has not yet
been marked out. At present, this conict is making several plants
installation, such as So Manuel (700 MW), Teles Pires (1820 MW)
and So Luiz do Tapajs (8040 MW) unfeasible or difcult. In order
to reduce such conicts, 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. How-
ever, in order to adjust the timing between pre-implementation
measures execution and the beginning of the construction work, it
is necessary to dene 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 specic 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 environ-
mental 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 justied 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 decient structure, and the absence of a stand-
ard 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 identied
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) 14131423
Reference Term definition
EIR delivery after Reference Term definition
Time length for IBAMA to accept EIR
Prior License application final answer after EIR and after
IBAMA acceptance
Prior license application final answer time length
0 10
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 nal 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 nal answer to the prior
license request.5
In the processes in which environmental viability was dis-
cussed 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, sh species impacts prognosis, and fauna
and ora inventory, can be highlighted. This is depicted in Fig. 7.
In only one case (Santo Antnio 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 plan-
ning, installation and operation. The diagnosis and prognosis are
very often non-conclusive, so the licensing institution frequently
resorts to the precautionary principle as a justication 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).
4.6. Limited public participation
Public participation is a fundamental requirement in an Envir-
onmental 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.
10
6
33
14
64
20 30 40 50 60 70
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 inter-
ested 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 genera-
tion 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 inuence 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
Recognized limitations in the present Brazilian environmental
licensing process caused several institutions and researchers to suggest
that the Strategic Environmental Assessment (SEA) should be gener-
ally 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 specically, to provide information for planning hydro-
electricity 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) 14131423
16 15
NUMBER OF PROCESSES
14
12
10
8 7
6 5
4 3
2
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 implementa-
tion voluntary initiatives have multiplied in Brazil. These initiatives
have not occurred to meet any legal requirement, but in many cases
due to the difculties 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 environ-
mental licensing of Santo Antnio (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 conicts
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 hydro-
electric 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 discre-
tionary aspect of the decision-making process relative to hydro-
electric 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
1421
8
7
5 5
4 4
3
2
hydroelectric expansion planning process is carried out in a
transparent manner, with the participation of the various inter-
ested 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 environ-
mental 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 ght against global warming. Though imperfect and sluggish,
it is considered that impacts assessment has led to signicant
environmental gains, as it is able to prevent, control and compensate
signicant and very often irreversible environmental impacts,
especially through projects improvement and the inclusion of envir-
onmental 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) 14131423

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 difcult; 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 genera-
tion. It would reduce the number of conicts and bring more
speed, credibility and efciency to hydroelectric plants environ-
mental 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
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
Creates and denes elements for the environmental licensing instrument.
Details the characteristics and dene the requirements of the Environmental Impact Assessment Report EIR.
Details the characteristics of the environmental licensing instrument.
Creates and denes projects with the obligation to pay environmental compensation, in order to support the setting up and
maintenance of preservation units.
Denes hydroelectric power plants power auction procedure.
Details the federal environmental licensing process implemented by IBAMA
Denes the obligation to carry out a prior socioeconomic register of the population that will be affected by Hydroelectric Power
Plants
Denes 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
Denes 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 Magalhes (150 MW)
Araguaia River
Ipueiras (460 MW) Tocantins
River
Itumirim (60 MW) Corrente
River
Marab (2160 MW) Tocantins
River
Pai Quer (292 MW) Pelotas
River
Santa Isabel (1087 MW) Araguaia
River
Serra Quebrada (1328 MW)
Tocantins River
Tijuco Alto (144 MW) Ribeira
River
Tupiratins (620 MW) Tocantis
River
Uruui (134 MW) Parnaiba River Unfavorable installed capacity/ooded area ratio. Need for removal of riparian populations and ooding of large cerrado fragments
with importance to local wildlife. Interference area of great importance for Ichthyofauna breeding (ooding of marginal lagoons).
Reduced ow instream ow passage does not allow aquatic ecosystems maintenance.
Flooding of large areas of cerrado with signicant importance, ooding of marginal lagoons, unfavorable power/ooded area ratio,
intention of establishing a protected area in the area to be ooded.
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 ooded, interference in archeological heritage area (Passo de Santa Vitria).
Potential impact in a Conservation rea 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, sh populations to be affected. Possibility of lead contamination. Lack of integrated
impacts assessment.
Affects indigenous land.
 A.d.L. Andrade, M.A. dos Santos / Renewable and Sustainable Energy Reviews 52 (2015) 14131423
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