Impact Assessment and Project Appraisal

ISSN: 1461-5517 (Print) 1471-5465 (Online) Journal homepage: https://www.tandfonline.com/loi/tiap20

Practitioners’ perceptions of the Brazilian

environmental impact assessment system: results
from a survey

Carla Grigoletto Duarte, Ana Paula Alves Dibo, Juliana Siqueira-Gay & Luis
Enrique Sánchez

To cite this article: Carla Grigoletto Duarte, Ana Paula Alves Dibo, Juliana Siqueira-Gay &
Luis Enrique Sánchez (2017) Practitioners’ perceptions of the Brazilian environmental impact
assessment system: results from a survey, Impact Assessment and Project Appraisal, 35:4,
293-309, DOI: 10.1080/14615517.2017.1322813

To link to this article: https://doi.org/10.1080/14615517.2017.1322813

Published online: 06 Jun 2017.

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Impact Assessment and Project Appraisal, 2017
VOL. 35, NO. 4, 293–309
https://doi.org/10.1080/14615517.2017.1322813

Practitioners’ perceptions of the Brazilian environmental impact assessment

system: results from a survey
Carla Grigoletto Duarte  , Ana Paula Alves Dibo  , Juliana Siqueira-Gay  and Luis Enrique Sánchez 
Escola Politécnica, University of São Paulo (USP), São Paulo, Brazil

ABSTRACT ARTICLE HISTORY

Practitioners play a key role in implementing environmental impact assessment (EIA) policies. Received 10 January 2017
Gauging their perception can help in designing legislation or regulation reforms and signals Accepted 17 March 2017
what needs more attention in research. The Brazilian EIA system is under review by lawmakers, KEYWORDS
but there is scant information about the views of professionals. A survey was conducted to Impact assessment;
inquiry on practitioners’ perception of the Brazilian EIA system regarding: (1) quality of the effectiveness; EIS quality; EIA
process, (2) quality of the environmental impact studies (EIS), and (3) proposals to change the system; Brazil; environmental
system. Four hundred and fourteen professionals participated in an online survey responding policy
to 44 questions. Results show positive perceptions about some aspects of current practice,
but there is a clear predominance of negative appraisal both about the quality of the process
and the quality of EIS. The poorest practices are the consideration of cumulative impacts and
determination of impact significance. As for proposals to change the system, respondents
defend the continuity of specific characteristics of the Brazilian system. Essentially, practitioners
are calling for incremental changes that do not require any modification in the legislation.

1. Introduction Surveying the perception of professionals can show

the most controversial issues as well as areas of agree-
In recent years, legal requirements for environmental
ment, and can support initiatives of reforming legislation
impact assessment (EIA) underwent changes in many
or regulation and signal what needs more attention in
countries, such as Canada (Gibson 2012), Colombia
public debates or what deserves the interest of research-
(Toro et al. 2010), Australia, United Kingdom, South
ers (Morgan et al. 2012).
Africa (Bond et al. 2014). Pressures to change emerge
The 30-years old Brazilian EIA system is under
from many sectors and push to different, often oppo-
pressure from legislators and their constituencies for
site, directions – from streamlining and fast-tracking
change (Fonseca et al. 2017) but not surprisingly, the
the process (Kirchhoff & Tsuji 2014) and reducing ‘green
proposed directions of change are divergent. In the
tape’ (Gumley 2015) to enlarging its scope to include and
past three years, several rounds of discussion have
integrate more topics (Morrison-Saunders et al. 2014;
been promoted by different stakeholders and different
Sánchez 2014).
proposals have been put forward. Aiming at capturing
Changing policies, however, does not easily result in
the understanding of practitioners about current prac-
its effective implementation (Matland 1995). As practi-
tices and several proposed changes, we conducted an
tioners play a key role in implementing policy reform,
online survey structured in three sections: (1) quality
capturing their perception of current ­practice can help in
of the process; (2) quality of the EIS; and (3) propos-
designing reforms. Analyzing the o ­ pinions of p
­ ractitioners
als to change the system. In this paper, we first briefly
has been used in research about e­ ffectiveness of EIA in
describe selected aspects of the Brazilian EIA system,
The Netherlands and the United Kingdom (Arts et al.
then we present the survey methods, report and dis-
2012), discourses on EIA in The Netherlands (Runhaar
cuss its main results.
et al. 2013), effectiveness of o
­ ffsets (Hayes & Morrison-
Saunders 2007), of non-legal guidance (Waldeck et al.
2003) and about EIA quality (Morrison-Saunders et al. 2.  Key characteristics of Brazilian EIA system
2001) in Australia. Kågström (2016), on the other hand,
The competent authority for EIA is always an environ-
studied the role played by one important group of prac-
mental agency. At the federal level, IBAMA (Brazilian
titioners, consultants who prepare environmental impact
Institute of Environment and Renewable Natural
studies (EIS).

CONTACT  Luis Enrique Sánchez  lsanchez@usp.br

Please see the video abstract here
© 2017 IAIA
294   C. G. DUARTE ET AL.
Resources) is responsible for offshore, nuclear and other
projects as well as those affecting two or more states,
located in federally managed areas and nearby interna-
tional borders. Projects with regional consequences are
usually assessed by state environmental agencies, while
others, featured by local importance may be assessed by
local governments.
All state, the federal agency and, when applica-
ble, municipal agencies, must follow the procedures
defined by national regulation (Resolutions No.
1/1986 and No. 237/1997 of the National Council on
the Environment). States can have their own comple-
mentary legislation, provided it does not conflict with
national rules.
EIA is required for any project with a potential to
‘cause significant environmental degradation’ and its
approval is a condition for issuance of an environmen-
tal license. Many other projects require an environmen-
tal license, but only a limited number undergo the EIA
process.
The process is divided into three phases (three-phase
licensing): (1) previous license, granted after approval of
an EIS; (2) implementation license, after approval of an
environmental management plan detailing mitigation,
and complying with any conditions resulting from the
previous license; (3) operation license, issued when all
conditions are complied with.
Environmental agencies usually require a brief pro-
ject descriptive document, and proceed with scoping
formulating Terms of Reference (ToR) for the EIS. The
EIS is developed by the proponent, which nearly always
contract consultancy firms. After public hearings, envi-
ronmental agencies proceed with the review and a
final technical note (review report) is issued. In case of
approval, this report usually defines the environmental
acceptability of the proposal and establishes terms and
conditions for project implementation.
One characteristic feature of Brazilian environmental
policy is the frequent involvement of the Prosecutor’s
Office, known in Brazil as Ministério Público. Independent
prosecutors are entitled to protect the environment,
consumers and minorities. In defending local com-
munities and future generations, they often litigate
against development projects, many times initiating
a lawsuit aiming at stopping controversial projects
(Zambão 2014). Their enquiries often result in settle-
ments establishing legally binding out-of-court terms
(Sánchez 2013), thus making the Prosecutor’s Office a
powerful agent in EIA.
A summary of key characteristics of EIA in Brazil is
presented in Box 1.
Box 1 – Key characteristics of EIA in Brazil
Screening. A list of projects submitted to an EIS is part
of the 1986 regulations; other projects may be added
at the discretion of each environmental agency. Other
kinds of environmental studies (shorter than an EIS)
may be required for other kinds of projects submitted to
environmental licensing.
Scoping. Scoping is not mandatory, but issuance of ToR
for EIS is adopted by the federal agency and in some
states. There is no public participation in this step.
EIS preparation. A consultancy firm is hired by the
proponent to prepare the EIS and assist in public
hearings, meetings with government agency,
submission of technical studies and other tasks. There
is no requirement for public involvement during the
preparation of an EIS.
EIS review. The review is conducted by staff at the
competent environmental agency. Most EIS are required
to be supplemented by providing additional baseline
information and/or modifying the project.
Public hearing. A hearing is mandatory during the
review step. The hearing is called for and conducted by
the competent environmental agency. Proponent and
consultant are required to make presentation and answer
to questions raised by the public.
Decision-making. In case of approval, the environmental
agency emits a ‘previous license’. Other authorizations are
often necessary, e.g. water abstraction and vegetation
clear-cut have to be required separately. Depending on
the jurisdiction, an environmental management plan
is filed with the application for an ‘installation license’,
also issued by the environmental agency. Both licenses
usually contain a series of conditions of approval.
Follow-up. Monitoring reports are filed at regular
periods. The proponent is required to report on the
implementation of all environmental management
programs and to provide environmental monitoring data.
For additional information, see Borioni et al. (2017) and
Sánchez (2013)
3. Methods
A structured questionnaire was developed for capturing
the perception of practitioners, considered as anyone
experienced in any EIA-related task, including, but not
limited to preparing or reviewing an EIS or parts of it,
hiring firms to undertake surveys, prepare reports or
communicate with third parties, legal counsel or lit-
igation related to EIA and environmental licensing, or
undertaking research. The survey was made available in
SurveyMonkey® from January 21 to February 29 2016.
The dissemination and outreach strategy aimed to
include practitioners from at least six groups:

• Environmental agencies: government departments
responsible for managing the EIA process and issu-
ing environmental licenses.
• Civil Society Organizations (CSO): nonprofit, vol-
untary citizens-based groups independent of
governments. These organizations are oriented
and driven by people with common interest, to
serve specific social or political purposes, as those
related to human rights, environment, health, and
others.
• Consultancy firms: responsible for preparing the
environmental studies and related documents in
the licensing process.
• Proponents: project proponents responsible for all
expenses and costs for the EIA process.
• Public Ministry (Prosecutor’s Office): an autonomous
public entity whose mission is to defend collec-
tive interests and rights and entitled to litigate on
behalf of public interest, both at federal and state
level. It carries on civil inquiries and files a special
kind of lawsuit known as public civil action, aiming
at defending the environment, the rights of minor-
ities such as indigenous communities and other
‘diffuse and collective interests’. Both civil enquir-
ies and lawsuits often result in settlements named
‘Conduct Adjustment Agreements’.
• Research institutions: Universities and research
institutes were included in this category.
The questionnaire features an Introduction stating its
aims and asking for collaboration and contains three
main sections (Appendix):
• The first section enquired about respondent’s level
of agreement (using a five level Likert scale) with
statements about current practice of EIS prepara-
tion. It featured 14 questions about EIS, two ques-
tions about time typically required to develop and
review an EIS and two questions about costs.
• The second section (with 14 questions) focused
on the main steps of the EIA process (Box 1) asking
questions sourced in findings from audits about
procedural and technical aspects of EIA, mostly at
the federal level (MPF 2004; TCU 2009) and in aca-
demic research (Montaño & Souza 2015; Duarte et
al. 2017).
• The third section (with 12 questions) addressed
a number of proposals to change EIA legislation,
collected mostly from draft bills and recent public
debates. The review of three documented propos-
als conducted by Fonseca et al. (2017), as well as
discussions held at the October 2014 Conference
of the Brazilian Association for Impact Assessment
(Ouro Preto) and meetings organized by the Public
Ministry (especially the Seminar Licenciamento
Ambiental: Realidades e Perspectivas – Brasília,
November 2015) were also sources of the ques-
tions included in this section.
IMPACT ASSESSMENT AND PROJECT APPRAISAL   295
The questionnaire featured both multiple choice and
open-ended questions, wherein the respondents were
free to add any comments at the end of each section.
The survey contained 44 questions in its three sections.
In addition, nine questions aimed at capturing the
respondent’s professional involvement with EIA: the
environmental agency he or she is more familiar with;
the types of project he or she is more familiar with;
number of cases the respondent knows in detail; years
of experience and group (out of the above-mentioned
six practitioner groups) the respondent currently works;
in which groups he or she has worked in the past and
what city he or she is based in. The full questionnaire is
presented as an Appendix of this paper.
An early version was tested by inviting seven profes-
sionals to fill in the questionnaire. They were asked not
only to provide answers to all questions, but also to com-
ment about the clarity of questions and the adequacy
of answers scale. The questionnaire was revised after
considering their feedback.
Results were analyzed by describing percentages
of responses to each multiple-choice question, firstly
by all respondents and then by each one of the above-­
mentioned groups, in order to explore different percep-
tions according to the position of the respondents in
the group of practitioners. Open-ended questions were
individually interpreted and excerpts were extracted to
illustrate an argument that we judged as relevant for the
purpose of the survey.
4. Results
A total of 414 respondents from 24 federative units (i.e.
states and the Federal District) and from all target groups
completed the survey, as shown in Figure 1. A majority of
respondents are from the three largest states (São Paulo,
Minas Gerais and Rio de Janeiro), where most EIAs are
conducted, and from the federal capital, Brasília. The
respondents’ profile is shown in Figure 2.
The participants were asked to indicate which types
of projects they were familiar with, being the four most
popular: hydropower, mining, highway/railway and power
line. As for their current sector of professional practice, 34%
are working for EIA agencies, 31% for consultancy firms,
and 23% are at research institutes or Universities. Total
exceeds 100% because some respondents have double
affiliation, e.g. University and consultancy. To gauge the
experience with EIA, it was asked for how many years the
respondents have been involved – those featuring less
than 10 years make 59% of respondents and those with
more than 10 years 41%. It is interesting to note, in Figure
2, the differences regarding respondents’ experience. While
it could be expected that professionals with fewer years
of experience would be engaged in a smaller number of
cases, the question about number of EIA cases known in
detail helps to identify different profiles, including experi-
enced professionals with minor involvement in EIA cases.
296   C. G. DUARTE ET AL.
(Normalized by total participants
of each state)
Figure 1. Survey respondents in each state and their distribution per professional segment.
Right at the beginning of the questionnaire, the
respondents were asked to inform which EIA agencies
they know best. This is because Brazil has a federal agency,
state agencies in 26 states and in the Federal District, as
well as in some municipalities. The Federal Agency was
cited by 74% of the participants, followed by the State EIA
agencies from São Paulo (33%), Minas Gerais (25%), Rio
de Janeiro (17%) and Paraná (13%), while 4% mentioned
having international experience.
4.1.  The quality of the EIA process
Fourteen questions addressed the steps of the EIA pro-
cess (Figure 3(a)). The best performed step is screening,
whose rules are perceived as satisfactory or fully satisfac-
tory by 58% of the respondents. The second-best result
was found for the quality of review performed by the EIA
agencies, but respondents are split, as it is considered as
satisfactory by 48% and as unsatisfactory by 48% too.
There is a predominance of poor evaluation – five
questions achieved above 70% of unsatisfactory results –
for the following: effective implementation of mitigation
(environmental management programs) (77%), participa-
tion of other government agencies (77%), public partic-
ipation during EIS development (76%), consideration in
the EIS of guidelines established by other planning instru-
ments (74%), and recognition of lessons learned (73%).
Total of participants
0
1-5
6 - 10
11 - 40
41 - 80
> 81
Breaking the answers by sector of professional prac-
tice, 80% of respondents from EIA agencies think that
consideration of guidelines from other planning instru-
ments is unsatisfactory, while the best performance is
assigned to the quality of the technical advice for EIA
review, summing 68%, substantially above the overall
average. It is interesting to note that the opinion about
the quality of ToR is split: unsatisfactory for 50% of
respondents and satisfactory for 46%. In the consult-
ants’ view, participation of other government agencies
(80%) and public participation during EIS development
(72%) are the two worst performed practices, while the
adequacy of screening rules (62%) is the best, having no
other practice where positive opinions surpass negative
opinions. Even the quality of EIS is viewed as unsatisfac-
tory by 57% of consultants while 42% express positive
opinions. For researchers, the recognition of lessons
learned into new processes is the worst practice (87%),
and adequacy of screening rules scores the best result
but with a lower percentage than the average for all
respondents (57%).
Proponents have no case of satisfactory opinion sur-
passing the number of negative ones. The three worst
practices from this group are: recognition of lessons
learned (81%), adequacy of participation of the Public
Ministry (75%), and participation of other government
agencies (75%).

(a)
(c)
(e)
Figure 2. Characteristics of the survey’s respondents (n = 414). (a) Types of projects, (b) Current and past experience sectors, (c)
Experience in years, (d) Experience in number of cases known in detail, and (e) Experience in years and experience in number cases
known in detail.
Even in the view of the Public Ministry’s respondents,
adequacy of participation of Public Ministry in the EIA
process is not satisfactory (50% unsatisfactory, 41%
satisfactory). This group reached the highest mark of
unsatisfactory results in two practices: 91% believe that
public participation during EIS development and consid-
eration of guidelines from other planning instruments
are unsatisfactory.
CSO’s reached the highest levels of unsatisfactory
opinions in two questions among all the groups of
respondents: 92% for the consideration of guidelines
from other planning instruments and effective imple-
mentation/operation of environmental programs. As for
the best practice, 61% agree that adequacy of participa-
tion of Public Ministry is satisfactory.
Answers of the two major groups – consultancy firms
and environmental agencies, who together make up
IMPACT ASSESSMENT AND PROJECT APPRAISAL   297
(b)
(d)
64% of respondents and are responsible, respectively, to
prepare and to review the EIS – are presented in Figure
3(b). The most significant divergence is found for opin-
ions about the overall quality of the technical advice
issued by environmental agencies, which is satisfactory
for 68% of environmental agency respondents while it
is satisfactory for 37% of consultants. Quality of ToR and
EIS present meaningful divergences too: while 28% of
consultants are satisfied with ToR and 42% with EISs;
46% of respondents working for environmental agen-
cies are satisfied with ToR, but only 23% are satisfied
with EISs.
Apart from screening (question 1) and the EIS (ques-
tion 11), all questions hit a few ‘this practice should be
suppressed’ responses. Such opinion is largely minority,
the highest rejection being related to the involvement
of the Prosecutor’s Office (5% of respondents).
298   C. G. DUARTE ET AL.

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

10

11

12

13

14

Completely satisfactory, requires no changes

Satisfactory but could be improved with incremental changes
Unsatisfactory, requires major changes
Very unsatisfactory, it needs to be completely changed
This practice should be suppressed
I prefer not to give my opinion

Figure 3a. Practitioners perception about Brazilian EIA process (n = 414).

Two questions aimed at gauging practitioners’ per-
ception about the adequacy of EIA time frames. Overall,
40% believe that the time used for developing an EIS is
shorter than necessary, while 38% think it is adequate,
and 13% think it is longer than necessary. When bro-
ken down by category (Figure 4), the most frequent
response from respondents in consultancy firms, CSOs,
Public Ministry and research institutions is that the time
is shorter than necessary, while most respondents work-
ing for EIA agencies and proponents think the time is
adequate.
Time for EIS review is appreciated differently. For 41%
of respondents, it is longer than necessary, while 29%
think it is shorter than necessary and, for 24%, it is ade-
quate. A majority of consultants (61%) and proponents
(71%) answered that time is longer than necessary. In
the view of respondents from EIA agencies, it is either
adequate (41%) or shorter (40%) than necessary, while
most respondents from CSOs (54%) think it is shorter.
As for costs (Figure 5), 44% answered that EIS devel-
opment is expensive, opinion of 75% of proponents, 47%
of respondents from environmental agencies, and 46%
from CSOs. Even a majority of consultants (40%) believe
that costs are usually high. The fees paid by proponents
are considered adequate for 34% of all respondents.
When the answers are broken down by sector, opinions
are split for most groups.
4.2.  The quality of the environmental impact
study
Asked about how satisfactory were the contents of EIS,
71% of respondents ranked project description as the
best (Figure 6(a)). Analysis of impacts on the physical
environment (47%), the quality of baseline (45%), and
reliability of data collection and analysis (43%) also
appear among the best performed tasks.
In contrast, analysis of cumulative and synergistic
impacts is considered unsatisfactory by 34% and very
unsatisfactory by 43%, while 4% indicated this analysis
should be ruled out of the EIS. Other poorly evaluated
practices are determination of significant impacts (71%),
proper use of baseline for impact analysis and mitiga-
tion proposals (66%) and the adequate proposition of
 IMPACT ASSESSMENT AND PROJECT APPRAISAL   299

Negative opinion 57% of consultants agree that it is satisfactory. Another

divergence is found for opinions about baseline focus
1 – 47% of consultants are satisfied, in contrast to 26% of
80%
14 2 respondents from environmental agencies. Figure 6(b)
60% shows the percentage of agreement or disagreement
13 3 with each statement about how satisfactory are the
40% contents of EIS. In this figure, ‘negative opinions’ refer
to ‘unsatisfactory’ or ‘very unsatisfactory’ ratings, while
12 20% 4
‘positive opinions’ refer to ‘satisfactory’ or ‘completely sat-
0% isfactory’ ratings. The best practice, for both groups, is the
description of the assessed project. The opinion is also
11 5
convergent about the worst practice, the consideration
of cumulative impacts.
10 6
Differences between more experienced and less
experienced professionals reveal an interesting variation
9 7 (Figure 7). Comparing the seven categories of respond-
8 ents, and considering the questions about EIA process
and EIS quality together, the group with higher scores
Consultancy firms Environmental agencies
for positive opinions, i.e. satisfactory and fully satisfac-
tory answers is the ‘I’ve never got involved’, with 45%
and ‘less than 3 cases known’, with 39%. The negative
Positive opinion
views are higher for practitioners in mid-career – from
1 5 to 10 years of experience (65%) and with 4–15 cases
70% known in detail. The more experienced practitioners
14 2
60%
maintain high levels of negative perceptions, but a bit
50%
13 3 lower than in 5–10 years’ group.
40%
30%

12
20%
10%
0%
11
10 6
9 7
8
Consultancy firms Environmental agencies
Figure 3b.  Opinions of practitioners from consultancy firms
and environmental agencies about quality of the EIA process
(percentage) (n = 266).
mitigation actions and environmental management
programs (63%).
Besides the consideration of cumulative impacts,
other practices that, according to some respondents,
should be suppressed are the study of location alter-
natives (2.4%) and of technological alternatives (3.1%).
These practices were evaluated as poorly performed by
62 and 60% of respondents, respectively.
Comparing the opinion of two major groups – consul-
tancy firms and environmental agencies – the sharpest
divergence is found for the reliability of data collec-
tion and analysis, which is considered satisfactory by
only 35% of environmental agency respondents, while
4 4.3.  Proposals to change the EIA system
Among 12 proposals, 7 were recognized as having
potential to highly contribute to improve the EIA system
5 (Figure 8): adopting Strategic Environmental Assessment
(73%); developing technical guidelines/handbooks for
EIA (72%); increasing the requirements of connecting EIA
to other planning tools (70%); increasing the participa-
tion of the scientific community in cases of high com-
plexity (62%); improving the requirements for analysis of
location alternatives (59%); developing brief informative
documents to spread concepts and methods (57%); and
expanding opportunities for public participation in the
preparation of ToR (56%).
Two proposals were considered as undesirable: elimi-
nating the need of public hearings in all EIA process (63%
of respondents), and decentralizing EIA and licensing,
by transferring decision-making to municipalities (40%).
5. Discussion
The survey included participants mostly from southeast,
south, northeast and central west of the country, a major-
ity of them currently practicing as environmental agen-
cies staff (34%), consultants (31%) and researchers (23%).
It is noteworthy that 97 respondents identified them-
selves as working in research area; despite the small
number of groups dedicated to the systematic research
in Impact Assessment in Brazil identified by Montaño
and Souza (2015). This result suggests a growing interest
300   C. G. DUARTE ET AL.

80%

Percentage of participation 70%

60%

50%

40%

30%

20%

10%

0%
Environmental Consultancy CSOs Proponents Public Ministry Research Others Overall Average
agencies firms institutions
Generally shorter than necessary Generally adequate Generally longer than necessary I prefer not to give my opinion

80%

70%
Percentage of participation

60%

50%

40%

30%

20%

10%

0%
Environmental Consultancy CSOs Proponents Public Ministry Research Others Overall Average
agencies firms institutions
Generally shorter than necessary Generally adequate Generally longer than necessary I prefer not to give my opinion

Figure 4. Practitioners perception about time demanded for (a) EIS development and (b) EIS review.

(a) (b)

(c) (d)

Figure 5. Practitioner’s perception about the costs involved in EIA. (a) Adequacy of the total cost to develop an EIS, (b) Adequacy of
fees charged by the environmental agencies, (c) Costs for EIS development by sector, and (d) Fees charged by the environmental
agencies.

Figure 6a. Practitioners’ perception about EIS quality (n = 414).
in Impact Assessment as a research field, also shown by
Duarte et al. (2017).
Comparing the most frequently mentioned prob-
lems of the EIA process (>73% agreement among
respondents) to the scientific literature, both align-
ments and divergence can be identified. In relation
to the follow-up phase, several respondents point out
negative opinions, such as environmental agencies are
very distant from the projects during the implementation
of environmental programs (R152, from both research
institution and consultancy); the quality of the pro-
posals of the environmental [management] programs
is generally low, as well as the effectiveness of their
implementation (R346, currently working for a consul-
tancy); and the inspections should be random and not
IMPACT ASSESSMENT AND PROJECT APPRAISAL   301
dependent on complaints … they should be frequent to
enforce environmental [management] programs (R402,
currently working for a consultancy). Perception that
effective implementation of environmental programs
is poor is supported by findings from do Prado Filho
and de Souza (2004), Fabri et al. (2008), Massoli and
Borges (2014), although the literature also reports
good practices (Sánchez & Gallardo 2005; Gallardo et
al. 2016).
On the other hand, the involvement of other govern-
ment agencies and the consideration in the EIS of guide-
lines established by other planning instruments, viewed
as topics of poor practice, did not deserve much atten-
tion from researchers (Vilani & Machado 2010; Fearnside
& Laurance 2012).
302   C. G. DUARTE ET AL.
Figure 6b.  Opinions of practitioners from consultancy firms
and environmental agencies about EIS quality (percentage)
(n = 266).
In contrast, public participation receives more atten-
tion in the literature, but essentially as critical reviews of
cases to highlight the shortcomings of current practice
(Alonso & Costa 2004; McCormick 2007; Hochstetler 2011;
Souza & Jacobi 2011; Zhouri & Oliveira 2012; Jaichand
& Sampaio 2013; Pereira & Conto 2014), to understand
its role in modifying or stopping high-impact projects
(Rothman 2001; Devlin & Yap 2008; Devlin & Tubino 2012)
or, more recently, to show the absence of public partic-
ipation in scoping (Borioni et al. 2017) or what are the
concerns of the participants (Duarte et al. 2016). These
papers show that public hearings are largely ineffective
as a means of public participation, nevertheless they play
a fundamental role, occasionally influencing denial of
project approval. Respondents also criticize the timing
of public participation mechanisms and ponder the need
of public participation in the scoping phase to identify
(a)
(b)
Figure 7.  Perceptions of practitioners according to their
experience.
relevant issues to be considered in the preparation of
EIS. Further, they consider that
a public hearing, in the moment in which it occurs,
does not contribute significantly to the study because
it has already been delivered to the agency… meetings
should take place during the EIS preparation, in order
to assist the team in collecting more concrete and real
data and thus contributing to a more assertive environ-
mental assessment. (R53, researcher)
In addition, respondents commented on the potential
participation of researchers in the EIA process, such as
increasing the participation of scientific community in
the elaboration of EIS review reports in cases of high
complexity would greatly benefit, on the one hand,
with some expert opinions, but on the other hand
would greatly burden and delay environmental licens-
ing. (R321, from a consultancy)
As for feeding lessons learned back in future assess-
ments, e.g. into ToR and EISs, the vast majority of
respondents considered this practice as very unsatis-
factory or unsatisfactory. One respondent commented:
the same mistakes, distortions and misunderstandings are
repeated in new projects and are not used as paradigm
shifts and practices for new licenses (R369, from a consul-
tancy). This critical reflection captures the understanding
of many practitioners that experiential learning is largely
lost or at least not adequately harnessed to be used in
future assessments (question 8, Figure 3). Consultants
interviewed about their knowledge management prac-
tices (Costanzo & Sánchez 2014) revealed that practices
of knowledge socialization, such as tutoring, team and
technical meetings, are often employed in order to trans-
fer the knowledge obtained between individuals in an

Figure 8. Practitioners perception about proposals to change the Brazilian EIA process (n = 414).
organization, but there is scarce utilization of critical
evaluations such as after-action reviews.
Considering the answers about quality of the EIA pro-
cess, we could expect that practitioners from different
sectors would associate the unsatisfactory aspects to
tasks which are under responsibility of others, but this
is not a rule. Contrasting the opinions of respondents
currently working for EIA agencies with those working
for consultancy firms, it can be noted that: (i) for 80% of
respondents from EIA agencies, consultants do not per-
form a good job in considering the guidelines of other
planning instruments; (ii) for 68% of respondents from
consultancy, the quality of the technical advice issued
by environmental agencies is satisfactory or completely
IMPACT ASSESSMENT AND PROJECT APPRAISAL   303
satisfactory – for comparison, the percentage of all
respondents similarly rating the quality of such advice
is 48%.
In the consultants’ view, the participation of other
government agencies in the process is the worst prac-
tice (80%). However, consultants are critical of their own
performance: 56% of respondents in this group think the
overall quality of EIS is unsatisfactory (41% believe the
quality is satisfactory), while 72% indicated public partic-
ipation during EIS development as unsatisfactory.
In terms of EIS quality, a vast majority of respondents
understand that addressing cumulative and synergistic
impacts is a very poor practice (Figure 6). It is exempli-
fied by one free comment: currently, it is very difficult to
304   C. G. DUARTE ET AL.
access data and information relating to colocalized projects
that influence the results of impact analysis (R152, from
research and consultancy), as for a proper assessment
of cumulative impacts it is necessary to consider other
past, present and reasonably foreseeable future activi-
ties that affect environmental components. This state-
ment coincides with findings of Neri et al. (2016) about
access to information in conducting cumulative impact
assessment in Minas Gerais state and is related to the
perception of most respondents who consider that the
availability and accessibility of reports and documents
in the environmental licensing process – with data and
information that could be used in other projects – are
unsatisfactory or very unsatisfactory (Figure 3, question
7). Hence, there is urgent need of revamping electronic
repositories and searching mechanisms not only in order
to facilitate document retrieval, but also in terms of qual-
ity of information. Since information and knowledge cre-
ated in the EIA process can improve its efficiency and
effectiveness (Sánchez & André 2013), the assessment
of cumulative impacts would benefit from initiatives
by environmental agencies and project proponents
of better managing data, information, and knowledge
(Sánchez 2012).
Figure 6 show that only 1 out of 14 topics of EIS quality
reached more than 50% of satisfactory responses, ech-
oing criticism in the literature (e.g. Montaño et al. 2014)
about the poor quality of EIA documents, despite one
research identifying improvements over time (Landim
& Sánchez 2012).
Regarding possible changes, four proposals were
rejected by more than 40% of respondents. Three of the
four most rejected proposals are specific of the Brazilian
EIA system (public hearings for all EIAs, three-phase
licensing, and a centralized system). Respondents largely
agree that these characteristics should not be changed.
The fourth most rejected proposal – adopting special
rules for infrastructure projects labelled as public util-
ity or social interest – was probably interpreted as fast
tracking environmental licensing, a highly controversial
topic in the current political debate about reforming EIA.
Benefits would be obtained by incremental changes
not requiring legal reform, like the development of tech-
nical guides, as current guidance is focused only on the
administrative steps. Fortunately, this is already part of
the plans of two institutions – IBAMA and the São Paulo
state agency (DAIA/CETESB 2015; IBAMA 2016).
6. Conclusions
Through a survey, our research examined practitioners’
perceptions of the Brazilian EIA system. This survey helps
to understand positive and negative aspects of EIA prac-
tice in Brazil, as well as how a number of proposals for
change are perceived.
A total of 414 respondents answered questions about
the EIA process, the content of EISs, and selected propos-
als to improve or to change current practice.
Results show a predominant negative perception
about the quality of both the process and the EIS.
Regarding the EIA process, positive opinions were
obtained only for screening, perceived as satisfactory
or fully satisfactory by 58% of the respondents. The
review performed by environmental agencies reached
the second highest score, but the opinion of respondents
is split, with 48% considering the quality of such reviews
as satisfactory and an equal percentage as unsatisfactory.
Regarding the EIS, the poorest practices are the consider-
ation of cumulative impacts and determination of impact
significance.
One important finding is that a vast majority of prac-
titioners consider that lessons learned in professional
practice are poorly fed back in future assessments, e.g.
into new ToR and the preparation of other EISs. This is a
matter of concern, as improvements in practice depend
on learning by all participants (Sánchez & Mitchell 2017)
and learning is being considered in the literature as an
important component of an effective EIA system (Bond
et al. 2013). If learned lessons are not used to improve
both efficiency and effectiveness by practitioners them-
selves, then outside pressures to streamline the EIA sys-
tem are more likely to result in unwelcome changes.
While there is a negative perception on several topics
related to EIS quality, most respondents agree that the
time usually available to develop an EIS is generally ade-
quate or shorter than necessary while costs are usually
high. This perception is in contrast with arguments usu-
ally advanced to pressure for streamlining EIA. Among
respondents, it is interesting to notice that even among
those currently working for proponents, only 27%
believe that this time is generally longer than necessary.
In contrast, time needed to review an EIS is viewed as
too long by most respondents within proponents and
consultants.
As for the proposals to change the system, the results
reveal that respondents believe that many of them can
improve EIA practice. Three reform proposals are not wel-
come by the respondents, i.e. revoking: (i) mandatory pub-
lic hearings for all EIAs; (ii) the three-phase licensing; and
(iii) the centralized system in state and federal institutions.
The most accepted proposed changes include: (i) devel-
oping technical guidance; (ii) increasing requirements for
alternatives comparison and for linking EIA with other
planning tools; (iii) adopting Strategic Environmental
Assessment; and (iv) increasing public participation
during scoping, proposals supported by nearly 90% of
the respondents. However, current political pressure for
changing the Brazilian EIA system (Fonseca et al. 2017)
does not converge with the understanding of practition-
ers, as bills under discussion in the National Congress
include several elements aiming to streamline the process,
e.g. by skipping the need of conducting public hearings,
by eliminating three-phase licensing and establishing
tighter timelines for EIS review (Fearnside 2016; Tollefson
2016). Essentially, practitioners are calling for incremen-
tal changes that do not require any modification in the

legislation. An example of efficiency-oriented incremental
improvement is setting up searchable electronic reposi-
tories of EIA information and documents.
Each one of the 44 questions of this survey may
unfold into research to explore strengths, achievements,
weaknesses, failures, opportunities, and risks for EIA in
Brazil. Thus, research of other nature, such as documen-
tal analysis and case studies detailing the issues raised
are welcome to confirm or deny the perception of the
respondents of this questionnaire.
EIA systems all over the world have a number of com-
mon characteristics alongside context-specific features.
While literature and international experience are impor-
tant references when discussing possible ways to reform
EIA, the perception of practitioners is irreplaceable to
understand how a system works in practice and how
could it be affected by proposed changes. Many differ-
ent proposals are under discussion by lawmakers at the
national level, and we hope the results presented here
can be used as inputs in discussions about the future of
EIA in Brazil, as well as inspire new research in this context.
Acknowledgments
The first author thanks the São Paulo Research Foundation
(FAPESP) for supporting her postdoctoral research. The
second and third authors thanks the Coordination for the
Improvement of Higher Education Personnel (CAPES) for sup-
porting respectively their PhD and Master research.
Disclosure statement
No potential conflict of interest was reported by the authors.
Funding
This work was supported by the São Paulo Research
Foundation (FAPESP) [grant 2013/04285-0].
ORCID
Carla Grigoletto Duarte    http://orcid.org/0000-0003-2129-
7117
Ana Paula Alves Dibo   http://orcid.org/0000-0003-2201-9354
Juliana Siqueira-Gay   http://orcid.org/0000-0002-7930-9806
Luis Enrique Sánchez   http://orcid.org/0000-0001-6779-8481
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 IMPACT ASSESSMENT AND PROJECT APPRAISAL   307

Appendix: Questionnaire
General information about the respondent

(1)  Which is/are your level of involvement with the EIA System?

[ ] Municipal
[ ] State
[ ] Federal
[ ] International
[ ] Other
Please specify:
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________

(2)  To answer this questionnaire, keep in mind the environmental agency you know better. Please inform us which one (or
more, if applicable):
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________
Part I – Quality of the environmental impact study

(3)  How do you consider current practice in the Brazilian EIA process for the following topics:
1 2 3 4 5 6
1 Location alternatives
2 Technological alternatives
3 Clarity in the description of the project
4 Quality of baseline
5 Baseline focus (sufficient detail on significant issues)
6 Use of baseline data for impact analysis and mitigation proposals
7 Identification, assessment and mitigation of impacts on the physical environment
8 Identification, assessment and mitigation of impacts on the biotic environment
9 Identification, assessment and mitigation of impacts on the socio-economic environment
10 Identification, assessment and mitigation of cumulative and synergistic impacts
11 Clarity in determining significant impacts
12 Connection between mitigation proposals and environmental management programs
13 Reliability of data collection and analysis presented in the EIS
14 Adequacy of the Non-Technical Summary as a document for discussions with society

Key
(1)  Completely satisfactory, requires no changes
(2)  Satisfactory, but could be improved with incremental changes
(3)  Unsatisfactory, requires major changes
(4)  Very unsatisfactory, it needs to be completely changed
(5)  This practice should be suppressed
(6)  I prefer not to give my opinion

Do you have any comment or suggestion?

_________________________________________________________________________________________________________
_________________________________________________________________________________________________________

(4)  How do you consider current practice in terms of total time to:

Generally shorter than necessary Generally adequate Generally longer than necessary I prefer not to give my opinion
(4a) Develop an EIS
(4b) Review an EIS 
Do you have any comment that you would like to add?
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________

(5)  How do you consider current practice in terms of total costs to:

Usually high Usually adequate Usually low I prefer not to give my opinion
(5a) Develop an EIS
(5b)  Fees charged by the environmental agencies

Do you have any comments that you would like to add?

_________________________________________________________________________________________________________
_________________________________________________________________________________________________________
308   C. G. DUARTE ET AL.

Part II – Quality of EIA process

(6)  How do you consider current practice in the Brazilian EIA process as related to the following topics:
1 2 3 4 5 6
1 Sufficiency of the rules that define which projects require EIA (complete studies)
2 Effective implementation of environmental management programs
3 Adequacy of the participation of other government agencies (beyond the competent authority)
4 Adequacy of the participation of the Public Prosecutor's Office
5 Public hearing as an adequate mechanism for society's participation (is mandatory)
6 Public participation during EIS elaboration
7 Public access to reports and documents related to EIA
8 Recognition of lessons learned into new processes (ToR, EIS)
9 Consideration in the EIS of guidelines of other planning instruments, such as zoning, management plans and
river basin plans
10 Overall quality of the Terms of Reference
11 Overall quality of the EISs
12 Overall quality of the Non-Technical EIS Summary
13 Overall quality of the technical advice issued by environmental agencies
14 Overall quality of the studies and reports submitted after EIS approval (monitoring reports, compliance reports,
etc)

Key
(1)  Completely satisfactory, requires no changes
(2)  Satisfactory, but could be improved with incremental changes
(3)  Unsatisfactory, requires major changes
(4)  Very unsatisfactory, it needs to be completely changed
(5)  This practice should be suppressed
(6)  I prefer not give my opinion

Do you have any comment or suggestion?

_________________________________________________________________________________________________________
_________________________________________________________________________________________________________
Part III - Proposals to change the EIA system

(7)  In your opinion, how the following proposals could influence the Brazilian EIA process?
1 2 3 4 5
1 Prepare technical guidance about methods and procedures for EIA, including alternatives comparison, evaluation of
significance and public participation
2 Develop brief informational materials to explore important concepts such as significance, cumulative impacts and
mitigation
3 Increase requirements for alternative development and comparison
4 Promote decentralization of environmental licensing
5 Adopt special rules for assessing the impacts of public utility and social interest infrastructure projects
6 Increase requirements for linking EIA with other planning instruments (such as zoning, watershed plans, etc)
7 Adopt Strategic Environmental Assessment for the sectors with the highest EIA demand
8 Require certification / accreditation of EIS coordinators
9 Modify the current three-phase licensing for a model with two or a single phase
10 Increase participation during scoping stage (elaboration of Terms of Reference)
11 Eliminate the requirement for public hearings in all EIA processes
12 Increase the participation of the scientific community in the preparation of technical reports in cases of high complexity

Key
(1)  It would bring great benefit
(2)  It would bring little benefit
(3)  It would result in some prejudice
(4)  It would result in great prejudice
(5)  I prefer not to give my opinion

Do you have any other comments on these proposals or do you believe that any of them would prejudice the EIA process?
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________
Profile of the respondent

(8)  For how many years have you been involved with the EIA system?
[ ] Up to 5 years
[ ] 5 to 10 years
[ ] 10 to 20 years
[ ] More than 20 years

(9)  How many cases do you know in detail?

[ ] I’ve never got involved
[ ] Less than 3 cases
 IMPACT ASSESSMENT AND PROJECT APPRAISAL   309

[ ] 4 to 15 cases
[ ] 16 to 30 cases
[ ] More than 30 cases

(10)  Which type of projects are you most familiar with?

[ ] Hydropower
[ ] Roads/Rails
[ ] Mining
[ ] Power Lines
[ ] Oil and Gas
[ ] Landfills
[ ] Pipelines
[ ] Sugarcane plants
[ ] Others (Specify)
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________

(11)  Have you participated of any EIA event in the last 3 years? (seminar, congress, course?)
[ ] Yes
[ ] No
If yes, please inform at least one:
_________________________________________________________________________________________________________
_________________________________________________________________________________________________________

(12)  In which of the following sector(s) do you currently work?

[ ] Environmental agencies
[ ] Consultancy firms
[ ] CSOs
[ ] Proponents
[ ] Public Ministry
[ ] Research institutions
[ ] Others
Others (Specify)
_________________________________________________________________________________________________________
________________________________________________________________________________________________________

(13)  In which of the following sector(s) did you work in the past?
[ ] Environmental agencies
[ ] Consultancy firms
[ ] CSOs
[ ] Proponents
[ ] Public Ministry
[ ] Research institutions
[ ] Others
Others (Specify)
_________________________________________________________________________________________________________
________________________________________________________________________________________________________

(14)  What city are you based in?

_______________________________________________________________________________________________
_______________________________________________________________________________________________