Alternativas locacionais em estudos de impacto ambiental no setor de silvicultura na SUPRAM TMAP

Abstract

Minas Gerais ranks second as the state with the highest total production value of planted forest in Brazil, which generates relevant impacts. As a result, forestry is an activity that is subject to Environmental Licensing (LA), which is instructed by the Environmental Impact Assessment (EIA). The AIA is an important instrument of environmental management and, as a principle of good practice, it brings the study of alternatives, which is required by Brazilian legislation, to projects submitted to Environmental Impact Studies and respective Environmental Impact Reports (EIA/RIMA ). Thus, arousing a growing academic interest on the subject, works indicate that the study of alternatives is deficient in EIA in Brazil. Thus, stimulated by the geographic expansion of plantations and the relevance of silvicultural production in the Regional Superintendence of Minas Gerais in the Triângulo Mineiro and Alto Paranaíba (SUPRAM TMAP), the objective of this study is, using the methodology of Mattos (2019), to describe and analysis of the quality of alternative location studies in EIA of enterprises that carry out monoculture of forest species, located at TMAP in the period from 2013 to 2018. In other words, evaluate the form and content, as well as analyze the quality of documentary information using a checklist with scales of concepts (A to D), both applied to the six EIA surveyed, five referring to DN COPAM No. 74/2004 (G-03-02-6) and one DN COPAM No. 217/2017 (G -01-03-1), and three Terms of Reference (TR). It was found that the five EIA (EIA 1, EIA 2, EIA 3, EIA 4 and EIA 5), governed by the former DN, do not present a study of location alternatives, therefore it was not possible to apply the qualitative analysis, that is, to qualitative analysis, only the one governed by the new DN, EIA 6, was detailed. EIA 6, in view of the scenario identified in the literature, presented satisfactory framing of concepts (A and B) in most of the criteria, indicating a relatively good quality, leaving something to be desired as to the justification for the location choice, as this is brief, direct and it does not make the details explicit, but in a general way, avoiding subjectivity by relying on a clear comparison between the different options studied. Regarding the TR, there was an evolution in the entry of the new DN regarding the study of locational alternatives, as the most recent TR available by SEMAD (2021), brings the study of alternatives in a more detailed way. However, an important criterion not addressed in any EIA is the presentation of the hypothesis of non-execution of the project, disregarding the obligation imposed by CONAMA nº 001/1986. Among the results observed, these corroborate the deficiencies found in the literature, necessarily, the improvement of both the scoping stage, with the presence of more specific instructions for the study of alternatives, and the selection of components to be related (processes of description, comparison and selection of the location), together with a greater imposition of environmental agencies regarding the quality of studies, aiming at a greater understanding, understanding and consequently less subjectivity in the analysis of location choice.