Researcher emphasizes technical criteria and minimizes political decisions
Throughout his experiences as an environmental analyst, geologist Dalmo de Araújo realized that the Environmental Licensing Manual (MLA) for the mining sector in Goiás, aimed at entrepreneurs, practically stops at the list of necessary documentation, does not present legal criteria at the state level for classifying the activities and sizes of mining enterprises and does not detail standards for project development. With the aim of analyzing the main stages that characterize this licensing process, establishing connections with education as much as possible, he developed a master's thesis with the Institute of Geosciences (IG) from Unicamp, guided by professor Luciana Cordeiro de Souza Fernandes. As a case study, with a view to a comparative evaluation, the MLA of Goiás, Secima, and the Cetesb and Ibama manuals were used.
Since graduating, he has worked in the mining sector at the body responsible for environmental licensing in the State of Goiás. In this area, he is responsible for issuing environmental licensing for projects of varying sizes, such as the extraction of sand, granite, limestone and ores of all kinds, which It involves multidisciplinary knowledge, involving geologists, biologists, engineers, social scientists and other professionals. Licensing depends on analysis of the documentation and projects presented by the entrepreneur so that the environmental and social impacts that may arise can be properly measured.
In executing the project, the author proposes to bring together the areas of mining and licensing and the concern with education. The work was guided by the characterization of the main actors involved in the licensing process; where, when and with what resources education can contribute; and what can be improved in environmental licensing. The research, of an exploratory nature, aimed to recognize a reality that has been little studied and raise hypotheses for its understanding.
The study is justified given the great potential of the mining sector in Goiás and its relevance in the Brazilian scenario, in which it is positioned as the third mineral producer, just behind Minas Gerais and Pará. Hence the great responsibility of the State environmental agency in preserving the environment and as an opinion leader in the country. It should be noted that the State's greatest demand is for minerals for direct use in civil construction – sand, granite (gravel), clay – and in agriculture – limestone.
Revelations
The work reveals the absence in the MLA of legal criteria for classifying the nature of the deposits, size of the enterprise, location of mineral activities and guidance for project development, essential attributes for carrying out the environmental study. The specification of these criteria, which must be set out in the standards, is exclusive to the State, responsible for guiding the entrepreneur. Even because, according to federal legislation for the sector, each State can define specific criteria based on its geological, geographical, cultural, economic and social characteristics.
According to the author, the MLA provides superficial information and does not delve into the technical elements necessary to prepare the projects presented by entrepreneurs, failing to fulfill the role of educating. This even implies problems for the environmental analyst, in addition to the lack of established criteria leading to the prevalence of political decisions, to the detriment of technical aspects.
To overcome the difficulties and allow the analyst to make a more accurate decision on the environmental viability of the project, it is necessary to organize the information and explain the instruments that enable the preparation of a more detailed licensing request form. Based on the type of mining, location, size and possible processing, the analyst is responsible for analyzing the documents presented and studying the viability of the site in terms of topography, vegetation, water resources, environmental and social implications.
The crux of the matter
For the researcher, the core of the manual's shortcomings is linked to the lack of organization of criteria within the environmental agency itself, as it is from them that guidelines for entrepreneurs must be established. The manual must represent the licensing process: “A licensing body without clearly established internal criteria cannot have information that can be represented”, says Dalmo. In a case study, he shows what can be done to arrive at the formulation of a properly structured licensing application.
A deficient form contaminates the progress of the licensing process and is one of the main causes of the excessive number of notifications to the entrepreneur to replace or supplement documents or correct design errors, causing obstacles in the process. He emphasizes the need for the licensing manual to be an instrument of organized information, teaching-learning and consolidation of education as an element of citizenship, also valuing the work of the analyst and his career.
The solution to the problem is the restructuring of the environmental agency, organizing multidisciplinary teams, guaranteeing their management and implementing the development of research. The author also understands that the reformulation of environmental licensing in the State requires political motivation and the implementation of a program that, for continuous improvement, depends on the support of successive governments. “It is essential that the body is structured so that it can define its mission and incorporate it into the licensing manual, with a view to educating entrepreneurs and also providing parameters that guide predominantly technical judgments”, emphasizes Dalmo.
