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Manufacturing Pre-Decisions: A Comparative Analysis of Environmental

Impact Statement (EIS) Reviews in Brazil and Portugal

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 sustainability

Article
Manufacturing Pre-Decisions: A Comparative
Analysis of Environmental Impact Statement (EIS)
Reviews in Brazil and Portugal
Caroline Fan Rocha 1,2, * , Tomás B. Ramos 2 and Alberto Fonseca 1
1 Graduate Program in Environmental Engineering, Federal University of Ouro Preto, Ouro Preto 35400-000,
Brazil; [email protected]
2 CENSE—Center for Environmental and Sustainability Research, NOVA School of Science and Technology,
NOVA University Lisbon, 2829-516 Lisbon, Portugal; [email protected]
* Correspondence: [email protected]




Received: 19 May 2019; Accepted: 8 June 2019; Published: 12 June 2019


Abstract: The review of environmental impact statements (EIS), despite its relevance to impact
assessment effectiveness, has received scarce scholarly attention. Few studies have gone beyond the
realm of regulatory evaluations to understand the managerial meanders of the review process. This
study evaluated the responsibilities, procedures, information inputs, and scope of EIS reviews within
two environmental authorities: APA (Portuguese Environment Agency), in Portugal, and SEMAD
(State Secretariat for Environment and Sustainable Development), in the Brazilian state of Minas
Gerais. Based on a qualitative multiple-case study methodology informed by participant observation,
unstructured interviews, and content analysis of 12 EIS review reports, the study provided what is
arguably one of the most detailed characterizations of EIS review to date. While following similar
institutional arrangements and broad procedural steps, the EIS review has important differences in
APA and SEMAD. Overall, the Portuguese agency was found to have a more structured, participative,
interdisciplinary, detailed, and grounded review, thus meeting some of the good practices often cited
in the literature. The EIS review reports prepared by APA reviewers were also found to provide
a profoundly more complete and transparent account of the review process. The details of the
review process revealed in the article can affect perceptions around the legitimacy and reliability of
reviewers’ recommendations.

Keywords: environmental impact assessment (EIA); review stage; environmental impact statement
(EIS); EIS review; public administration; Portugal; Brazil

1. Introduction
Among the world’s most influential environmental policy tools is environmental impact assessment
(EIA) [1]. This decision-making process, which tries to predict the future consequences of a current or
proposed action [2], was first regulated in the United States in 1969 but spread to almost every country
on Earth. Economic development and environmental conservation worldwide are routinely affected by
EIA decisions [3]. The growing importance of EIA has driven the emergence of a vast body of research
since the 1970s. Dissertations, theses, scientific books, and articles have long been addressing EIA’s
challenges. However, some intricate aspects of this decision-making process, such as public authorities’
review of environmental impact statements or studies (EIS), have received marginal attention so far.
As noted by Morgan [4] in his review of the state of the art of EIA, in the past decades, scholars have
devoted significant attention to theoretical and effectiveness issues, particularly in connection with
some of EIA’s main stages, such as screening, scoping, impact prediction, significance, monitoring,

Sustainability 2019, 11, 3235; doi:10.3390/su11123235 www.mdpi.com/journal/sustainability

Sustainability 2019, 11, 3235 2 of 15

and follow-up. The prioritization of particular EIA stages has also been found in other reviews of EIA’s
knowledge gaps [5–10].
EIS review, that is, the administrative stage in which public authorities review EISs and other
pieces of information, has long been investigated, but mainly through the lenses of content quality.
For decades, practitioners and policy-makers have been concerned about what contents should be
included or not in EISs so that informed decisions can be made [11–15]. While there have been studies
targeting specific aspects of the review process, such as the role of external stakeholders [16], advantages
and disadvantages of individuals versus group reviews [17], and knowledge management [18,19],
among others, there is still a scarcity of in-depth empirical research on how authorities review EISs.
The scarcity of empirical information on the public administration of EIS reviews is a problem,
because the intricacies of this stage directly affect EIA decisions. Despite its various technical and
scientific facets, EIA has a strong political dimension [20] that deals with high dosages of uncertainty,
value-laden trade-offs, and subjectivity. These ‘fuzzy’ elements of the decision-making process are to a
great extent judged in the review stage. Sense-making around what should be a good or bad decision
is to a great extent ‘manufactured’ in the review process [21]. Thus, understanding how this stage
works is a fundamental step towards the promotion of more transparent, legitimate, and efficient EIAs.
The main objective of this study was to explore three administrative traits of EIS review in the
empirical context of Brazil and Portugal: (1) responsibility and profile of reviewers; (2) procedures
and information inputs; and (3) scope of review reports. More specifically, this article critically and
comparatively explored how the national Portuguese environmental agency, APA (Portuguese acronym
of Portuguese Environment Agency), and the Minas Gerais State environmental agency, SEMAD
(acronym of State Secretariat for Environment and Sustainable Development) manage the review of
EISs. In light of this analysis, a number of recommendations are made as to how EIS reviews can
be enhanced to deliver more substantive and procedural results. The research focuses on two very
different empirical contexts (i.e., national agency in a developed country versus state agency in a
developing country) to capture a more diverse picture of current EIS review practices.
This study was structured in five sections. The next one reviews some of the key approaches to
EIS review. The methodology is explained in Section 3. Section 4 presents and discusses the findings.
Finally, Section 5 draws concluding remarks.

2. EIS Review Approaches

The world’s diverse EIA legislations and institutional arrangements have long been inspiring
cross-country and within-country comparisons of EIA systems [6,22–24]. While this literature has
been showing many approaches to EIS review, Ross [25] has long noted that this stage is mainly
concerned with three key areas of inquiry: (1) whether EIS focuses on key issues (compliance with
Terms of References and expected assessment scope); (2) whether information in EIS is scientifically
and technically sound; and (3) whether EIS can be clearly understood by decision makers. This
‘quality assurance’ facet of the EIS review stage, mirrored in IAIA’s best practice principles [26],
is arguably the most common in worldwide practice. Nevertheless, quality assurance can be carried
out under different formal and informal institutional arrangements [27]. For example, the EIS review
can be an internal responsibility of the proponent agency, or carried out by environmental authorities,
interagency technical groups, independent review panels, or permanent commissions. The use of
external independent reviewers based on review panels or permanent commissions, while common
in countries like Canada and the Netherlands, is uncommon worldwide. As noted by NCEA [28]
(p. 2)., “( . . . ) in most countries, review is the responsibility of the competent authority on EIA or the
competent authority for decision-making on a proposed project”.
The procedures and outcomes of reviews can also vary substantially. For example, Wood [6]
in his comparison of EIS review in the United States, the UK, The Netherlands, Canada, Australia,
and New Zealand, realized that EISs are not always publicly reviewed; moreover, proponents do not
always need to respond to the points raised by authorities. Across the diverse practices of Australian
Sustainability 2019, 11, 3235 3 of 15

provinces, EIS reviews tend to go beyond quality verification to include public consultations and the
issuing of a decision recommendation for agencies in charge of decision making and approvals [29].
These recommendations, as highlighted by Thomas and Elliot [30], are actually ‘advice’, as authorities
are not required to adopt them. In the UK, according to Glasson et al. [31], EIS review also aims to
“advise on whether a project should be allowed to proceed”, although this is not mandatory. The main
generic steps of the review process have been outlined by Sadler [27] (p. 124) as follows:

1. Identify deficiencies in the EIA report using reference materials;

2. Determine shortcomings that are crucial to restricting informed decision making, separate these
from the less important deficiencies, and focus primarily on the former in the review; and
3. Recommend to the responsible authority how and when any serious shortcomings should be
remedied to assist decision making.

Some EIA capacity-building programs, like the one prepared by the International Institute for
Environment and Development (IIED) for Tanzania, prescribe particular ‘good practice’ criteria for the
EIS review stage, such as: seeking independent opinion, following content guidelines, holding public
hearings and consultations, empowering reviewers to request additional information and, eventually,
rejecting EISs on grounds of inadequacy [32]. Judging, however, which procedural or institutional
approach is the best in a particular jurisdiction is a delicate task, because the effectiveness of each
approach can be context-dependent. Particularly, the strengths of a country’s EIS review process may
not work elsewhere as expected [33].
In any case, the success of the review process is tightly related to the capacity of reviewers to judge
whether EISs and other sources of information meet both legal and technical requirements, as well as
whether further information should be provided. For this purpose, structured reviewing guidelines
or checklists have long been perceived to be helpful [34]. However, such checklists, as mentioned in
the previous section, are often concerned with the scope and quality of content and communication,
overlooking managerial issues like effectiveness of procedures, information channels, and stakeholder
responsibilities. Moreover, reviewers’ roles in providing advice to authorities about whether or not a
project should proceed still remain an area of limited guidance.

3. Methodological Approach
The scarcity of empirical studies on EIS review stems in part from the scarcity of easily accessible
data related to this stage. Mere reviews of legislation, which is a common analytical choice in
comparative EIA policy studies, can only capture broad traits of the review process because, as noted
by Glasson, Therivel, and Chadwick [31], many administrative decisions are not mandatory and can
only be understood by those who are directly involved in the system. To overcome such data barriers,
this study adopted a qualitative multiple-case study approach informed by participant observation,
unstructured interviews, and content analysis of internal review documents.
Among the many reasons why scholars decide to adopt qualitative methodological approaches
is because they want to “engage in the complex, time-consuming process of data analysis through
the ambitious task of sorting through large amounts of data and reducing them to a few themes or
categories” [35] (p. 41). This reason is certainly reflected here, as this study aimed at capturing not
only formal procedures, but mainly the vast amount of informal and publicly unavailable practices
that occurs in the daily administrative routine of EIA authorities.

3.1. Case Studies

This research, while focusing on the empirical context of Brazil and Portugal, falls into the
category called by Yin [36] as a multiple-case study. Data were collected in SEMAD, the Brazilian
Minas Gerais State Environmental Agency, and in APA, the Portuguese Environmental Agency. While
more time-consuming, multiple cases tend to be more compelling insofar as their contrasting findings
provide a more robust basis for interpreting social phenomenon. The selection of these two cases was
Sustainability 2019, 11, 3235 4 of 15

supported by the following criteria: (i) addressing distinctive EIA legal and institutional frameworks;
(ii) covering different EIS reviewing systems; (iii) covering different geographic and socio-economic
contexts; and (iv) covering countries with the same national official language and common cultural
aspects, allowing an easier cross-comparison between the documents and data analyzed. In addition,
the two cases were purposefully selected not only because they are convenient, as the co-authors of
this study speak Portuguese and have contacts in both the Brazilian and Portuguese authorities, but
mainly because they represent very different points in the spectrum of EIA systems. Both agencies
are well-established institutions with decades of experience in EIS review. However, SEMAD is a
subnational environmental authority in a developing country and APA is a national environmental
authority in a developed country within the European Union. Such contrasting geographic and
socioeconomic contexts are expected to enrich the discussions and generate more valuable lessons to
scholars and practitioners worldwide.

3.2. Participant Observation and Interviews

Participant observation is “( . . . ) a method of data collection in which the researcher takes part in
everyday activities related to an area of social life in order to study an aspect of that life through the
observation of events in their natural contexts.” [37] (p. 599). Some scholars, like Babbie [38], refer to
this method as ‘field work’, because participants not always ‘participate’ on what they are researching.
Regardless of the terminology, this study conducted ‘participant observation’ in SEMAD and APA to
characterize internal procedures and information inputs. Given the lack of published material about
this, the observation of review administration was fundamental to generate the data presented further
below. During these observations, a number of clarifying, unstructured interviews were carried out
with both SEMAD and APA staff. In July 2018, one of the co-authors of this article systematically
observed the procedures and information inputs in SEMAD. The same systematic observation was
carried out earlier in APA, in January 2017, when the same co-author was granted access to observe the
reviewing practices of the Portuguese agency and conduct a number of interviews with internal staff.

3.3. Content Analysis

EIS review reports are arguably the most important documental evidence of the review process.
This document, which may or may not be publicly available, presents the outcomes of the review
process and eventual recommendations. EIS review reports were classified as ‘knowledge repositories’
for environmental agencies, as their contents can drive institutional learning [19]. An arbitrary sample
of 12 EIS review reports was analyzed: 6 from SEMAD and 6 from APA, as presented in Table 1. The
choice of a non-probabilistic sample was deemed appropriate because of the exploratory nature of the
research [38].
While EIS content checklists abound in the EIA literature [15], content checklists for review reports
are rare. Scholars have mostly been concerned with what is inside EISs, rather than with what is
communicated in Review Reports. This study had to create a unique checklist with 15 criteria to guide
the content analysis. These criteria were arbitrarily chosen by authors to enable an understanding
of the following aspects of the review process: participation, procedures, methods, scope or reach,
and recommendations. The analyzed items were judged as ‘explicit’ or ‘not explicit’. Findings of
the content analysis, presented further on in Table 2, were counted as 1, when explicit, or 0, when
nonexplicit. Moreover, counts were aggregated to understand what contents are most often disclosed
within and across environmental authorities.
The review reports, combined, had a total of 942 pages, which were systematically analyzed
against the checklist of 15 criteria. Findings from the content analysis, following methodological good
practice [39], were systematically organized in spreadsheet software to facilitate the identification of
patterns and relevant information.
Sustainability 2019, 11, 3235 5 of 15

Table 1. Sample of EIS review reports analyzed in the study.

Number of Length of
EIS Type
Document Reviewers EIS Review
Jurisdiction Project Typology (Licensing Publication
Code Explicit in EIS Report
Type)
Review Report (in Pages)
December
PT-1 Photovoltaic power plant 9 81 EIA/RNT
2018
August
PT-2 Hydraulic circuit 10 145 EIA/RNT
Portugal 2018
PT-3 Accessibility of sea port 11 151 EIA/RNT July 2018
PT-4 Modernization of railway 9 263 EIA/RNT April 2018
March
PT-5 Extraction of limestone 10 90 EIA/RNT
2018
February
PT-6 Resin factory 11 59 EIA/RNT
2018
MG-1 Sugar factory 5 39 EIA/RIMA July 2018
EIA/RIMA
Minas MG-2 Small hydropower plant 2 21 May 2018
e PCA
Gerais
January
(Brazil) MG-3 Thermoelectric plant 3 40 EIA/RIMA
2018
Extraction of sand and September
MG-4 3 23 RCA/PCA
gravel 2018
MG-5 Furniture factory 4 22 RCA/PCA July 2018
March
MG-6 Metallurgy 3 8 RCA/PCA
2018

4. Results and Discussions

4.1. Institutional and Regulatory Frameworks of the EIA Systems in Brazil and Portugal
SEMAD, the Brazilian state agency, has jurisdiction over a larger and more populated area when
compared to APA. The territory of the Brazilian state of Minas Gerais (586,522 km2 ) is more than 6 times
larger than Portugal’s (92,256 km2 ), and its population (~21 million) is about twice the population of
Portugal (~10.5 million). However, the EIA processes of SEMAD and APA are difficult to compare
with simple numbers, because these processes are implemented in very different institutional and
regulatory contexts.
In Portugal, EIA was defined as one of the policy tools of the Base Law of the Environment, initially
established by the Law 11/1987, 7th of April, which specified requirements for the minimum contents
of Environmental Impact Statements (Art. 31), and recently updated by the Law 19/2014, 14th of Abril.
Yet the legal regime for EIA was formally approved 3 years later, through the transposition of the
European Union Directive 85/337/EEU to the Portuguese legislation through Decree-Law (DL) 186/90,
6th of June. In recent years, EIA in Portugal was mainly legislated by Decree-Law (DL) 151-B/2013, 31st
of October, which transposed the European Union Directive 2011/92/EU [40]. More recently, the DL
152-B/2017, 11th of December, transposed the revised European Union Directive 2014/52/EU, which,
among other things, pushed member states’ EIA processes to address issues such as climate change
and also required EIA processes to ensure that EIS preparation and review are carried out by people
with sufficient expertise [41].
Portugal has today a typical EIA process structured in the following stages: screening, scoping,
elaboration of impact assessment studies, review, decision making, and follow-up. EIA can be triggered
by both private and public projects that are likely to have significant environmental impacts. Screening
lists determines which projects are subject to EIA.
The EIS Review stage in the Portuguese EIA process is to a large extent shaped by Arts. 9, 12, 13,
14, 15, 16 of the DL 151-B/2013 and the DL 152-B/2017 revision, which established minimum content
requirements for EISs, as well as a revision procedure carried out by an interdisciplinary evaluation
committee (EC) led by the EIA authority but with participants from various public institutions related
to the effects of the project. The EC is responsible for verifying the conformity of the EIS document
and publishing its findings in a technical review document that will inform a final decision by the EIA
Sustainability 2019, 11, 3235 6 of 15

authority. This decision is known as the ‘Declaration of Environmental Impact’, whose Portuguese
acronym is DIA. The decision can be favorable, favorable with conditions, or unfavorable.
The EIA system coordinated by SEMAD in the Brazilian state of Minas Gerais is embedded within
the country’s federal legislation. EIA first emerged in Brazil in the 1970s driven by the World Bank
and embryonic state legislation in São Paulo and Rio de Janeiro [42,43]. However, it only started to
become a widespread practice in the late 1980s, after federal legislation [44] and regulations made EIA
mandatory for both public and private projects. EIA was even included in Article 225 of the 1988
Brazilian constitution, which requires potentially environmentally harmful construction works and
activities to prepare ‘prior environmental impact studies’.
The main requirements for EIA in Brazil are set by the National Council on the Environment
Resolution 01/1986, whose Portuguese acronym is CONAMA [45]. This resolution exemplifies a list
of projects that should be subject to EIA and establishes minimum content requirements for EISs.
In the 1990s, CONAMA Resolution 237/1997 [46] further regulated the link between EIA and Brazil’s
three-phased environmental licensing system and also provided incentives for the creation of simplified
impact assessment studies at the federal, state, and municipal levels. As recently noted by Fonseca and
Rodrigues [47], it is difficult to generalize the traits of the Brazilian EIA system, because administrative
procedures and EIS documents can vary substantially within and across jurisdictions.
In the Minas Gerais state, EIA was regulated in 1990 by the Normative Deliberation (known by the
acronym DN) 01/1990 of the State Council for Environmental Policy (COPAM). This regulation was later
revised by DN COPAM 74/2004 and, more recently, by DN COPAM 217/2017. The latter established an
EIA system that is confusingly embedded in the licensing procedure. Unlike the Portuguese legislation
and other Brazilian states like São Paulo, in Minas Gerais, there is neither an explicit definition of EIA
nor a list of projects that are subject to EIAs. While the state adopts a risk assessment approach in the
screening stage to classify projects and determine likely studies, the decision as to which projects are
subject to EIA is discretionary. Projects can be subject to EIA not only in the planning and feasibility
phases, but also during the operation phase, when the project has already been constructed on the
ground and is in full operation. For the latter, the state created ‘correction environmental licenses’ to
give an opportunity for incompliant enterprises to go through EIA. The general rule in Minas Gerais is
that a project can only be implemented after completing the EIA process and being granted a license.
However, given the high degrees of noncompliance with environmental laws in that state [48], SEMAD
created ‘corrective licenses’ to give an opportunity for illegal development projects to go through
ex-post impact assessments and enhance their environmental performance.
The impact assessment studies required in either the feasibility or construction and operation
phases of projects in Minas Gerais can be comprehensive (whose Portuguese acronym is EIA/RIMA)
or simplified (e.g., RCAs). The coordination of the EIA process is carried out by SEMAD’s regional
branches, known as SUPRAMs (Portuguese acronym of Regional State Environmental Offices), which
are also in charge of the decision making of less impactful projects. Decisions on high-class projects
are carried out by COPAM, a collegiate forum, whose final decision can be approved, approved with
conditions or denied. Moreover, unlike the Portuguese EIA system, in Minas Gerais, the EIS review
stage is not explicitly addressed in regulations. Review procedures and responsibilities are designed
and implemented at the discretion of civil servants and elected administrations. This study, however,
shed light on how discretion has been implemented in practice.

4.2. EIS Review’s Responsibilities in Portugal and Minas Gerais

As introduced in Section 2, the EIA literature has been recurrently concerned with the issue of
responsibility in EIS review, particularly of ‘institutional’ responsibility, that is, which institutions
are involved in the review and what their roles and powers are. The legislation and participant
observations revealed that, in general, the dynamics of institutional responsibility are somewhat
similar in the Portuguese and Minas Gerais’ EIA processes. In both countries, EIA is triggered by
the need to obtain a declaration or license that authorizes project implementation. In both countries,
Sustainability 2019, 11, 3235 7 of 15

EISs are prepared by proponents (which can hire private consultancies) and later reviewed by an
environmental authority. Decision making is also a competence of environmental authorities, i.e., APA
and SEMAD. A subtle difference, however, is that SEMAD, in addition to being the environmental
authority, is also, and always, the licensing authority; whereas in Portugal, there is a wide range of
government agencies and bodies that can function as licensing authorities. In most cases, APA is only
the environmental authority.
Despite these broad institutional similarities, SEMAD and APA have different approaches to
managing the responsibilities of people involved in EIS reviews. As presented in the previous section,
Portugal has a more inclusive and participative approach to conducting the review: EISs are reviewed
by an evaluation committee that, as mandated by law, must include reviewers from various external
public organizations whose knowledge areas are related to the project. In Minas Gerais, this is not
the case. Participant observation and interviews revealed that EISs are reviewed only and always
by internal staff of the environmental authority. Additionally, the number of people involved in the
review is also very different. The content analysis of the EIS review reports, whose full results are
presented in Table 2, indicated that in APA, EISs were reviewed by an average of 10 people with
different technical backgrounds. In Minas Gerais, an average of three internal analysts, including
someone from the legal department, were found to be in charge of reviewing EIS reports. Another
contrast between the two agencies is that APA always includes a step of EIS public consultations in
the review, whereas in SEMAD, public consultations are required mainly in the licensing of large,
potentially impactful projects.
Overall, these findings show that, although following similar institutional arrangements and
broad procedural steps, APA has a more open, participative, and interdisciplinary review than
SEMAD. APA’s approach mirrors more clearly some of the EIS review good practices highlighted in
the literature [26,27,49]. The superior number of people and interdisciplinary expertise in APA’s EIS
review process also suggests that the Portuguese agency has a more critical and potentially consistent
approach to ensuring quality information in decision making. After all, as Peterson [17] found in his
empirical comparison of group versus individual EIS review, “( . . . ) group assessment is more critical
than the individual assessment. This possibly results from a wider technical expertise and balancing of
subjective values and perspectives among group members” (p. 169).

4.3. Procedures and Information Inputs

The participant observations and content analysis of EIS review reports have helped to reveal
procedures and information inputs in the review process in both APA and SEMAD that are not explicit
in regulations, particularly in the case of Minas Gerais. The Portuguese review process, as shown
in Figure 1, clearly reflects the requirements of the national EIA legislation (DL 151-B/2013 and DL
152-B/2017 revision). The review is structured in two sequential phases: (1) analysis of EIS conformity;
and (2) analysis of environmental content conformity. The first phase, as required by law, targets
mostly the completeness of EISs. In the second phase, the main purpose is to evaluate the extent to
which the document meets content requirements. The review process only advances to the second
phase if the EC agrees that the EIS, the respective nontechnical summary and additional information
meet minimum quality criteria. To accomplish these tasks, the coordinator of the EIA process, after a
preliminary review of the EIS document, invites representatives for an evaluation committee. Once
created, the EC starts to evaluate the conformity of the EIS in light of both legislation and EC members’
technical preliminary reviews. Then, the process moves to a meeting with the project proponent
and/or respective consultants. The EC, if necessary (and that is often the case), can request additional
information to complement the EIS document.
Sustainability 2019, 11, 3235 8 of 15
Sustainability 2019, 11, x FOR PEER REVIEW 8 of 15

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Sustainability 2019, 11, 3235 9 of 15

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Sustainability 2019, 11, x FOR PEER REVIEW 9 of 15
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review procedures
procedures and information
and information inputs
inputs in the in the State
State Secretariat Secretariat and
for Environment for
Environment
Sustainable and Sustainable
Development (SEMAD,Development
Minas Gerais,(SEMAD,
Brazil). Minas Gerais, Brazil).

The
The differences
differences between
between the
the APA
APAandandSEMAD
SEMAD procedures
procedures areare more
more easily
easily perceived
perceived whenwhen one
one
compares
compares Figures 1 and 2. In Portugal, the review process is phased into, first, a verification of
Figures 1 and 2. In Portugal, the review process is phased into, first, a verification of
information
information completeness
completeness and,and, second,
second, aa verification
verification of
of content
content quality.
quality. Moreover,
Moreover, the the process
process has
has
more
moreinputs of information
inputs from from
of information internal and external
internal and organizations and more procedural
external organizations and moretransparency.
procedural
In Minas Gerais, the whole review process is conducted by a limited number
transparency. In Minas Gerais, the whole review process is conducted by a limited of internal
number staff
ofwithout
internal
participation from external organizations. The only opportunity for external public input
staff without participation from external organizations. The only opportunity for external public takes place
in eventual
input takes public
place inhearings.
eventual public hearings.
4.4. Comparative Analysis of EIS Review Reports
4.4. Comparative Analysis of EIS Review Reports
Findings from the content analysis, presented in Table 2, revealed the extent to which each of the
Findings from the content analysis, presented in Table 2, revealed the extent to which each of
12 EIS review reports met the list of 15 criteria. Such findings should be carefully considered because
the 12 EIS review reports met the list of 15 criteria. Such findings should be carefully considered
they are not judging ‘quality’ in the review process. They reveal degrees of information disclosure.
because they are not judging ‘quality’ in the review process. They reveal degrees of information
A review report with high counts of information disclosure, while more transparent, is not necessarily
disclosure. A review report with high counts of information disclosure, while more transparent, is
indicative of the quality of the review.
not necessarily indicative of the quality of the review.
Sustainability 2019, 11, 3235 10 of 15

Table 2. Explicit and non-explicit contents in EIS review reports from APA and SEMAD.

APA SEMAD
Analyzed Items
PT-1 PT-2 PT-3 PT-4 PT-5 PT-6 MG-1 MG-2 MG-3 MG-4 MG-5 MG-6 Total
Does it inform who participated in the review? 1 1 1 1 1 1 1 1 1 1 1 1 12
AI1: Participant reviewers
Does it inform the thematic areas of reviewers? 1 1 1 1 1 1 0 0 0 0 0 0 6
AI2: Procedures adopted in the
Does it inform what procedures were used in the review? 1 1 1 1 1 1 0 0 0 0 0 0 6
review
AI3: Characterization of the project Does it inform the characteristics of the project? 1 1 1 1 1 1 1 1 1 1 1 1 12
AI4: Project alternatives Does it address the project’s locational and/or technological alternatives? 0 0 1 1 1 0 1 1 1 0 0 0 6
AI5: Affected areas Does it address the spatial scope of the area to be affected by the project? 1 1 1 1 1 1 1 1 1 1 1 1 12
Does it address the characteristics of the physical environment in the area
1 1 1 1 1 1 1 0 1 1 0 0 9
AI6: Environmental diagnosis of the of influence of the project?
affected area Does it address the characteristics of the biotic environment? 1 1 1 1 1 1 1 1 1 1 0 0 10
Does it address the characteristics of the anthropic environment? 1 1 1 1 1 1 1 0 0 1 0 0 8
AI7: Identification of social and Does it address the likely impacts? 1 1 1 1 1 1 1 1 1 1 1 1 12
environmental impacts
Does it address the positive impacts? 1 1 1 1 1 1 1 0 1 0 1 0 9
Does it address the methods used to forecast impacts? 0 0 0 0 0 0 0 0 0 0 0 0 0
AI8: Prediction of magnitude of
Does it address the justification for methodological choices? 0 0 0 0 0 0 0 0 0 0 0 0 0
impacts
Does it address the indicators used? 0 0 0 0 0 0 0 0 0 0 0 0 0
Does it analyze the forecast? 1 1 1 1 1 1 0 1 1 0 0 0 8
Does it address the impact assessment methodology used to evaluate
AI9: Assessment of the importance 0 1 1 1 1 1 0 0 1 0 0 0 6
importance?
of impacts
Does it address the impacts considered important? 1 1 1 1 1 1 1 0 1 0 0 0 8
AI10: Measures taken for negative
Does it address mitigation measures? 1 1 1 1 1 1 1 1 1 1 1 1 12
impacts
AI11: Programs to monitor positive
Does it address monitoring programs? 1 1 1 1 1 1 1 1 1 1 1 0 11
and negative impacts
AI12: Public participation Does it address on the outcomes of public participation? 1 1 1 1 1 1 0 0 0 0 0 0 6
AI13: Related legal regimes Does it address legal regimes linked to the EIA process? 1 1 1 1 1 1 0 1 1 1 1 1 11
AI14: Relevant Stakeholder Does it address the opinion of other institutions involved in the EIA
1 1 1 1 1 1 1 1 0 0 0 0 8
Institutions process?
Does it recommend a final decision as to whether or not the project
1 1 1 1 1 1 1 1 1 1 1 1 12
AI15: Final Recommendation should proceed?
Does it justify the final recommendation? 1 1 1 1 1 1 0 0 0 0 0 0 6
Total 19 20 21 21 21 20 14 12 15 11 9 7
 Sustainability 2019, 11, x FOR PEER REVIEW 11 of 15
Sustainability 2019, 11, 3235 11 of 15
Sustainability 2019, 11, x FOR PEER REVIEW 11 of 15
The explicit contents found in the sample 12 EIS review reports helped to understand the scope
of the reviewcontents
The explicit and its likely
found effects
in the in decision making. Review reports, as
to shown in Figure 3, do not
The explicit contents found insample 12 EIS
the sample 12review reports
EIS review helped
reports helped understand
to understand the scope
the scope
provide
of the a and
balanced account of in
EISdecision
content.making.
They tend to emphasize particular intopics, such asnot
project
ofreview
the review its likely
and effects
its likely effects in decision Review
making. reports,
Review as
reports, shown
as shown Figure 3, do
in Figure 3, do not
characteristics,
provide a balanced affected
account areas,
of EIS and mitigation measures. Some issues of the EIS report, such as
provide a balanced account of content. TheyThey
EIS content. tendtend
to emphasize particular
to emphasize topics,
particular suchsuch
topics, as project
as project
prediction of
characteristics, magnitude,
affected areas, were
and not found to measures.
be clearly communicated by reviewers.
characteristics, affected areas, andmitigation Someissues
mitigation measures. Some issuesof of
thethe EIS report,
EIS report, such
such as as
prediction
prediction of magnitude,
of magnitude, were not were not to
found found to be clearly
be clearly communicated
communicated by reviewers.
by reviewers.
0 2 4 6 8 10 12
AI3: Characterization of the project 0 2 4 6 8 10 12
AI5: Affected areas
AI3:Measures
AI10: Characterization
taken forofnegative
the project impacts
AI7: Identification of social and AI5: Affected areas
environmental impacts
AI10: Measures
AI11: Programs to monitor taken for negative
positive impacts
and negative impacts
AI7: Identification of social and environmental
AI13: Related legalimpacts regimes
AI11: Programs to monitor positive and AI1:negative impacts
Participant reviewers
AI6: Environmental AI13: Relatedoflegal
diagnosis the regimes
affected area
AI1:AI15:
Participant reviewers
Final Recomendation
AI6: Environmental diagnosis
AI9: Assessment of the
of the affected of
importance area
impacts
AI15: Final
AI14: Relevant Recomendation
Stakeholder Institutions
AI9: Assessment of the importance
AI2: Procedures adopted of impacts
in the review
AI14: Relevant Stakeholder Institutions
AI4: Project alternatives
AI2: Procedures adopted in the participation
AI12: Public review
AI4: Project
AI8: Prediction alternatives
of magnitude of impacts
AI12: Public participation
AI8: Prediction of magnitude of impacts
Figure 3. Counts of explicit checklist content items in the sample of EIS review reports.
Figure 3. Counts of explicit checklist content items in the sample of EIS review reports.
Figure 3. Counts of explicit checklist content items in the sample of EIS review reports.
Differences in information disclosure were found to be very different between APA’s and
Differences in information disclosure were found to be very different between APA’s and SEMAD’s
SEMAD’s
Differences review reports. This
in This
information was expected
disclosure were because,toasbepreviously shown in TableAPA’s 1, the and
average
review reports. was expected because, as found
previously shown very in
different
Table 1, between
the average size of APA’s
size ofreview
SEMAD’s APA’s reports.
review reports
This (132
was pages) isbecause,
expected 5 times aslarger than theshown
previously average in size of 1,
Table SEMAD’s
the Reports
average
review reports (132 pages) is 5 times larger than the average size of SEMAD’s Reports (26 pages), a fact
size (26
that
pages),review
of APA’s a fact that suggests
suggests thatreports
the Portuguese
that the
(132 pages) is Portuguese
agency 5 times
tends larger
agency tends to be more
than transparent
to be more the average transparent
sizedisclose
and of SEMAD’s and disclose
more Reports
information
more
(26 pages), information
a fact about
that suggests the review process. As shown in Figure 4, APA’s reports disclosed, on
about the review process. that
As the Portuguese
shown in Figure agency
4, APA’stends to be more
reports transparent
disclosed, and disclose
on average, 85% of the
moreaverage,
checklist
85% ofabout
information the checklist
items, whereas the SEMADitems,
review whereas SEMAD
process.
disclosedAs 47%.shown disclosed
in Figure 47%.
4, APA’s reports disclosed, on
average, 85% of the checklist items, whereas SEMAD disclosed 47%.
100 88 88 88
83 83
Percentage of Met Criteria

90 79
100 80 88 88 88
83 83
Percentage of Met Criteria

90 70 79
80 60
70 50 58 63
60 40 50
63 46
50 30 58 38
APA
40 20 50 29
10 SEMAD 46
30 38
00 APA
20 29
10 SEMAD
00
Review Review Review Review Review Review
Report 1 Report 2 Report 3 Report 4 Report 5 Report 6
Review Review Review Review Review Review
Report
Figure
Figure 1 Report
4. Percentage
4. Percentage of of 2 Report 3
explicitcontents
explicit contentsin Report 4
in EIS review Report
reviewreports:
reports: 5
APA
APA Report
versus 6
SEMAD.
versus SEMAD.
Figure 4. Percentage of explicit contents in EIS review reports: APA versus SEMAD.
More important
More important than than these
these quantitative
quantitative contrasts
contrasts are are the
the qualitative
qualitative differences
differences between
between the
the
agencies’ review
agencies’ review reports. Overall,
Overall, the
the Portuguese
Portuguese review
review reports
reports provide
provide aa profoundly
profoundly more more detailed
More important reports.
than these quantitative contrasts are the qualitative differences between detailed
the
account
account of the
of the procedures,
procedures, scope,
scope, and criteria considered
and criteriareview
considered in the
inprovide review
the review process.
process. For For example,
example, APA,
APA,
agencies’ review reports. Overall, the Portuguese reports a profoundly more detailed
like SEMAD,
like SEMAD, discloses
discloses thethe reviewers
reviewers involved
involved the the process,
process, butbut APA
APA goesgoes aa step
step further to to explain the
the
account of the procedures, scope, and criteria considered in the review process. Forfurtherexample,explain
APA,
thematic expertise
thematic discloses
expertise theof each
of each reviewer.
reviewer. APA’s
APA’s reports
reports have
have specific chapters devoted to explaining the
like SEMAD, reviewers involved the process, butspecific
APA goes chapters
a stepdevoted
further to toexplain
explaining
the the
review process,
review process, whereas
whereas in
in SEMAD,
SEMAD, the
the explanation
explanation isiseither
either non-existent
non-existent oror confusingly
confusingly dispersed
dispersedin
thematic expertise of each reviewer. APA’s reports have specific chapters devoted to explaining the
thethe
in review
reviewreport. Considerations
report. Considerations of public
of public participation
participation werewerefound
foundin all six review reports of the
review process, whereas in SEMAD, the explanation is either non-existent or in all six
confusingly review reports
dispersed of
Portuguese
the Portuguese agency. In
agency. Minas
In Gerais,
Minas there
Gerais, were
there no
were mentions
no mentionsof public
of participation.
public participation.
in the review report. Considerations of public participation were found in all six review reports of
One ofofthethe
One most interesting findings of the content
theanalysis is related to the final recommendation
the Portuguese agency.most
In Minas interesting findings
Gerais, there were noof mentions content analysis
of public is related
participation. to the final
of the review
recommendation processes.
of the Each of the 12
review processes. review reports analyzed here recommended decision-makers
One of the most interesting findingsEach of of
thethecontent
12 review reports is
analysis analyzed
relatedhere to recommended
the final
to be favorable, to
decision-makers with
be conditions,
favorable, to the
with proposals.
conditions, to None
the of the None
proposals. reportsof recommended
the reports a rejection.
recommended
recommendation of the review processes. Each of the 12 review reports analyzed here recommended
aThe SEMAD
rejection.
decision-makers The reports
SEMAD
to be
didreports
favorable,
not explain
did
with
how
not or why
explain
conditions, to how
they recommended
or why
the proposals. they
None
approvals.
recommended
of the reports
However,
approvals. the APA
However,
recommended
a rejection. The SEMAD reports did not explain how or why they recommended approvals. However,
Sustainability 2019, 11, 3235 12 of 15

review reports not only justified their recommendations, but in 5 out of the 6 documents, they based
their recommendations on a quantitative weighted index of environmental impacts, which was a
legal requirement of DL 151-B/2013. By doing so, APA reviewers carried out a quantitative and
comparative analysis of ‘trade-offs’ of impacts, an issue that “lies at the heart of environmental impact
assessment” [50] (p. 13). While important, particularly in sustainability-oriented processes [51,52],
trade-off evaluations tend to be overlooked or poorly understood in the decision-making process. This
might suggest that APA’s reports are ‘better’ than SEMAD’s. From a transparency standpoint, this is
certainly the case. However, from a technical point of view, this will depend on the robustness of the
weighted index used during the review. Interestingly, the revised DL 152-B/2017, which transposed
the Directive 2014/52/EU, is no longer requiring an ‘index’. This suggests that the former practice,
captured in this article, might have been perceived as having undesirable effects in decision making.
Future studies should follow up on this regulatory change.

5. Conclusions
This study evaluated the responsibilities, procedures, information inputs, and scope of EIS review
within two environmental authorities: APA, in Portugal, and SEMAD, in the Brazilian state of Minas
Gerais. Based on a predominately qualitative methodology informed by participant observation,
unstructured interviews, and content analysis, the study has provided what is arguably one of the
most detailed characterizations of EIS review to date. Although following a similar logic, EIS review
was found to be profoundly different in APA and SEMAD. Such differences were only possible to
capture by analyzing the details of the review steps that are often presented in simplified ways in
the literature. Overall, the Portuguese agency was found to have a more structured, transparent,
participative, interdisciplinary, detailed, and grounded EIS review, thus meeting more clearly some of
the good practices that are often highlighted in the literature. These findings are likely to be relevant to
stakeholders from various countries, as the issues addressed here are commonly found in international
practice. Moreover, given its applied nature, findings are likely to be relevant not only to scholars but
also to practitioners, civil servants, and law and policy-makers.
The causes of the differences in EIS review found here are unclear. Future studies should further
evaluate whether Portugal is benefiting from being a European Union member and thus having the
opportunity to learn from the plurality of practices within the union, or if Portugal has a particular
administrative culture that fosters good reviewing practices. Future studies should also evaluate
whether findings related to SEMAD are restricted to the Minas Gerais state or mirror a broader situation
in Brazil. If the latter is the case, then there is a clear opportunity for capacity-building in that country,
something that has long been emphasized in the literature [53].
Regardless of the causes of such differences, this study has helped to expose the relevance of better
studying the EIS review process. Small details related to reviewers’ independence, public consultations,
and trade-off criteria, among others, are expected to affect perceptions around the legitimacy and
reliability of recommendations. These details might be influencing not only perceptions, but actual
decisions and related consequences to society and the environment. Therefore, it is fundamental that
scholars start to go beyond the description of the review process to understand its actual implications
to EIA effectiveness.

Author Contributions: Conceptualization, C.F.R., T.B.R. and A.F.; methodological design, C.F.R., T.B.R. and A.F.;
data collection and investigation, C.F.R.; writing of first draft, C.F.R.; translation to the English language, A.F.;
figures and tables, C.F.R. and A.F.; revisions and final approval of manuscript, C.F.R., T.B.R. and A.F.
Funding: Part of this research was conducted during an international scholarship (PDSE) supported by CAPES –
Brazilian Federal Agency for Support and Evaluation of Graduate Education within the Ministry of Education
of Brazil. The study was also partly funded by the Brazilian National Council for Scientific and Technological
Development (CNPq), grant number 311201/2018-0. CENSE is financed by Fundação para a Ciência e Tecnologia,
I.P., Portugal (UID/AMB/04085/2019); this funding source played no part in the design, analysis, interpretation,
or writing-up of the paper or in the decision to publish.
Sustainability 2019, 11, 3235 13 of 15

Acknowledgments: The authors are grateful to all interviewees and agencies employees for sharing their
knowledge and experience. They are also grateful to the various colleagues in SEMAD, CENSE, and UFOP. The
first author is particularly grateful to Hugo Rodrigues de Araújo, for his kind and profound help in several stages
of this study.
Conflicts of Interest: The authors declare no conflict of interest.

References
1. Bond, A.; Pope, J. Editorial: The state of the art of impact assessment in 2012. Impact Assess. Proj. Apprais.
2012, 30, 1–4. [CrossRef]
2. IAIA. What Is Impact Assessment? International Association for Impact Assessment (IAIA): Fargo, ND,
USA, 2009.
3. Morrison-Saunders, A. Advanced Introduction to Environmental Impact Assessment; Edward Elgar Publishing:
Cheltenham, UK, 2018.
4. Morgan, R.K. Environmental impact assessment: The state of the art. Impact Assess. Proj. Apprais. 2012, 30,
5–14. [CrossRef]
5. Lawrence, D.P. Impact Assessment: Practical Solutions to Recurrent Problems and Contemporary Challenges;
John Wiley & Sons: Hoboken, NJ, USA, 2013.
6. Wood, C. Environmental Impact Assessment: A Comparative Review; Pretice Hall: Harlow, UK, 2003.
7. Pope, J.; Bond, A.; Morrison-Saunders, A.; Retief, F. Advancing the theory and practice of impact assessment:
Setting the research agenda. Environ. Impact Assess. Rev. 2013, 41, 1–9. [CrossRef]
8. Morrison-Saunders, A.; Pope, J.; Gunn, J.A.E.; Bond, A.; Retief, F. Strengthening impact assessment: A call
for integration and focus. Impact Assess. Proj. Apprais. 2014, 32, 2–8. [CrossRef]
9. Fischer, T.B.; Noble, B. Impact Assessment Research—Achievements, Gaps and Future Directions. J. Environ.
Assess. Policy Manag. 2015, 17, 1501001. [CrossRef]
10. Retief, F. The evolution of environmental assessment debates: Critical perspectives from South Africa.
J. Environ. Assess. Policy Manag. 2010, 12, 375–397. [CrossRef]
11. Lee, N.; Colley, R. Reviewing the Quality of Environmental Statements; Occasional Paper Number 24; University
of Manchester: Manchester, UK, 1992.
12. Cooper, L.M.; Sheate, W.R. Cumulative effects assessment: A review of UK environmental impact statements.
Environ. Impact Assess. Rev. 2002, 22, 415–439. [CrossRef]
13. Landim, S.N.T.; Sánchez, L.E. The contents and scope of environmental impact statements: How do they
evolve over time? Impact Assess. Proj. Apprais. 2012, 30, 217–228. [CrossRef]
14. Lee, N.; Brown, D. Quality control in environmental assessment. Proj. Apprais. 1992, 7, 41–45. [CrossRef]
15. Anifowose, B.; Lawler, D.M.; van der Horst, D.; Chapman, L. A systematic quality assessment of
Environmental Impact Statements in the oil and gas industry. Sci. Total Environ. 2016, 572, 570–585.
[CrossRef]
16. Lima, L.H.; Magrini, A. The Brazilian Audit Tribunal’s role in improving the federal environmental licensing
process. Environ. Impact Assess. Rev. 2010, 30, 108–115. [CrossRef]
17. Peterson, K. Quality of environmental impact statements and variability of scrutiny by reviewers. Environ.
Impact Assess. Rev. 2010, 30, 169–176. [CrossRef]
18. Bond, A.J.; Viegas, C.V.; Coelho, C.C.; Selig, P.M. Informal knowledge processes: The underpinning for
sustainability outcomes in EIA? J. Clean. Prod. 2010, 18, 6–13. [CrossRef]
19. Sánchez, L.E.; André, P. Knowledge management in environmental impact assessment agencies: A study in
Québec, Canada. J. Environ. Assess. Policy Manag. 2013, 15, 1350015. [CrossRef]
20. Cashmore, M. The role of science in environmental impact assessment: Process and procedure versus
purpose in the development of theory. Environ. Impact Assess. Rev. 2004, 24, 403–426. [CrossRef]
21. Willis, K.G. Judging Development Control Decisions. Urban Stud. 1995, 32, 1065–1079. [CrossRef]
22. Lim, G.-C. Theory and Practice of EIA Implementation: A Comparative Study of Three Developing Countries.
Environ. Impact Assess. Rev. 1985, 5, 133–153. [CrossRef]
23. Advisian. International Review of Environmental Assessment Processes; Advisian: Calgary, AB, Canada, 2016.
24. Glasson, J.; Salvador, N.N. EIA in Brazil: A procedures-practice gap. A comparative study with reference to
the European Union, and especially the UK. Environ. Impact Assess. Rev. 2000, 20, 191–225. [CrossRef]
Sustainability 2019, 11, 3235 14 of 15

25. Ross, W.A. Evaluating environmental impact statements. J. Environ. Manag. 1987, 25, 137–147.
26. Senécal, P.; Goldsmith, B.; Conover, S.; Sadler, B.; Brown, K. Principles of Environmental Impact Assessment
Best Practice. Available online: http://www.iaia.org/publicdocuments/special-publications/Principles%20of%
20IA_web.pdf (accessed on 20 January 2011).
27. Sadler, B. Environmental Assessment in a Changing World: Evaluating Practice to Improve Performance; Canadian
Environmental Assessment Agency (CEAA): Ottawa, ON, Canada; International Association for Impact
Assessment (IAIA): Ottawa, ON, Canada, 1996.
28. NCEA. Review in EIA: Memorandum by the NCEA—Part of a Three Year Co-Operation Project on EIA between the
Burundi Ministry for Water, Environment, Urbanism and Spatial Planning (MEEATU) and the NCEA; Netherlands
Commission for Environmental Assessment (NCEA): Utrecht, The Netherlands, 2012.
29. Morrison-Saunders, A.; Bailey, J. Transparency in environment impact assessment decision-making: Recent
developments in Western Australia. Impact Assess. Proj. Apprais. 2000, 18, 260–270. [CrossRef]
30. Thomas, I.; Elliot, M. Environmental Impact Assessment in Australia: Theory & Practice; The Federation Press:
Annandale, VA, USA, 2005.
31. Glasson, J.; Therivel, R.; Chadwick, A. Introduction to Environmental Impact Assessment; Routledge: London,
UK; New York, NY, USA, 2005.
32. Mwalyosi, R.; Hughes, R.; Howlett, D. Orientation Course on Environmental Impact Assessment in Tanzania
Resource Handbook; International Institute for Environment and Development: London, UK, 1999.
33. Günther, M.; Geißler, G.; Köppel, J. Many roads may lead to Rome: Selected features of quality control
within environmental assessment systems in the US, NL, CA, and UK. Environ. Impact Assess. Rev. 2017, 62,
250–258. [CrossRef]
34. Morgan, R.K. Environmental Impact Assessment: A Methodological Approach; Springer: Norwell, MA, USA, 1998.
35. Creswell, J.W. Qualitative Inquiry & Research Design: Choosing Among Five Approaches; SAGE Publications:
Thousand Oaks, CA, USA, 2007.
36. Yin, R.K. Case Study Research: Design and Methods; SAGE Publications: Thousand Oaks, CA, USA, 2003.
37. Given, L.M. The SAGE Encyclopedia of Qualitative Research Methods: Volumes 1 & 2; SAGE Publications:
Thousand Oaks, CA, USA, 2008.
38. Babbie, E. The Practice of Social Research; Cengage Learning: Wadsworth, OH, USA, 2013.
39. Krippendorff, K. Content Analysis: An Introduction to Its Methodology; SAGE Publications: Thousand Oaks,
CA, USA, 2004.
40. European Union. Directive 2011/92/EU of the European Parliament and of the Council of 13 December 2011 on the
Assessment of the Effects of Certain Public and Private Projects on the Environment; European Parliament and of
the Council: Brussels, Belgium, 2012.
41. Ramos, T.B.; Mascarenhas, A.; Polido, A. Challenges and opportunities for the revised EIA Directive
implementation in Portugal. UVP Rep. 2016, 30, 82–87.
42. Sánchez, L.E. Development of Environmental Impact Assessment in Brazil. UVP Rep. 2013, 27, 193–200.
43. Moreira, I.V. EIA in Latin America. In Environmental Impact Assessment: Theory and Practice; Wathern, P., Ed.;
Routledge: London, UK; New York, NY, USA, 1988; pp. 239–253.
44. Brazil, Lei No 6938, de 31 de agosto de 1981. Dispõe Sobre a Política Nacional do Meio Ambiente, Seus Fins e
Mecanismos de Formulação e Aplicação, e dá Outras Providências; Presidência da República, Casa Civil, Subchefia
para Assuntos Jurídicos: Brasília, Brazil, 1981. Available online: http://www.planalto.gov.br/ccivil_03/leis/
l6938.htm (accessed on 11 June 2019).
45. CONAMA. Resolução CONAMA Nº 001/1986—Dispõe Sobre Critérios Básicos e Diretrizes Gerais Para o Relatório
de Impacto Ambiental—RIMA; Conselho Nacional do Meio Ambiente (CONAMA): Brasília, Brazil, 1986.
46. CONAMA. Resolução CONAMA Nº 237/1997—Regulamenta os Aspectos de Licenciamento Ambiental Estabelecidos
na Política Nacional do Meio Ambiente; Conselho Nacional do Meio Ambiente (CONAMA): Brasília, Brazil, 1997.
47. Fonseca, A.; Rodrigues, S.E. The attractive concept of simplicity in environmental impact assessment:
Perceptions of outcomes in southeastern Brazil. Environ. Impact Assess. Rev. 2017, 67 (Suppl. C), 101–108.
[CrossRef]
48. Garcia, L.C.; Fonseca, A. The use of administrative sanctions to prevent environmental damage in impact
assessment follow-ups. J. Environ. Manag. 2018, 219, 46–55. [CrossRef]
49. European Comission. Guidance on EIA-EIS Review; European Comission: Luxembourg, 2001.
 Sustainability 2019, 11, 3235 15 of 15

50. Retief, F.; Morrison-Saunders, A.; Geneletti, D.; Pope, J. Exploring the psychology of trade-off decision-making
in environmental impact assessment. Impact Assess. Proj. Apprais. 2013, 31, 13–23. [CrossRef]
51. Gibson, R.B. Sustainability assessment: Basic components of a practical approach. Impact Assess. Proj. Apprais.
2006, 24, 170–182. [CrossRef]
52. Morrison-Saunders, A.; Pope, J. Conceptualising and managing trade-offs in sustainability assessment.
Environ. Impact Assess. Rev. 2013, 38, 54–63. [CrossRef]
53. Kirchhoff, D. Capacity building for EIA in Brazil: Preliminary considerations and problems to be overcome.
J. Environ. Assess. Policy Manag. 2006, 8, 1–18. [CrossRef]

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