En este Boletín Usted encontrará

BOLETIN
MENSUAL
No. 12: Agosto, 2009
En esta edición del boletín BICECA encontrará:
1. World Bank Environmental Development Policy Loan to BNDES: Moving Money or
Mainstreaming?
2. Environment Amazon Dieback
3. Amazon in Peril: Dams Threaten Rainforest Biodiversity
4. Eficiência Económica: Riscos e Custos Ambientais da Reconstrução da Rodovia BR-319.
Resumo Executivo
Para mayor información sobre BICECA y los proyectos que viene haciendo seguimiento visitar la
página de internet:
http://www.biceca.org
World Bank Environmental Development Policy Loan to BNDES: Moving
Money or Mainstreaming Environment?1
By Vincent McElhinny
Since 2004, the World Bank has introduced Development Policy Loans (DPLs) as a “softer and gentler” form of
conditionality to replace the adjustment loans that had became a lightning rod for public criticism. External critiques
of policy-based lending have emphasized the misuse of disbursement conditions as being ineffective, intrusive, and
in some instances harmful.2 Despite these concerns, Development Policy Operations (DPOs) have represented 35%
of all Bank lending in recent years. In the 2008-2009 fiscal year, DPOs shot up to over 50% of all WBG lending.
In a new set of DPLs for Brazil, Peru, and Colombia, the World Bank has begun to focus on various environmental
policy reforms. In this article, we review the background and concerns associated with development policy lending
since 2004, and then offer a detailed analysis of the Brazilian Sustainable Environmental Management (SEM) DPL.
In November of 2008, the WB announced a $US 1.3 billion development policy loan to the Brazilian National Bank
for Economic and Social Development (BNDES).3 The DPL, which was approved in March 2009 but awaits Senate
ratification to disburse the first $US 600 million tranche, is the first operation in a series of two loans which span the
1
This article benefited from comments and suggestions from Brent Millikan of Amigos da Terra – Amazonia; Pedro Bara-Neto,
World Wildlife Fund-Brazil; Josh Lichtenstein, BIC.
2
For a summary of the controversy, see Koberle, Stephan (2003), Should Policy-Based Lending Still Involve Conditionality?,
The World Bank Research Observer, Vol. 18, pp. 249-73.
3
The implementing agencies are the Ministry of Finance, the Ministry of Environment and BNDES.
period 2008-2010.4 According to the loan documents, the SEM DPL aims to support the Government of Brazil
(GoB) efforts to (i) improve the effectiveness and efficiency of policies and guidelines of the Brazilian
environmental management system; and (ii) further integrate principles of environmentally sustainable development
in the development agenda of key sectors.
What is most striking about the SEM DPL is its connection to nearly every major climate related legislative or
policy initiative in Brazil. The loan lists as prior actions or triggers (Bank labels for conditions) the restructuring of
the federal environmental agency (IBAMA) to speed up environmental licensing; the approval and implementation
of a National Climate Change Action Plan; an Environmental and Social Institutional Policy for BNDES, including
the formulation of sub-sectoral social/environmental guidelines for key investment sectors such as energy, sugar
cane - biofuels, cattle among others; the regulation of the Amazon Fund;5 support for and implementation of Brazil‟s
Public Forest Management Law.
The expected results of the DPL predict increases in renewable energy production, fewer judicially challenged
environmental licenses, reduced GHG emissions and deforestation, as well as full social-environmental screening,
approval and monitoring of all new BNDES projects.
Civil society organizations with interest in the SEM DPL have written two letters to World Bank officials raising
questions about the lack of full transparency or a clear consultation plan for a loan of this significance. 6 In the
context of the ongoing review of the World Bank‟s information disclosure policy, the SEM DPL highlights one of
the many weaknesses in the Bank‟s current practices. 7 Perhaps most surprising is the fact that no SEM DPL
documents have been translated into Portuguese.
What information that has been made public points to a number of additional substantive concerns regarding the
coherence of the Brazilian development policies and the risks associated with the proposed modalities of Bank
support. These risks were underscored in a second April 22 letter to Makhtar Diop, the World Bank Country
Director in Brazil. Among those risks outlined in greater detail below, are the lessons not apparently learned about
uneven performance of past WB policy loans to achieve improved environmental performance, the backpedaling on
strategic environmental analysis tools for the energy sector, the gaps in arguments favoring expedited environmental
licensing, and the absence of any public consultation plan for the formulation of a social-environmental institutional
policy for BNDES.
Despite the best intentions of the World Bank to have the SEM DPL provide positive incentives for environmentally
sustainable development policy in Brazil, the operation is constrained by the troubled nature of DPOs within the
World Bank and the mistakes made so far in how the operation has been prepared and implemented. The Brazilian
SEM DPL offers an important test for how the World Bank will be able to deploy new knowledge based instruments
in complicated policy contexts.
Background to the Brazilian DPL:
4
See First Programmatic Development Policy Loan for Sustainable Environmental Management (P95205), which as of August
20, 2009 has not disbursed.
http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/0,,countrycode:BR~menuPK:64820017~pagePK:64414648~piPK:
64414956~subTitle:All%20Loans~theSitePK:40941~pageNo:1~pageSize:Show%20All,00.html
5
For more on the Amazon Fund, see www.fondoamzonia.gov.br
To read correspondence between civil society and the Bank on the DPL, see www.bicusa.org....
7
See Feb. 27, 2009 letter to WB Vice President Pamela Cox signed by ten Brazilian and international organizations. The
approach paper for the proposed revision to the World Bank information disclosure policy suggests that future draft Program
Documents, such as the PGD for the SEM DPL, would be made public prior to Board approval. However, there is no
commitment to publish related technical documents, aide memoires, or monitoring reports.
6
It is important to understand the context from which the SEM DPL emerged, which reflects a fundamental shift in
power relations between the Brazilian government and the interests that have historically controlled the World Bank.
In the current Country Partnership Strategy, the Bank was obliged to confess that it would no longer act like a
“shadow government” to its Brazilian partners. This public act of remorse was in part motivated by the poor
performance of the past Country Strategy, where only 53% of the projects defined (18 of 34) in first 2 years ever
materialized, and a remarkable 15% of projects defined (4 of 26) ever materialized in the final 2 years. 8 In short, the
World Bank had seen lending drop to Brazil and the past business model would no longer work to restore the share
of multilateral credit the Bank once controlled.
In this context of a shifting balance of power between the Bank and Brazil, the World Bank stated that a four-year
plan made little sense. Instead the CPS would focus on defining new rules of engagement between the Bank and the
Government. The immediate emphasis would be on greater lending to State governments and sub national or
private sector actors. Of the $US 5 billion envelope of expected lending for 2008-2009, only 15% was scheduled to
go to the Federal government.
While few new Federal loans were planned before 2010, the financial crisis reversed these plans and the SEM DPL
emerged on a fast track. The SEM DPL series follows prior World Bank analytical and financial support for GoB
efforts to promote the sustainable management of Amazon agricultural lands, forests, and water resources; reduction
of deforestation in the Amazon; reduction of the environmental degradation of land, water, and other resources
which are key determinants of the well-being of the poor; and promotion of renewable energy. 9
Many of the conditions included in the SEM DPL were first included in an earlier DPL. The WB prepared and then
approved a first Environmental PRL DPL in 2004 for $500 million.10 That earlier loan was designed as a three
phase policy loan to be disbursed over 2 years and to be completed before Lula‟s first term ended. A related
Environmental Technical Assistance Loan (ENV TAL) was approved on Sep. 15, 2005.
The Brazilian Government decided to end all SAL (adjustment loans) in 2006 and redirected WB lending to the state
level. Various WB loans were placed in the freezer at this time, including the planned second two phases of the
PRL loan.
The current SEM DPL is officially new loan, not a continuation of the prior DPL despite the resemblance. The time
expired to complete the prior DPL and over 40% of the ENV SAL was cancelled also. In 2008, Brazil decided to
unfreeze the DPL, preserving many of the same objectives and triggers of the prior loan. No evaluation of the first
ENV PRL was conducted in time, so there is relative lack of clarity or accountability regarding the potential lessons
of that earlier DPL.
Civil society organizations in Brazil and elsewhere have questioned the lack of transparency in the preparation of the
SEM DPL to BNDES as well as many of the substantive goals of the loan in a context of hostility originating from
conventional “developmentalist” interests that predominate within the Lula administration toward advocates for
more stringent Amazon sustainability criteria.
The SEM DPL represents an important test case for the World Bank, not only for the effectiveness of this new breed
of DPOs that support environmental policy reforms, but also for the coherence of the Bank‟s development strategy
in general.
BNDES and the World Bank
8
World Bank (2008) Brazil Country Partnership Strategy (2008-2011), pg. I, pg.13. The CPS also noted the long average lag
between concept approval and loan signing of 30 months (Fig. 10, pg 22)., which resulted in delayed disbursements.
9
See National Environmental Project (NEP 1) 1991-1998; NEP II Phase I APL - $30 million; Pilot Program to Conserve the
Rainforest (PPG 7) 1994-present); Amazon Regional Protection Project (ARPA) $30 million in 2002; First Programatic
Reform Loan for Environmental Sustainability DPL (2004) - $600 mn; ENV TAL I (2005) - $8 mn; Pará Integrated Rural
Development Project (2006) - $60 mn; Amazon Region Cartography Project (2007) $5 mn; Alto Solimoes Basic Services and
Sustainability (2008) -$24 mn; Acre Sustainable Development Loan PROACRE (2009) - $US 120 mn; Land Administration
ESW (2007, 2009); NEP II Phase II;
10
World Bank, “First Programmatic Loan for Environmental Sustainability, approved Aug. 24, 2004.
BNDES has experienced phenomenal growth in overall disbursements over the past five years. Annual
disbursements have doubled since 2001 to over $US40 billion – over ten times the combined lending to Brazil by
the World Bank, IDB and CAF. BNDES finances one third of all infrastructure in Brazil, only 12% of which is
through public institutions. BNDES is the central financing mechanism for Brazil‟s ambitious $300 million
Accelerated Growth Program (PAC) that focuses primarily on infrastructure.
With that growth in public investment (in addition to increased foreign investment) Brazil has been able to reduce
borrowing from the IFIs. The growing profile of BNDES has also inspired the confidence of Northern donor
support for the Amazon Fund, a sovereign Brazilian trust fund managed by BNDES to support climate friendly
activities in the legal Amazon.
In the context of the current financial crisis that has cut foreign direct investment flows by half in 2009, Brazil is
depending heavily on increased lending for infrastructure and trade finance by BNDES to compensate for frozen
credit markets. Facing certain limitations in the allocation that BNDES receives from the Worker‟s Assistance Fund
(FAT), it will increasingly have to rely on international markets to sustain the annual increases in lending of the past
years.11 BNDES is also increasingly exposed to the same public attention regarding transparency, accountability
and participation that was often reserved for the IFIs.
The rapid growth of BNDES, which is a reflection of the strength of the Brazilian economy, could stimulate Brazil‟s
rapid recovery from the ill effects of the financial crisis. BNDES also allows Brazil to assert greater sovereignty in
the evolving debate over the reform of global finance. Over the past year, governance reforms at the IFIs have been
deeply influenced by the emerging leadership of BRIC countries for voice and representation reforms. Threats to
withhold demand for new lending and support for core initiatives, such as the World Bank‟s largest climate funds,
have been issued by BRIC countries to ensure commitments in the G-20 resolutions favoring reforms of the global
finance system.
The extent to which all of this indicates a break with past dependence on the IFIs for BNDES and Brazil remains an
open question. One emblematic example of this new autonomy is BNDES recent experience with support to the
cattle sector after reports linking the sector with illegal deforestation in the region. In an unusual step, the IFC broke
with its Brazilian client, Bertin, when it became clear that cattle processing operations supported by the loan were
clearly identified as a driver of Amazon deforestation. The worldwide negative attention that has led to demands of
certification by international buyers such as Nike and Wal-mart were initially ignored by BNDES – even though it is
the foremost financial supporter of the cattle industry in Brazil and owned equity in Bertin. 12
The shock came when BNDES was denied the terms of credit that it was seeking on the international market largely
due to concerns associated with the perceptions of its role in supporting the maladies of Amazon livestock. Taken
aback, BNDES has been forced to reconsider the implications of not upholding industry standards associated with a
financial institution of its stature, such as social and environmental safeguards (.e.g the Equator Principles, of which
BNDES is not a signatory). Over the past several years, particularly under the leadership of Luciano Coutinho,
BNDES has contemplated several profound institutional reforms. However, the increased pressure to expedite
funding for infrastructure and trade has neutralized these intentions by placing a higher premium on investment
timetables and volume over consensus and results.13
11
Fabio Giambiagi, Fernando Rieche, Manoel Amorim (Jun 2009) “As Financas do BNDES: Evolucao Recente e Tendencias,”
Revista do BNDES. 16:31, pg. 3-40. The FAT contribution to BNDES assets reached a maximum of 59.7% in 2006 and has
declined to 46.3% in 2008 as BNDES turns to other financing sources. Multilateral Bank share of BNDES assets has also
declined steadily from 18.4% in 2001 to only 7% in 2008.
12
See Greenpeace (June 2009) “Slaughtering the Amazon,” http://www.greenpeace.org/international/press/reports/slaughtering-theamazon; Amigos de Terra – Amazonia (Jan. 2008) “Time to Pay the Bill,”
http://www.amazonia.org.br/english/guia/detalhes.cfm?id=313449&tipo=6&cat_id=85&subcat_id=413 . See also, “IFC withdraws loan
from Brazilian cattle corporation, Bertin,” http://www.bicusa.org/EN/Article.11258.aspx
13
RHETT BUTLER (AUG. 10, 2009) “Controlling the Ranching Boom That Threatens the Amazon,” Yale Environment 360,
http://e360.yale.edu/content/feature.msp?id=2176
In recent months, BNDES has attempted to diffuse criticism of its perceived lack of rigorous sustainability criteria
by announcing support for climate friendly mitigation schemes that are clearly not available for near-term
implementation. At a climate and cattle conference, a BNDES representative touted a newly formulated cattle
certification scheme in order to buy time to think through the complexities of such a system. Earlier in June, the
Bank announced investment in a carbon capture sequestration system for the recently funded Pecem coal fired
energy plant, again promising to deliver a technology that is not close to commercial operation. 14
Perhaps in light of these types of public pressures, BNDES has apparently sought the eagerly peddled advice of the
World Bank to respond to calls to reform its lending practices by adopting social and environmental screening and
design criteria that are closer to development bank industry standards.15
DPL Analysis:
In this uncertain context, the World Bank and GoB have designed the SEM DPL to support nine ambitious policy
objectives (outlined in the Development Policy Matrix in annex 1). The proposed policy actions touch nearly every
aspect of the climate debate in Brazil and in the Amazon region specifically. Several of the proposed policy actions
include:
the formulation and approval of a new Environmental and Social Institutional Policy for BNDES that
incorporates the National Climate Change Action Plan, the Green Protocol, and application of this new
policy to BNDES full portfolio.16
the drafting of investment guidelines for BNDES to manage social and environmental risk for 60 sub-sectors
of the economy (including energy, agriculture and transport) 17
the filling of 600 vacancies at IBAMA, MMA and ICMBio, to support the Ecological Economic Zoning
plans outlined in the National Sustainable Amazon Program (PAS),
informing the regulatory design for the new Amazon Fund, and to implement the Water Resources National
Plan.
The outcomes for the SEM DPL include the following objectives:
Improving the environmental licensing process by decreasing the number of licenses challenged in the
courts by the Public Prosecutor‟s Office by 20% compared with 2002-2007 period average.
Increase planned green house gas emission reductions to 20 million tons of CO2 equivalent/year through the
CDM, BNDES and National Climate Action projects
To have 100% of projects submitted directly to BNDES screened, approved and monitored according to the
new Environmental and Social Policy
Increase the Sustainable Natural Forest Management of private and public areas from 27,000 km2 to 50,000
km2.
Reduction in average annual rate of deforestation in the Amazon for 2008-2010 to 20% below the annual
average rate for 2005-2007 (14,800 km2).
An area of 500,000 ha. Receiving Amazon Fund support for promoting sustainable land use activities.
14
See Alana Gandra (May 21, 2009) “IDB funded Brazilian Thermal-Electric Plant to use Carbon Capture Technology,” Brazzil
Forum. http://www.brazzilmag.com/content/view/10775/1/
15
As with many IFI policy based operations, it is not clear whether the World Bank, BNDES or other agencies of the Brazilian
government acted as the impetus for including BNDES reforms in the SEM DPL.
16
See Appendix for summary of key Brazil programs
17
SEM DPL PGH, p.14-15
Water quality monitoring results released to the public for 90,000 km of main rivers.
Reduction of 110,000 tons of pollution loans discharged into rivers due to approved BNDES sanitation
projects
The production of 60,000 tera joule per year of renewable energy or saved by energy efficiency projects
supported by BNDES.
As warranted as the WB SEM DPL and other DPLs may seem, the lack of transparency about how the loan was
prepared is directly related to more substantive underlying concerns associated with the policy preferences inherent
in these loans. Are the development policy triggers the most appropriate options? Are they ambitious enough?
Was there adequate public consultation in design of the loan, or in the validation of whether the prior conditions
were met? Was the loan amount justified in relation to the cost of carrying out the reforms? Does the loan contribute
at all to addressing chronic budgetary constraints of environmental agencies? Should the DPL trigger the World
Bank‟s social and environmental safeguard policies and formalize requirements for disclosure, public consultations
and grievance recourse mechanisms? Is the system for
M&E rigorous enough? These questions and others were
conveyed in two letters to the World Bank as well as a
follow up meeting with the DPL loan task managers on
Aug. 23, 2009 and have yet to receive adequate answers.
In a letter dated March 5th 2009, various civil society
organizations from Brazil, together with the Bank
Information Center, stated reasons for opposing immediate
approval of the Brazil SEM DPL by the World Bank
Executive Directors. The Bank‟s March 12th letter of
response, subsequent to Board approval of the loan,
essentially restated information from the program
document, failing to address key substantive and process
problems identified in the initial letter of civil society organizations. Such an evasive response, in and of itself,
raises concerns about the Bank‟s commitment to improving dialogue and transparency regarding its operations in
developing countries.
One of the primary civil society concerns is the lack of transparency and accountability regarding the performance
and shortcomings of past World Bank energy sector and environment loans in Brazil, within a context in which
loans were never subjected to public scrutiny or serious evaluation. The SEM DPL refers to the achievements and
learning of a past Pilot Program to Conserve the Rainforest (PPG7) Amazon grant program as a strategic input into
the SEM DPL design. However, the relative success of the PPG7 is contested by some and several components
were cancelled by the Government. The World Bank has not produced the project evaluations of the entire program
(beyond the Pilot program) to explain how the performance of the PPG7 loan would inform the design of the SEM
DPL. Nor has the Bank adequately addressed a recent IEG Evaluation of World Bank environmental programs that
suggested shortcomings in moving from projects to mainstreamed environmental incentives, weak M&E systems,
lack of coherence between IBRD and IFC operations, and most relevant to the SEM DPL – problems in
strengthening institutional capacity.18
The Bank conducted only a Simplified Implementation Completion Report for the First Environmental PRL in 2005
that provides only projected results for 2007.19 Given the significance of this loan as one of the first Environmental
DPLs in World Bank history and for Brazil, an analysis of the results is warranted. However the SEM DPL seems
to have been designed without full access to this evaluation.
Partly due to Government decisions to cancel or delay significant parts of prior World Bank loans or ignore
commitments established in these projects, sustainability planning for key sectors such as hydroelectricity have been
18
19
World Bank IEG (2008) Evaluation of WBG Support for the Environment.
World Bank (June 29, 2005) “ICR for First PRL for Environmental Sustainability,” Report No. 32299-BR.
weakened. For example, the impacts of a unilateral decision by the Ministry of Mining and Energy's (MME) to
abandon a cooperative effort with the Ministry of the Environment (MMA) in carrying out Strategic Environmental
Assessments (SEA) for hydro-projects at the river basin level, as called for in the policy matrix of the First
Programmatic Reform Loan for Environmental Sustainability (Loan No. 7256-BR) was never subjected to serious
analysis and public debate.20
Another fundamental problem concerns the generalized lack of prior, broad and informed consultation with
Brazilian society organizations during the preparatory process of the SEM DPL. The loan document refers to broad
consultation upon which the National Climate Change Action Plan (NCCAP) and the Sustainable Amazon Plan
(PAS) were based. However, there is no commitment to hold open public consultations on the proposed BNDES
Social and Environmental Policy, a loan that would have tremendous impact on the NCCAP implementation (see
annex 1 for more on NCCAP). For the development sub-sector investment guidelines, including the most dynamic
and challenging sectors for the Government‟s stated objective of reconciling development and conservation in the
Amazon, there is no public review scheduled.
The BNDES Social and Environmental Policy and related sub-sectoral guidelines are the centerpiece of the SEM
DPL. Numerous aspects of formulating such a policy are controversial and require open public debate, but are being
discussed selectively with consultants and hand-picked private sector experts. To avoid the perception of bias and to
field the best advice, the draft policy should have at least a 90 day public comment period and related public
hearings.
Another issue relates to the fact that BNDES provides 70% of its finance to private sector intermediaries, which
represents a challenge for enforcing policy commitments. Similar to other IFIs that lend to private sector clients,
20
See World Bank, Simplified ICR (June 29, 2005) First Programatic Reform Loan for Environmental Sustainability, Report
32299-BR.
such as the World Bank Group‟s International Finance Corporation, the preparation and monitoring and evaluation
phases of the project cycle are entirely non-transparent. How BNDES will hold financial intermediaries and other
private sector companies accountable through commonly available recourse mechanisms such as participatory
oversight councils, inspection panels, independent evaluations, all require greater transparency commitments.
Another issue is how the new BNDES Social and Environmental Policy will address the indirect and cumulative
impacts of proposed projects as part of its risk assessment process. Large infrastructure projects in the Amazon,
such as many of the 80 hydroelectric dams planned in Brazil under the Growth Acceleration Program (PAC),
typically require analysis of the cumulative impact of several dams and related transmission lines or river locks that
often follow.
The Brazilian National Electric Company,
Electrobras, is conducting Integrated Basin Assessments for the
10 largest river basins.
However, these integrated basin
assessment tools (IBATs) tend to serve as a prospective
inventory of hydroelectric potential rather than an assessment of
cumulative impacts. Seven dams are being planned on the
Tapajós River, totaling 14, 245 MW of total installed capacity
and the total area of rainforest flooded would be over 3,000 km2.
Nearly half of the flooded area is within federally protected
areas.21 The IBAT is designed to identify which of the seven
dams might be the most politically safe dam to begin
construction on. Electrobras and the National Electric Energy
Agency, ANEEL, have not explained how the IBAT analyzes the
cumulative impacts of the seven Tapajós River dams together or
the other indirect impacts that construction inevitably will have
on this part of Amazonas state. The highly flawed EIA for the
Madeira projects has also lowered confidence in the ongoing
IBATs. 22
The sub-sectoral investment guidelines are intended to help
BNDES and investors identify and assess social and
environmental risks. Of the 60 sub-sector guidelines underway,
the World Bank is providing technical advice on 8 (which Proposed Inambari 2,000 MW hydroelectric dam, Madre
includes hydroelectric energy). However, early drafts of these de Dios, Peru
guidelines also reportedly lack any guidance or trigger for
conducting strategic environmental assessment (SEAs). Rather, each project is viewed in isolation, which
undermines the effectiveness of the guideline (“checklist”) approach when assessing many multi-sectoral projects.
The World Bank has proposed that BNDES consider the IFC performance standards as a model for the new Bank
Social and Environmental Policy. The IFC Performance Standards are considered by some to be the most robust of
the IFI safeguards, and have led to the creation of the Equator Principles for private banks. However, even given the
short life of the IFC PS application (since 2006), specific concerns have emerged as to their effectiveness in
ensuring development impact and sustainability. Stated concerns with the IFC PS include no reporting on project
level development outcomes and weak disclosure rules in general, no free and prior informed consent (FPIC)
commitments for affected indigenous groups, inconsistent risk categorization, inadequate extractive industry
disclosure requirements, and no overarching focus on climate change.23 The recent disastrous experience with IFC‟s
support for the Bertin cattle processing project, despite widespread criticism by civil society organizations, signals
21
See Glenn Switkes, “Preliminary Report on the Tapajos Basin Hydroelectric Inventory” (June 5, 2009) International Rivers.
http://www.internationalrivers.org/en/latin-america/amazon-basin/preliminary-report-tapaj%C3%B3s-basin-hydroelectric-inventory
22
See IRN and FOE Amazonia (2007) “Studies that don‟t hold water,” a report that outlines 30 errors in the Madeira EIA
process. http://www.internationalrivers.org/en/latin-america/amazon-basin/madeira-river/studies-don%C2%B4t-hold-water; See also
BICECA Madeira project page, http://www.bicusa.org/es/Project.aspx?id=10138
23
For more on the IFC Performance Standards Review process, see Bank Information Center www.bicusa.org/ifcreview.
that the application of even the best standards may be inadequate in the context of Amazon development projects
and deserves careful public consideration.24
The World Bank and GoB have indicated that some type of public consultation is planned for the BNDES safeguard
policy in late 2009, but no details have been provided. On the SEM DPL contribution to the climate debate in Brazil,
the support for the NCCAP is clouded by the loan‟s inadequate attention to strengthening the coherence of the
government‟s Amazon strategy. The World Bank has advised the Brazilian Government to fix the environmental
licensing process, which suffers from jurisdictional confusion, poor EIA design, and in turn acts as a disincentive to
investors. 25 The Bank has identified several factors that lead, in their view, to the unnecessarily high frequency of
judicially challenged licenses. These factors include lack of capacity within IBAMA, the Federal agency charged
with licensing, to prepare quality EIAs; the confusion and duplication of roles among local, state and federal
licensing authorities, the lack of clear rules for licensing that lead to greater politicization and general lack of
transparency of the process. 26 The solution promoted by the SEM DPL is to add staff capacity to IBAMA, MMA
and ICMBIO and to draft a new law that clarifies decentralized licensing functions. What these measures fail to
acknowledge are the steamrolling of all environmental regulatory authority by prioritized PAC projects, regardless
of the social and environmental impacts. Would the decentralization of environmental licensing address the
problem of ambiguous criteria or prevent the politicization of controversial projects? Would more IBAMA staff and
clearer licensing guidelines have prevented the firing of the head of IBAMA‟s technical review team when they
rejected the Madeira EIA?
While the SEM DPL suggests support for the Sustainable Amazon Plan and advances the touted macro and micro –
scale zoning processes, it seems to ignore numerous examples of conflicting policies in the Brazilian Amazon are a
cogent illustration of the non-functioning of the PAS. The agency responsible for overall coordination of PAS, the
Secretariat for Strategic Affairs (SAE) has not assumed its role. Rather, it has limited itself to specific measures
which are often highly controversial, even within the federal government.
For example, the loan‟s risk analysis fails to adequately address the implications of a recent amendment to Brazil‟s
land law (MP 458, Lei 11.952), which is widely viewed as a giveaway to illegal land grabs. The new land law will
legalize hundreds of thousands of illegal Amazon farms that occupy more than a quarter million square miles of
protected forest, legitimating land speculators and grileiros, while intensifying social conflict and deforestation.
Changes to the legal reserves on private landholdings that weaken the 80% reserve requirement is another
concession related to the Brazilian Forestry Code and other legal attempts to change its contents. In practice, the
80% reserve requirement is poorly enforced. Still, the new law simply relaxes the requirement with little reciprocal
benefit except for political support in the coming Presidential election. The analysis in the Program Document offers
only blanket endorsement of the PAS, which many view as paralyzed by the land laws, cattle and soy expansion,
and unmitigated advance of the PAC. Lack of governance in large parts of the Amazon and contradictory legislative
initiatives both highlight the absence of a more detailed risk analysis of the factors that could impede the SEM DPL
outcomes.
The SEM DPL support for designing regulations for the newly formed Amazon Fund also deserves greater scrutiny
given the ongoing efforts by the World Bank to position itself as a broker in the global climate negotiations. 27 The
Strategic Framework on Climate Change and Development, which was launched in 2008, lays out a blueprint for a
massive accumulation of power and wealth in the form of an arsenal of international climate trust funds and
projections for energy and carbon finance expenditure that would launch the World Bank into a position of parallel
authority to the UNFCCC. Concerns raised by civil society organizations about the World Bank‟s climate strategy
argue that it will serve as a protection scheme for the largest polluting donor countries and a proponent of
questionable carbon finance solutions.
Brazil, China, Russia and other middle income countries have challenged the Bank‟s climate agenda just as they
have questioned any Bank efforts to weaken the autonomy of member countries in all aspects of World Bank
governance. Member support for any World Bank climate strategy, particularly by BRIC countries, has become a
24
See fn 8, Greenpeace and Amigos da Terra Amazonia reports.
World Bank (Mar. 28, 2008) Licenciamento Ambiental de Empreendimentos Hidrelétricos no Brasil: Uma Contribuição para
o Debate. Relatório Nº 40995-BR
26
SEM DPL PGD, pg 19.
27
See annex for description of the Amazon Fund
25
bargaining chip in the overall negotiations for governance reforms in voice and representation at the World Bank.
The creation of the Amazon Fund might be viewed as a measure to ensure Brazilian control over its own reduced
deforestation, emissions and climate adaptation strategy, but also as a bargaining chip with donor countries in
negotiating contexts such as the World Bank governance reforms arena. The World Bank‟s interest in clarifying the
guidelines for the Amazon Fund cannot be viewed only as a technical input, but as getting to know the competition
in the unfolding competition for loyalties over approaches to carbon finance.
As noted in another article in this bulletin, the World Bank study on Amazon die-back,28 which was only casually
referenced in the draft of the SEM DPL loan document, seems to have disappeared from the SEM DPL as a
technical input or a relevant feature of any outcome. The World Bank‟s climate team that prepared the Amazon dieback study over the past several years was reportedly not involved in the design of the SEM DPL. Given the
significance of the findings of this Bank study and the clear indications of incoherence between the PAC and
sustainability programs supported in the DPL, its absence is more than a casual oversight.
A serious lack of transparency and accountability regarding numerous components of the loan nullify any claim to
authentic consultation. The policy conditions in the SEM DPL results matrix include such controversial issues as a
lack of effective public consultation regarding the MME's Ten-Year National Energy Plan for 2008-201729, recent
attempts by the Executive and Legislative branches to dismantle environmental legislation in the name of
"simplifying" licensing procedures30, and a persistent lack of transparency within the National Bank for Economic
and Social Development (BNDES) regarding social and environmental criteria used to justify the approval of huge
and unprecedented loans for mega-hydroelectric projects (e.g. Rio Madeira) and beef-processing facilities in the
Amazon, in contrast to the mostly ineffective guidelines of the "Green Protocol" signed in August 2008 within the
context of the Bank's first environmental sector loan to Brazil ( Loan no. 7256-BR).31
With regard to the proposed outcomes of the DPL, the central issue here seems to be that of World Bank
additionality / relevance. Take for example the proposed outcome of increasing reductions of CO 2 by 20 million
tons per year. In what sectors will these reductions be achieved, and does this constitute a net reduction given
planning projections? Does it include reductions in deforestation? The 2008-2017 electrical energy plan is proposing
to build 82 new thermoelectric plants which implies that emissions from the sector will grow from 14.4 to 39
millions of tons (25 millions in 10 years). In 2030 the share of fossil fuels in the Brazilian electrical energy matrix
shall increase from 8% (2005) to 13%. The transportation sector is planning more railroads and waterways, but in
practical terms investments are massively going to roads. So, this reduction is solely based on deforestation
reduction targets assumed by the climate change plan (5,000 sq.km by 2017).
For the indicator of increasing private and public areas sustainably managed from 27,000 km2 – 50,000 km2, there
is a need for a more precise qualification. Will public areas include extractive reserves (RESEX) such as Chico
Mendes, which alone is 10,000 sq.km in size?. Concessions to private management are much more complicated in
terms of compliance with sustainable management criteria. One single indicator may be unsuitable for both types of
conservation goals. In addition there is no consensus on how to measure sustainable management, which goes far
beyond the counting of hectares of national parks created. Indicators of sustainable management involve financial
stability, security of land tenure, participatory land use planning, robust M&E processes, etc. Some clarification is
necessary to judge the ambition of this goal.
The DPL suggests a deforestation target for the Amazon of reducing the rate for 2008-2010 to 20% below the prior
period average of 14,800 km2. However, this target of 11,840 km2 is above what the climate change plan targets: in
28
See World Bank press release, “Climate Change: Latin America Is Part of the Solution,”
http://web.worldbank.org/WBSITE/EXTERNAL/COUNTRIES/LACEXT/0,,contentMDK:21928261~menuPK:2246555~pagePK:
2865106~piPK:2865128~theSitePK:258554,00.html
29
See recommendation of Federal Prosecutor's Office to MME, following a public hearing on the Ten Year Energy Plan (PDEE
2008-2017): Recomendação Conjunta no. 01/09, 4a e 6a CCR e PFDC/MPF, 09 March 2009.
30
See, for example, recent declarations by former Environment Minister and Senator Marina Silva in the Brazilian Senate (April
16th) and in an article published in the Folha de São Paulo, "Motoserra na Legislação" (April 20, 2009).
31
See May 13, 2009 Civil Society letter to the World Bank, which raises these issues.
2009 maximum of 9,200 sq.km, for 2010-2013 and 2014-2017 reduction of 30% for each period, in 2017 maximum
of 5,000 sq.km.
For energy outcomes, the DPL will contribute to 60,000 tera joules per year produced by RE or saved by EE
projects supported by BNDES. A rough conversion of this target would be 2,000 MW per year. 32 Consider that
for the wind power auction scheduled for November in Brazil, there may already be as much as 11,000 MW in
projects registered. There is also a high potential for exploiting carbon neutral energy from sugar cane bagasse,
estimated to total between 6,000 to 9,000 MW.33 So, even without the DPL, Brazil may be well above the DPL
target, raising the question of how SEM DPL will actually contribute to such an outcome, or how issues of causality
will be addressed (e.g. counterfactual) in the DPL evaluation.
Pecuária: alto custo em emissões
Missing from the list of proposed performance indicators was
certification for the cattle sector, which may be the most important
driver of Amazon deforestation. Brazil must reduce illegal ranching
activities/illegal slaughter (estimated 15%), which depends on
increasing "rastreabilidad," or traceability of beef sourcing. A major
obstacle is the lack of any complete or reliable registry of all
properties. Brazil exports beef to over 180 countries, complicating
further the goal of achieving an umbrella pact that prevents leakage.
One possible short-term indicator could be to simply increase the
number of cattle ranchers geo-referenced as proposed by the attorney
general of Pará and supported by the Ministry of Agriculture and
BNDES.
Within a context of deficient dialogue with CSOs and transparency in
the planning process, combined with loan disbursements that are
linked to prior actions that might have happened independent of the
DPL, plus vague triggers/indicators for further disbursements (that
Although the cattle industry represents just 2% of
GDP, it is responsible for 44% of emissions in Brazil.
don't include protection against severe budget cuts for environmental
agencies) it's unclear what the real benefits of DPLs are for the
environment and society in Brazil. This ambiguity extends to issues of clarity regarding the World Bank's role and
value-added to the status quo.
Final Thoughts
The effective implementation of the World Bank's disclosure policy, as well as Brazilian legislation regarding
transparency and accountability of public institutions 34, requires immediate public access to a series of documents
referenced in the Program Document (PGD). These include, inter alia, i) draft BNDES Environmental and
Institutional Policy, including operational guidelines for specific sectors (e.g. forest management, hydroelectric
energy); ii) evaluation report for Environmental Sustainability Agenda Technical Assistance Project (7331-BR ENV
TAL),35 iii) an Evaluation (ICR) for the 1 st ENV PRL; iv) Project Information Document (PID) for new
Environmental Sustainability Agenda Technical Assistance Project (ENV TAL) and v) the mid-term review of the
Country Partnership Strategy. Without public access to such documents, no World Bank claims to adequate public
consultation can be sustained. As such, these and other relevant documents should be released to the public prior to
any forthcoming Board decision on the second tranche disbursement for the SEM DPL I or a second scheduled SEM
DPL.
32
A tera joule is equal to the energy of one watt of power for a duration of one second. The rough equivalent of 60,000 TJ per
year would be close 2,000 MW.
33
V Forum Instituto Acende Brasil, Mudancas Climaticas e o Setor Electrico, 25 Aug. 2009. Brasilia.
http://www.acendebrasil.com.br/archives/20090825_VForum_Rev7.pdf
34
35
See, for example, the "Environmental Information Law" (Lei no. 10.659 de 16/04/2003)
In the WB June 15, 2009 response, it states that the ENV TAL evaluation will be completed in 2010.
A structural problem with DPLs/DPOs is the inability to track their entirely unearmarked funds to know what
relation, if any, the actual Bank finance has on the fulfillment of policy actions. While the IMF assessment of
Brazil‟s macroeconomy is generally positive, an accumulating internal public debt remains a concern for credit
rating stability. The SEM DPL points out that a key motivating factor behind the Government‟s request for the
SEM DPL was to ensure adequate credit resources to the financial system. The DPL would contribute to “dollar
liquidity.” 36 In a context in which BNDES has negotiated the two largest loans in the Brazilian Bank‟s history to
finance the San Antonio and Jirau hydroelectric dams, the liquidity challenges for BNDES are arguably associated
with such commitments. Civil society organizations have asserted that the SEM DPL provides indirect support to
BNDES to free funding for Amazon mega-projects like the Madeira hydroelectric Complex. While the World Bank
disputes any direct association between the DPL and Madeira, the inability to track the funds makes it impossible to
refute the claim.
The SEM DPL raises a series of questions in terms of process and substance for which adequate answers from the
Bank and Brazilian authorities are still lacking. Examples of such questions include the following:
1) What level of public participation will be ensured in the vetting/review of the new BNDES Environmental
and Institutional Policy (trigger for second tranche of DPL I) including sub-sectoral guidelines in such areas
as sustainable agriculture and renewable energy?
2) How will compliance with the first two DPL–II triggers related to BNDES social and environmental policy
be effectively measured, especially with regard to high risk projects already in the pipeline, such as the
Santo Antonio and Jirau hydroelectric dams?
3) How will the qualitative aspects of DPL triggers and outcome indicators be effectively evaluated, given the
vague wording throughout much of the Development Policy Matrix?
4) What criteria were used in defining the value of DPL I at US$ 1.3 billion, and DPL II at US$ 700 million?
If estimates of program cost, such as the recurrent expense of 600 new positions at IBAMA, ICMBio and
MME for 20 years, why weren‟t these estimates included in the loan appraisal or final document? How can
a sectoral loan for environmental management be justified in a context in which no additional funds will be
made available to MMA and other environmental agencies, while at the same time their operating budgets
are repeatedly slashed?37
5) What is the World Bank‟s understanding of how DPL SEM funds will actually be invested? How will such
investments be monitored to ensure compliance with World Bank standards and Brazilian legislation
regarding corruption?
6) Given the apparent lack of clarity regarding the use of finance resources from DPL SEM, how will the
World Bank ensure that the use of loan proceeds does not violate operational policies and directives (e.g.
Environmental Assessment/Disclosure, Involuntary Resettlement , Indigenous Peoples)?
Such unanswered questions and absent documentation underscore a serious lack of transparency and
accountability during the process of preparation and approval of the first tranche of SEM DPL I. It is the belief of
the ten organizations that signed the letter opposing the approval of the SEM DPL that until practices of
transparency and dialogue between the World Bank, the Brazilian government and civil society organizations are
truly
adopted,
the
laudable
goals
of
the
SEM
DPL
will
not
be
achieved. 38
36
SEM DPL PGD, pg. 9
For example, authorizations for expenditures by MMA have been reportedly slashed by the ministries of planning and
finance (MPOG, MF) to 43% of the 2009 budget approved by the Brazilian Congress.
38
The May 13 Letter to the World Bank was signed by Amigos da Terra Amazônia Brasileira , Associação de Mulheres da
Amazonas (AMA), Bank Information Center (BIC), Greenpeace Brasil, International Rivers, Instituto Brasileiro de Análises
Sociais e Econômicas (IBASE), Instituto de Estudos Sócioeconomicos (INESC), Instituto Políticas Alternativas para o Cone Sul
(PACS), Instituto Sócioambiental (ISA), S.O.S Mata Atlântica, Rede Brasil sobre Instituições Financeiras Multilaterais
37
Annex 1: Brazil Environmental and Development Programs (needs editing, taken from the SEM DPL
document)
The Green Protocol is a marked improvement over the 1995 version and strengthens the GOB‟S commitment to
support environmentally sustainable activities. The signatory banks have agreed to promote policies and procedures
aimed at financing development with environmental responsibility through lines of credits and programs that
enhance the quality of life o f the population, promote the sustainable use of natural resources and the environmental
protection. In addition, the current GP 2008 defines clear guidelines for each one of these principles. For example,
the harmonization principle calls for a common governance mechanism among the signatories to exchange
experiences and monitor the effective application o f the GP, the development of a standard approach to get socioenvironmental information from clients, and the continuous improvement of the GP through a biennial review o f
the principles and guidelines of the GP 2008.
NCCAP - the National Climate Change Action Plan is undergoing a public consultation
process to receive contributions for the final version to be approved by the GOB. The detailed actions of the Plan
might be modified as a result of the consultations but its general and specific objectives should not change much.
The NCCAP aims at the mitigation o f and adaptation to Climate Change, to be achieved by: (i) promoting an
increase o f efficiency of the productive sector to reduce the carbon content of the country‟s GDP, (ii)m aintaining
the relatively high contribution of renewable energy to generation of electricity, (iii)in creasing the contribution of
biofuels as a source o f energy for the transport sector (iv) seeking a sustained reduction of the deforestation rate, on
quadrennial basis, for all Brazilian biomes with a goal of zero illegal deforestation, (v) reaching zero net
deforestation (no decrease o f overall forest cover) by 2015, and (v) identifying impacts caused by Climate Change
and developing a strategy o minimize the social and economic adaptation costs for the country.
PAS - the Sustainable Amazon Plan, launched in May 2008 by the GOB and the state
governors o f the Amazon region aims at promoting the sustainable development of the region and improving the
quality of life of the population through the support of activities which generate jobs and income compatible with
the sustainable use o f natural resources and rainforest biome conservation. The specific objectives of the PAS are:
(i)t o promote territorial planning and environmental management, including zoning and land administration, (ii) to
support incentive programs for sustainable use of natural resources, including activities that add value locally, to
respect traditional knowledge and ensure food security, (iii)t o support the planning and implementation of
infrastructure for development (transportation, energy, communications and urban), and (iv) to strengthen social
inclusion and decrease social inequality by improving the access to education, health and social security services.
The PAS was designed by a committee comprised of 13 ministries and representatives of all Amazonian states. It
underwent an extensive public consultation process which included ten state and regional meetings with all sectors
and the resulting recommendations were integrated into the final document. The PAS includes and integrates in a
single framework all other regional or sub-regional programs such as the Sustainable Development Plan for the BR163 region and the PPCDAm, and i s coordinated by the Secretariat of Strategic Affairs under the President‟s Office.
PAC - the Program for Accelerated Growth plans for investments of R$ 646 billion ($323 bln), of which about
R$ 220 billion ($110 bln) is in sanitation and housing projects, that require partnerships with States and cities. Two
thirds of the investments will be used for infrastructure projects like energy, highways, railroads, ports and airports.
The government has reported that 77% of its nearly 2500 infrastructure projects are on schedule and 14% have been
concluded. According to official data, 7% of the projects require attention and 2% present problems. The report
indicated that through the end of April, 335 projects had been completed, representing investments of 62.9 billion
reals ($32 bln).
Amazon Fund
The GOB created the Amazon Fund as its alternative to receive compensation for reducing CO2 from deforestation
without having to rely on market-based mechanisms. The Amazon Fund, created by a Presidential decree, will
support the prevention, monitoring and combating of deforestation, and the promotion of conservation and
sustainable use of natural resources in the Amazon, fully in line with the Sustainable Amazon Plan (PAS) and the
Plan to Prevent and Combat Deforestation in the Amazon PPCDAM). The Fund will operate through grants
focusing on the following activities: (i) forest management in public lands; (ii) management of protected areas; (iii)
monitoring and enforcement on environmental laws; (iv) sustainable use of forest resources; (v) zoning and land
regularization; (vi) biodiversity conservation and sustainable use; and, (viii) rehabilitation of degraded areas.
The Fund, which is operating with a starting donation of $145 million from Norway but with projected donations of
$21 billion, is managed by BNDES and will be capitalized only through donations from bilateral and multilateral
agencies and the private sector. An expected steady flow of $1 billion per year and $500 million to $1.5 billion in
annual disbursements. Donations will always be conditioned to the decrease of the annual deforestation rate when
compared to the average annual rate of the past five years. Each donor will receive a non-tradable diploma stating
the amount of the donation and the amount of carbon “saved‟ as a result of reduced deforestation. This information
will be available to the public. A Technical Committee will be created to evaluate the methodologies to measure
deforestation and the amount of carbon “saved” per hectare.
The Amazon Fund has a Managing Committee comprised of 24 members (nine from the federal government, nine
from the Amazonian states, and six CSOs). Its first task is to define the Fund‟s bylaws and operational policies. The
Committee is also responsible for monitoring the portfolio to ensure that it is indeed supporting the PAS and
PPCDAM, and periodically review its adherence to the Fund‟s bylaws and operational policies.
Annex 2
Amazon Dieback
By Vincent McElhinny and Christian Velasquez-Donaldson
Latin America contributes 6 percent of global emissions from the energy sector and 12 percent of all global
emissions if we include deforestation and land use change. The share of the region in global emissions is very
modest, but the region is already facing profoundly negative impacts like the melting of its tropical glaciers in the
Andean region with heavy economic and the social consequences of water scarcity and hydropower availability
from which the Andean countries are highly dependent. In Ecuador, Peru and Bolivia, dependence on hydropower
energy coming from the Andes is 50, 68 and 70 percent respectively. In terms of water supply, more than 77 million
people are expected face water shortage by 2020.39
Among other impacts is the bleaching of coral reefs that threaten the ecosystem of the ocean in the Caribbean as
well as aquifer salinization and wetland loss in Mexico, hurricane intensification, etc. The list is long, but one of the
most devastating impacts not only for Latin America but worldwide, will be the risk of an Amazon dieback or
savannization of the large Amazon basin.
The Amazon represents one of three primary feedback loops that help regulate global climate stability through the
provision of crucial ecosystem services such as the recycling of rainfall and the capture of carbon. Reaching a
“tipping point” of irreversible damage to any of these three feedback loops is viewed by climate scientists as the
trigger for the most catastrophic scenarios. The collapse of the Amazon rainforest, as recent IPCC research has
explained, would unleash a chain of events that would result not only in disaster for the environment and economy
of South America, but contribute to the lethal accumulation of carbon in the atmosphere globally. 40 Of the 20 IPCC
general circulation models, the evidence suggests that regional temperature increases of 5 to 7 degrees Fahrenheit
would result in the beginning in 2050 of irreversible loss of as much as 85% of the Amazon forests by 2100. Still,
the prospect of Amazon die-back remains a somewhat misunderstood threat due to perceived uncertainty with the
climate models (vegetation, soil moisture,), but also due to the lack of visibility by development institutions.
In light of this potentially high risk of an Amazon dieback, the Latin America and Caribbean Environmentally
and Social Sustainable Development Department (LCSES) – “Climate Change Group” of the World Bank is
studying the possible implications of climate change on the integrity of the Amazon basin, focusing on tracing
factors for low soil moisture and negative feedback loops (rainfall, deforestation) and increased vulnerability to fire.
The results are being reviewed and will only be available later after a peer review is completed.
In November 2008, the Amazon die-back study was cited as a key input into the design and implementation of a
$1.3 billion environmental development policy loan by the World Bank to fund various actions by the Brazilian
Development Bank (BNDES). This SEM DPL has a significant climate orientation, which among other goals,
supports the implementation of the Brazilian climate action plan. However, in the final draft of the SEM DPL prior
to approval of the first tranche in March 2009, references to the Amazon die-back study were removed from the
loan, which raises several concerns regarding the Bank failing to incorporate pertinent research into the design of its
operations.
BNDES is the major financing institution for the Madeira Hydroelectric Complex, and the DPL includes among
other goals, support for BNDES to develop a social and environmental policy to better screen and analyze project
risk. The SEM DPL loan also supports the formulation of sub-sector investment guidelines for the energy sector,
including hydroelectric energy. The decision by the Bank to move forward quickly with the DPL (lacking full
transparency) without incorporating results from the Die-Back study seem to represent a lack of coherence regarding
overall strategy on climate.41
39
De la Torre, Augusto; Fajnzylber, Pablo & Nash, John (2009). Low Carbon, High Growth: Latin American Responses to
Climate Change. Overview. World Bank.
40
P.M. Cox, R.A. Betts, M. Collins, P.P.Harris, C. Huntingford, and C.D. Jones (2004) “Amazonian forest dieback under
climate-carbon cycle projections for the 21st century,” Theoretical Applied Climatology 78, 137-156; Yadvinder Malhi and
Oliver Phillips (2005) Tropical Forests and Global Atmospheric Change. Cambridge: Oxford University Press;
41
According to “Development and Climate Change: A Strategic Framework for the World Bank”, the Bank is planning to
expand its support for all sizes of hydropower projects from 40 to 50 percent in fiscal year 2011.
Global and Local
Amazon Dieback
Causes
of
The World Bank analysis of the
probability of Amazon dieback attempts
to integrate the various IPCC climate
models and reduce uncertainty regarding
the timing and cause. The risk analysis
of the Amazon Dieback relies on the
Earth Simulator data for end-of-century
climate in the basin, a probability density
function for rainfall in the Amazon basin,
carbon dioxide concentration and the
assessment of biomass response to these
changes through the application of the
LPJ model (carbon-water-vegetation-roll
dynamic
model).42
Preliminary
conclusions indicate that the Amazon
Dieback is mostly caused by global green house emissions (the world‟s two largest emitters include the United
States and China) as well and other developed countries; therefore, not related to Latin America‟s own GHG
emissions. Deforestation and land use trends also have the significant, although secondary potential to exacerbate
this mainly global climate change induced process.
The increasing temperatures and the disruption of the rainfall in the Amazon are damaging the basin capacity to
retain moisture, which in turn affects transpiration, changing rainfall patterns and making vegetation more
susceptible to forest fire. This situation reduces the capacity of the Amazon basis to retain carbon, which in turn
contributes to the problem of climate change by accelerating global warming and becoming an irreversible and
vicious feedback loop.
However, the environmental costs are not the only worry. As suggested above, there are as yet uncalculated social
and economic costs related to these findings. Human activities and environmental services that provide economic
means for the livelihoods of rural population and indigenous groups are at stake in this grim scenario. The poor and
most vulnerable are the ones that are the least responsible for causing the problem and the ones with least resources
to adapt.
Even though these preliminary conclusions to some extent are pointing to industrialized countries as the main cause
of the Amazon Dieback due to their proportion of global GHG emission, Latin America and especially Brazil‟s
participation is extremely important for the sustainability of the Amazon given the land-use changes and the rate of
deforestation in Brazil that makes it the world‟s fourth largest producer of GHG emissions.
The cattle sector in Brazil is the leading driver for deforestation in the Amazon responsible for about 80% of all
deforestation in Brazil. According to Greenpeace, the average deforestation rate from 1996-2005 accounted for the
loss of more than 19.5 million hectares with annual emission of 716Mt CO2, which is equal to the combined annual
emissions from coal consumption of Germany, the United Kingdom, Spain, Italy, France, The Netherlands and
Belgium. Moreover, according to a Greenpeace report, more than 70 million hectares, which represent almost 20
percent of the Brazilian Amazon, were already cleared by 2008.43
Land tenure laws in Brazil feed deforestation by allowing colonizers or land grabbers to gain titles by clearing forest
and place cattle on the land. According to Greenpeace, a set of laws passed by the Brazilian Congress this year
42
Vergara, Walter (2009). Climate Hotspots: Climate-Induce Ecosystem Damage in Latin America. In Walter Vergara (Eds.):
Assessing the Potential Consequences of Climate Destabilization in Latin America (pp. 5-17) LCR Sustainable Development
Working Paper No. 32. World Bank.
43
Greenpeace (2009). Slaughtering the Amazon.
legalizes property rights for illegally occupied land and in addition, doubles the percentage of forest that can be
cleared legally within a property. The new land regulations and the promotion of settlements in environmentally
fragile forest areas without economic viability undermine the recovery of degraded and deforested areas. 44
Road construction in the Amazon represents the entryway to previously inaccessible lands, not only physically but
also by reducing transport cost of merchandise, which represent a major constraint for the expansion of agroindustry and livestock.45 This is especially true when infrastructure development through initiatives like IIRSA or
the PAC lack coherent planning that adequately accounts for the social and environmental impacts that could
undermine sustainability. A recent cost-benefit analysis of the proposed BR-319 highway between Porto Velho and
Manaus calculates the full costs of deforestation and indicates that the social and environmental programs necessary
to ensure the sustainability of the highway would likely cost the same amount as the paving itself (about $430
million) – an added expense that Brazilian transport ministry has indicated it will not pay. 46
Hydroelectric dams, such as the Madeira Complex or Belo Monte appear to be politically motivated regardless of
any objective assessment of the sustainability of the Amazon. In contradiction to several studies raising important
concerns about the significant negative impacts of the Madeira Complex 47, at a recent public hearing at the U.S.
Chamber of Commerce in Washington D.C. the Brazilian Minister of Mines and Energy, Edison Lobao said that
“there are zero impacts” related to San Antonio and Jirau dams.
It is not a secret that in promoting cheap and clean energy, Brazil is pushing a ten year energy strategy that
prioritizes the construction of more than 80 dams in the Amazon to fulfill its growing demand for energy. Altino
Ventura Filho, the head of energy planning of the Ministry of Mines and Energy, recently stated, “Plans for Brazil’s
energy future are based on hydro-electricity from the Amazon. We are going to build all the dams we can, this given
the current legislation, and then we will revisit the other potential dam sites that would impact indigenous lands and
protected areas and see how we can exploit those as well.” These declarations raise major concerns given that most
Amazonian dams are considered the dirtiest in terms of emissions. There are estimations for Balbina, for instance,
concluding that this dam “emits ten times more GHG from rotting vegetation in its reservoir than a coal-fired plant
of the same capacity.”48 Together with the indirect impacts of uncontrolled migration, loss of riverine livelihoods
and exacerbated land use problems, all of these infrastructure mega-projects have the „real‟ potential to drastically
accelerate the Amazon Dieback process.
One of the major challenges not only for Brazil but the region is to identify and implement strategies to address the
major economic drivers for deforestation in the Amazon. Therefore, it is important to understand that a change in
behavior is needed even though it is a slow process. In this regard, a good starting point in the international arena
would be for the U.S. and China to commit to the Kyoto Protocol, which would be a victory in Copenhagen in
December 2009 that should initiate a major commitment for reduction of GHG emissions.
On the other hand, climate change is an immediate and serious problem that demands shared global action. For
Latin America, a redirection of its development policy that prioritizes sustainability over growth and promotes low
carbon strategies without undermining energy access for the poor and energy efficiency is of significant importance.
At the height of the Doha Round negotiations, the World Bank boldly pronounced its opposition to the persistence
of agricultural subsidies by the U.S. and European governments as an unjustifiable obstacle to free trade and the
successful conclusion to global trade agreement. In the debate on global climate strategy, similar leadership is
needed. This kind of leadership by the Bank should begin by providing access to relevant information like the
Amazon Dieback Report as an urgent priority in the run up to Copenhagen, not only for ensuring the quality of its
44
Amigos da Terra-Amazonia Brasileira (2009). “Time to pay the Bill: the current situation of cattle ranching in the Amazon”
Maria del Carmen Vera Diaz, Robert K. Kaufmann, and Daniel C. Nepstad (May 2009) The Environmental Impacts of
Soybean Expansion and Infrastructure Development in Brazil‟s Amazon Basin. Tufts University – Global Development and
Environment Institute. Working Paper No. 09-05.
46
Leonardo Fleck (Maio 2009) Eficiencia economica, riscos e custos ambientais da reconstrucao da rodovia BR 319.
Conservation Strategy Fund.
47
For more details on the concerns, news, and analysis of the Madeira Complex: http://www.bicusa.org/es/Project.10138.aspx
48
Switkes, Glenn (2009). Amazon Peril: Dams Threaten Rainforest Biodiversity. World Rivers Review.
Vol. 24/No.2. International Rivers.
45
own environmental operations (such as the DPL for BNDES) but also to inform the international debate about the
causes of global climate change and shared responsibilities in combating it.
Amazon in Peril: Dams Threaten
Rainforest Biodiversity
By Glenn Switkes
The Amazon Basin is well-known as a biological
wonder. Its impressive statistics attest to its global
importance: the river accounts for one-fifth of the
world's freshwater flow, and its vast floodplain includes
60% of the planet's remaining tropical rainforests. The
rich ecosystems support an equally diverse group of
indigenous peoples who rely on its waters for
sustenance and transport.
Ashaninka communities, led by Ruth Buendia, are fighting plans to
But to many in Brazil's energy sector, the mighty river
build dams in the Peruvian Amazon. Photo: Jonathan Mcleod
is primarily a tool for industrial and urban expansion.
With most of the country's future hydroelectric potential
in the Amazon, the government is pressing for scores of dams to be built over the next 20 years.
At a recent public hearing, the head of energy planning for Brazil's Mines and Energy Ministry, Altino Ventura
Filho, said, "Plans for Brazil's energy future are based on hydroelectricity from the Amazon - we're going to build all
the dams we can given the current legislation, and then we'll revisit the other potential dam sites that would impact
indigenous lands and protected areas and see how we can exploit those as well."
Under the guise of promoting "cheap, clean energy," Brazil's dam builders are planning more than 100 dams in the
Amazon, setting their sights on rivers with almost a mystical resonance to their indigenous names - the Araguaia,
Xingu and Tapajós. If unchecked, the country's projected growth in energy demand will have important implications
for the Amazonian rainforests of surrounding countries, including Peru and Bolivia, where dams are being planned
to export electricity to Brazil.
Along with global warming, the debate on the future of the Amazon is heating up. The rivers of Amazonia play a
vital role in keeping the rainforest alive. The scores of dams being planned could disturb the fragile water balance of
the Amazon, accelerating the drying of the forest. The projects would also expel more than 100,000 river-bank
dwellers from their lands and seriously degrade dozens of indigenous lands and protected areas.
Brazil's electricity-sector bureaucrats say these will be kinder, gentler dams, with smaller reservoirs, designed to
lessen social and environmental impacts. Even Brazil's Environment Minister, Carlos Minc, has become an ardent
promoter of dams in the Amazon. Legislation has been introduced that would fast-track the licensing of new dams in
Amazonia and allow projects to circumvent Brazil's tough environmental laws, under the pretext that they are of
"strategic importance" to Brazil's future.
But dam projects under construction, such as the Santo Antonio and Jirau dams on the Madeira, the Amazon's
principal tributary, have raised the possibility that individual dams could impact a huge area of the Amazon Basin.
Scientists have pointed out that several valuable migratory fish species could suffer near-extinction as a result of the
Madeira dams, affecting fisheries and fauna thousands of kilometers up and downstream. The fertility of the
Amazon floodplain, utilized by agriculturalists and an important site for fish reproduction, would also be negatively
affected.
Despite the weight of expert opinions critical of the projects and calls for additional studies, construction on the
Madeira dams is now underway amid a flurry of legal challenges.
World's third largest dam in the Amazon
Belo Monte on the Xingu River, with an installed
generating capacity of 11,300 MW, would be the
world's third largest hydroelectric project, and the
second largest in Brazil. Environmental studies have
been completed, and the government says it is
planning to offer the project to private investors by
October.
The Belo Monte Dam would dry out over 100 Km of the Xingu’s
famous “Big Bend”, leaving communities without
transportation or clean water supply. Photo: Monti Aguirre
fish,
Belo Monte would divert nearly the entire flow of
the Xingu River through two huge artificial canals
to the powerhouse, directly affecting an area of
1,552 square kilometers. A 130 km stretch of the
Xingu, including its famous "Big Bend," would dry
up. Independent studies question the economic
feasibility of the US$9 billion project, given that the
run-of-river dam would generate little or no
electricity during the four-month low-water season.
Impacts on indigenous peoples are likely to be a
crucial issue in determining whether or not Belo Monte will be built. Last May, 800 indigenous peoples from
throughout the Xingu Valley gathered in the city of Altamira to voice their opposition to the damming of the Xingu
River. They danced, chanted and warned that if the projects were not halted, there would be "World War Three in
the Amazon." For a warrior tribe, this was not a warning to be taken lightly.
Many of the other dams planned for the Amazon would also affect indigenous lands. Almost half of the planned
dams would also directly impact protected areas. Some, like the Marabá or Serra Quebrada dams on the Tocantins
River, would directly flood indigenous territories. Others would destroy fish stocks, which provide crucial
sustenance to indigenous peoples. Seven dams being planned for the Tapajós River would affect indigenous lands
and the Amazonia National Park, which has one of the world's greatest diversity of mammal species.
A changing climate
Amazonian dams are some of the dirtiest on the planet. Balbina – the worst Amazon Dam to date – emits ten times
more greenhouse gases from rotting vegetation in the reservoir than a coal-fired plant of the same capacity. Recent
revelations that Balbina's reservoir now covers 4,337 square kilometers, nearly twice its original size, mean these
emissions may be seriously underestimated.
In the long run, the effects of global climate change on the Amazon are uncertain. The Hadley Centre in the UK
predicts a greater probability of droughts, which could lead to a 13.4% decrease in the flow of the Amazon's rivers
by the end of the century, making Amazon dams less likely to fulfill their stated energy-generating potential. Other
studies show that the transformation of extensive areas of the Amazon into drier savannas would have effects in
distant parts of the continent, and potentially in North America and Europe as well, causing havoc with regional
climatic patterns.
Exporting disaster
With controversies raging over the damming of Amazonian rivers, Brazil is also looking to import electricity from
neighboring countries with weaker environmental and indigenous protection laws. The Peruvian government has
pushed through legislation opening indigenous lands to resource exploitation, provoking an uprising among
Amazonian natives. Brazilian state electric company Eletrobrás says it plans to build at least six of the eighteen large
dams currently being planned for the rivers of the Peruvian Amazon. The Ashaninka indigenous people of the Ene
valley have already initiated an international campaign against the Eletrobrás-supported Paquitzango Dam, which
would flood their ancestral lands.
Evo Morales' government, having protested the construction of dams on the Madeira River due to their probable
impacts on Bolivia, has now contracted a Canadian consulting firm to study the feasibility of Cachuela Esperanza
Dam on the Beni River. El Bala Dam has also recently resurfaced in discussions on Bolivia's future energy options,
including exporting electricity to Brazil.
Brazil is not the only country looking to get energy from its Amazonian neighbors. Colombia would likely be the
consumer of much of the electricity that would be generated by Ecuador's Coca Codo Sinclair project on the upper
Napo River. The dam would affect the Sumaco Biosphere Reserve and the majestic San Rafael Falls, as well as
ancestral lands of the Cofán indigenous people.
There is no doubt that meeting Brazil, and indeed Latin America's, future energy needs is of crucial importance.
However, studies have indicated that alternative options exist – a study by the conservation group WWF showed
that Brazil could meet a major part of its future energy needs at a lower social, environmental, and economic cost
from investments in energy efficiency and clean, renewable energy. Brazil's enormous wind-generating potential is
attracting investors and the country's potential for generating electricity from biomass, such as sugar cane bagasse,
rice husks, and sawmill scraps has been calculated to exceed the capacity of the massive Itaipu Dam.
Ultimately, the question facing Brazil, as with the rest of humanity, is whether our last precious ecosystems and
climate-sustaining rainforests are worth sacrificing for electricity. Surely the Amazon is too precious a place to
squander.
Eficiência Económica: Riscos e Custos Ambientais da Reconstrução da Rodovia
BR-319. Resumo Executivo49
Por Leonardo C. Fleck
Se por um lado a construção e a pavimentação de estradas na Amazônia geram benefícios na forma de redução de
custos de transportes, por outro lado impulsionam o desmatamento, os conflitos sociais e a ilegalidade. A eficiência
econômica e os efeitos diversos dos projetos precisam ser identificados e instrumentos que garantam uma
distribuição mais equânime de custos e benefícios entre os atores afetados precisam ser implantados.
Neste estudo, utilizamos a análise custo-benefício para avaliar a eficiência econômica do projeto de recuperação do
principal segmento da Rodovia BR-319, localizado entre os quilômetros 250,00 e 655,70, no Estado do Amazonas,
de forma a contribuir com a discussão dessas questões. Este trecho encontra-se fortemente deteriorado e
virtualmente intransitável desde 1986. Planeja-se sua recuperação dentro do Programa de Aceleração do
Crescimento (PAC) do Governo Federal, com início das obras em 2009 e término em 2011. As obras aqui
analisadas, com custo de implantação de cerca de R$557 milhões, incluem a recuperação e a pavimentação da
rodovia e a construção de quatro novas pontes entre Manaus e Porto Velho, o que viabilizará o tráfego continuado
entre Manaus e o resto do País.
49
Esta é uma publicação da Concervação Estratégica. O download deste documento pode ser feito na páagina do CSF:
http://conservation-strategy.org/en/reports/reports
Atualmente, não há estudo disponível que demonstre a eficiência do investimento e discussões aprofundadas sobre
as implicações sociais e ambientais de um projeto de tal magnitude. Para apoiar a discussão, construímos dois
cenários de análise, um convencional, que reflete a abordagem metodológica comumente empregada na avaliação de
projetos de infra-estrutura rodoviária no Brasil, e um cenário integrado, que visa incorporar custos ambientais
parciais no cenário anterior. Não consideramos custos sociais.
A análise do cenário convencional demonstra que o projeto é inviável economicamente, gerando prejuízos de cerca
de 316 milhões de reais, ou 33 centavos de benefícios para cada real de custos, em valores atuais. Isso significa que
para que o projeto alcance viabilidade econômica, os benefícios brutos estimados teriam de ser multiplicados por
três. A inviabilidade se mantém mesmo com a adoção de uma taxa de desconto tão baixa como 3%. Uma análise
mais abrangente, considerando incertezas na estimação de diversas variáveis de entrada, confirma a sua
inviabilidade, apresentando prejuízo médio de cerca de 311 milhões de reais e probabilidade zero de ser viável.
Modelagens recentes indicam que o projeto provocará forte desmatamento no Interflúvio Madeira-Purus, com a
perda de importantes recursos naturais ainda em excelente estado de conservação, caso políticas eficazes de
contenção do desmatamento não sejam implantadas. Estimamos que o custo econômico parcial do desmatamento,
modelado por Soares-Filho et al. (2006a)50, poderia alcançar aproximadamente 1,9 bilhões de reais, em valores
atuais. Destes, 1,4 bilhões corresponderiam ao efeito negativo do projeto sobre as mudanças climáticas globais,
valor muito superior aos benefícios brutos gerados pelo projeto, de 153 milhões de reais.
No cenário integrado, que inclui os custos ambientais estimados ao cenário convencional, os prejuízos do projeto
aumentariam significativamente e, nesse momento, somariam 2,2 bilhões de reais, ou somente 6,5 centavos de
benefícios para cada real de custos gerados, em valores atuais. Alternativamente, para cada real de benefícios brutos
gerados, seriam produzidos 12,3 reais de custos ambientais.
Essa análise, no entanto, não incorpora os custos e benefícios potenciais das recentes medidas de mitigação
propostas, relacionadas, principalmente, à criação e implantação de diversas Unidades de Conservação. Somente a
mitigação dos custos ambientais dentro dessas unidades, por meio de investimentos na sua implementação/proteção
básica, custaria cerca de R$469 milhões, em valores atuais. Isso significa que, para que seja economicamente
50
SOARES-FILHO, B. S. et al. (2006a). Modelling conservation in the Amazon Basin. Nature, 440: 520–523.
eficiente, o projeto de recuperação da rodovia teria de gerar pelo menos cerca de R$785 milhões de benefícios
adicionais, o que exigiria que os benefícios brutos estimados fossem multiplicados por pelo menos 5,12 vezes.
Esses resultados apresentam evidência de que a recuperação da BR-319, nesse momento, dificilmente representaria
um investimento eficiente dos recursos públicos brasileiros. Os recursos alocados nesse projeto seriam mais bem
utilizados em investimentos públicos alternativos que apresentem eficiência e equidade. Nesse contexto,
investimentos e incentivos aos modais de transporte atuais, nas hidrovias, rodovias, portos e aeroportos, poderão
tornar-se alternativas mais eficientes para a alocação de recursos públicos federais.
Implicações socioambientais
A BR-319 se localiza no Interflúvio dos Rios Madeira e Purus, uma região cuja biodiversidade é rica e pouco
conhecida, com grande potencial para novas descobertas.51 Além dessas características, ainda apresenta excelente
estado de conservação, principalmente pelo seu elevado grau de isolamento.52 No entanto, esse cenário é ameaçado
por diversos projetos de infra-estrutura planejados para os próximos anos, dentre eles o Gasoduto Urucu-Porto
Velho, as Hidrelétricas/Hidrovia do Madeira, a recuperação da BR-230 (Transamazônica) e da própria BR-319.
Além das pressões externas, as pressões internas são crescentes, principalmente na região sul do Estado do
Amazonas, onde se concentra a maior parte do desmatamento recente no estado. Já se observa a intense expansão de
estradas não-oficiais na região (SDS, 2005), efeito que deverá intensificar-se com a recuperação da BR-319 e a
possível construção de diversos ramais planejados após a sua conclusão. A reabertura do tráfego, ao longo da BR319, mudará drasticamente o cenário atual, tornando novamente acessíveis extensas áreas de terra para diversos
grupos de interesse, como sem-terras, agricultores, pecuaristas e madeireiros.
Pela fragilidade institucional da região, teme-se que se repita o processo predatório de ocupação de terras observado
historicamente em outras estradas da região Norte.53 Há indícios de que o simples anúncio de sua recuperação tenha
ocasionado aumento da grilagem e ocupação de terras54, tal qual ocorreu com a BR-16355. Além disso, é provável
que as melhorias nessa rodovia redirecionem as políticas de assentamento para a região, uma vez que muitos
assentamentos agrícolas estão sendo realizados na Região Norte, ainda que a maior parte das reivindicações seja
originada nas Regiões Sul e Sudeste56.
Modelagens recentes têm demonstrado o efeito potencial da recuperação da BR-319 sobre o aumento do
desmatamento da região e, conseqüentemente, a perda de serviços ambientais da floresta. Soares-Filho et al.
(2006a), em um estudo abrangendo a bacia Amazônica, projetaram desmatamento adicional induzido por esse
projeto de cerca de 9 milhões de hectares, em 2050. Segundo os mesmos autores, a recuperação da BR-319
provocaria maior desmatamento que os projetos das Rodovias BR-163 e Interoceânica, quando comparadas
separadamente.
Mais recentemente, Fearnside et al. (no prelo) realizaram outro estudo com uso de metodologia similar, mas
considerando os efeitos da reconstrução da rodovia em cenários com e sem a implantação de novas Unidades de
Conservação (UCs). Essa modelagem calcula desmatamento e emissões de gases de efeito estufa (GEEs) evitados
pela criação de UCs de 1,6 milhões de hectares e 310 milhões de toneladas de dioxide de carbono equivalente
(CO2eq), respectivamente, até 2050.
51
COHN-HAFT, M. (2008). Biodiversidade do Interflúvio Madeira-Purus. Apresentação do Projeto GEOMA. Disponível em:
[http://www.geoma.lncc.br/evento/ppt/Biodiversidade/Biodiversidade_4.pdf].
52
ÁRBOCZ, G., NALIATO, V. & W. REINECKE (2005). Relatório de vistoria técnica. Empreendimento: rodovia BR-319,
entre as cidades de Porto Velho, no Estado de Rondônia, e Manaus, no Estado do Amazonas, sob responsabilidade do DNIT
Departamento Nacional de Infra-estrutura de Transportes. COAIR/CGLIC/DILIQ/IBAMA, Brasília, DF. 80 p.
53
FEARNSIDE, P. (2005). Deforestation in Brazilian Amazonia: History, Rates and Consequences. Conservation Biology
19(3): 680-688. & REID, J. & W. SOUSA JÚNIOR (2005) Infrastructure and conservation policy in Brazil. Conservation
Biology, v.19, n. 3, pp. 740-746.
54
LBA INFORMA (22/11/2005). Anúncio da revitalização da BR-319 estimulou a ocupação de terras no Amazonas, informa
Incra. Disponível em: [http://lba.cptec.inpe.br/lba/site/?p=noticia&t=0&op=359].
55
ALENCAR, A. et al. (2005). A pavimentação da BR-163 e os desafios à sustentabilidade: uma análise ecônomica, social e
ambiental. Conservation Strategy Fund, Belo Horizonte, Brasil, 29 p..
56
AMAZONIA.ORG (07/07/08). Cerca de 40% dos assentamentos foram realizados na região Norte. Disponível em:
[http://www.amazonia.org.br/noticias/noticia.cfm?id=276513].
Além da perda de serviços ambientais, a implementação da BR-319 também ameaçará a sobrevivência de diversas
espécies de aves57, mamíferos58 e outros táxons, tanto pelo desmatamento como pela degradação florestal.
Argumenta-se, também, que o projeto ocasionará diversos problemas sociais, tanto ao longo da rodovia como na
cidade de Manaus. Ao longo da rodovia, espera-se aumento dos conflitos por terra e recursos naturais dentro e fora
de áreas formalmente protegidas, com a expansão da concentração de terras e invasões. Em Manaus, é provável que
haja aumento das taxas de imigração, dados os excelentes indicadores sociais da cidade em comparação com os
estados da Região Norte que serão conectados pela rodovia, como Rondônia e Acre, com diversas conseqüências
negativas para a cidade59.
Estado atual e projetado
A BR-319 possui 885,4 km de extensão5, sendo 859,60 km no Estado do Amazonas, onde atravessa os municípios
de Canutama, Humaitá, Tapauá, Manicoré, Beruri, Borba, Manaquiri, Careiro, Careiro da Várzea e Manaus. As
condições atuais de superfície e trafegabilidade são variáveis. Os 165 km entre Careiro da Várzea (na margem
direita do Rio Amazonas) e Careiro (na margem do Rio Tupãna) possuem asfalto em condições razoáveis de
trafegabilidade. No entanto, os 500 km seguintes – até o entroncamento com a Rodovia Transamazônica (BR-230) –
encontram-se virtualmente intransitáveis, sem asfalto e com problemas em suas pontes e bueiros. A única
manutenção vem sendo executada pela Embratel, restringindose à manutenção de pontes. A maior parte desse trecho
também se encontra desabitada. O trecho final de 180 km, entre Humaitá e Porto Velho, está pavimentado e em
estado regular, mas com muitos buracos e com pontes de somente uma faixa, permitindo condições razoáveis de
trafegabilidade61. As travessias dos rios Castanho, Tupãna, Igarapé-açu, Madeira (em Porto Velho) e Amazonas
(entre Manaus e Careiro da Várzea) são feitas, atualmente, por meio de balsas.
Para garantir a trafegabilidade futura da rodovia, planeja-se a recuperação completa do pavimento e a substituição de
todas as pontes de madeira por bueiros de cimento. Além disso, prevê-se a construção de quatro pontes sobre os rios
Castanho, Tupãna, Igarapé-açu e Madeira. Esta última, com cerca de 987 metros de extensão, encontra-se em
processo de licitação62. Para que a ligação terrestre entre Manaus e o resto do país esteja completa, só faltaria a
construção de uma quinta ponte entre Careiro da Várzea e a margem esquerda do Rio Amazonas, próximo a
Manaus. Esse é o projeto mais ambicioso, mas ainda não há previsão de implementação.
As obras da BR-319 foram iniciadas em 2005, sendo logo interrompidas pela falta de Estudo de Impacto
Ambiental/Relatório de Impacto Ambiental (EIA-RIMA). Tal fato ocorreu por ter sido considerado que, dadas as
condições precárias da rodovia, esta obra deveria ser considerada como um novo projeto e não a simples
recuperação de uma rodovia existente. A exigência de EIA-RIMA fundamentava-se nas perspectivas de danos
ambientais significativos gerados pelo projeto, o que resultou em acordo para que o trecho intermediário, entre os
57
VALE, M. et al. (2008). Effects of future infrastructure development on threat status and occurrence of Amazonian birds.
Conservation Biology, 22(4):1006-1015.
58
SOARES-FILHO, B.S. et al. (2006a). Modelling conservation in the Amazon Basin. Nature, 440:520-523.
59
IDESAM (2008). Ferrovia vs. BR-319: um debate sócio-ambiental urgente. Documento preliminary. Versão 2.8. 11p;
FEARNSIDE, P & P. GRAÇA (2006). BR-319: Brazil‟s Manaus-Porto Velho Highway and the Potential Impact of Linking the
Arc of Deforestation to Central Amazônia. Environmental Management, 38:705-716; FEARNSIDE, P. (2008). Impacto do
desmatamento amazônico sobre o ambiente urbano de Manaus. In: Santos, A. & Nowaza, S. Impactos urbanos sobre la
biologia do ambiente amazônico: interações entre moléculas, organismos e ambientes. Centro Universitário Nilton Lins,
Manaus.
60
Fonte: Ministério dos Transportes. Internet: [http://www.transportes.gov.br/bit/trodo/br-319/gbr-319.htm].
61
ÁRBOCZ, G., NALIATO, V. & W. REINECKE (2005). Relatório de vistoria técnica. Empreendimento: rodovia BR-319,
entre as cidades de Porto Velho, no Estado de Rondônia, e Manaus, no Estado do Amazonas, sob responsabilidade do DNIT
Departamento Nacional de Infra-estrutura de Transportes. COAIR/CGLIC/DILIQ/IBAMA, Brasília, DF. 80 p.; DNIT
(30/10/08). Condições das rodovias. Estado: Amazonas/BR-319. Disponível
em:[http://www1.dnit.gov.br/rodovias/condicoes/condicoesdrf.asp?BR=319&Estado=Amazonas&drf=1].
62
DNIT (01/09/08). Licitação para ponte sobre o Rio Madeira sera aberta no próximo mês. Disponível em:
[http://www.dnit.gov.br/noticias/mad].
quilômetros 250 e 655,7, fosse submetido ao EIA/RIMA. O estudo ficou sob responsabilidade da Universidade
Federal do Amazonas, sendo entregue no início de 200963.
Apesar da necessidade de consideração a impactos ambientais indiretos em um EIA, os estudos aprovados no Brasil
incorporam, quando muito, somente uma descrição qualitativa e suas medidas mitigatórias, que são, muitas vezes,
insuficientes para a contenção dos diversos danos ambientais gerados por projetos desse porte 64. Antevendo esses
impactos, em 2006 os governos federal e estadual decidiram estabelecer novas UCs no entorno da rodovia como
forma de restringir o avanço de desmatamento. Nesse contexto, iniciou-se um processo de consultas públicas sobre
as propostas de criação e ampliação de diversas UCs na região de influência da rodovia, entre estaduais e federais,
sendo que diversas foram criadas/expandidas recentemente ou se encontram em processo de criação/expansão 65.
O projeto da rodovia foi, no entanto, novamente paralisado em 2007, desta vez devido a denúncias de corrupção
envolvendo a construtora vencedora da licitação para as obras dos trechos autorizados66. Conseqüentemente, no final
de agosto do mesmo ano a maior parte das obras foi assumida pelo Exército através de seus Batalhões de Engenharia
e Construção (BEC), em convênio com o Departamento Nacional de Infra-Estrutura de Transportes (DNIT). Essa
estratégia foi adotada, possivelmente, para evitar maiores atrasos na execução do projeto.
63
UFAM & DNIT (2009). Estudo de Impacto Ambiental da Recontrução da Rodovia BR-319.
Devido aos diversos projetos de infra-estrutura planejados para a região, seria também recomendável o uso de um instrumento
adicional de política ambiental, a Avaliação Ambiental Estratégica (Therivel 1992), devido aos impactos estruturais na
economia, sociedade e meio ambiente proporcionados por esses investimentos.
65
ICMBio, SDS/AM, SEDAM/RO & CSF (2008). Grupo de Trabalho BR-319 (Portaria N. 295 MMA, de 22.09.2008).
Subgrupo: Proteção e Implementação das Unidades de Conservação da BR-319. Resumo Executivo. Manaus-Porto Velho. 27
p..
66
GAZETA MERCANTIL (20/09/2007). TCU constata irregularidades em 29 obras. Disponível em:
[http://indexet.gazetamercantil.com.br/arquivo/2007/09/20/20/TCU-constata-irregularidades-em29-obras.html].
64
BOLETIN
MENSUAL
No. 11: Julio, 2009
Acerca del Boletín Mensual BICECA
Construyendo Conciencia Cívica Informada para la Incidencia y la Conservación en la Amazonía-Andina
Un proyecto del Centro de Información Bancaria.
Por medio de este boletín, el proyecto BICECA del Centro de Información sobre la Banca Multilateral, busca traer noticias
e información relevante y de último momento acerca de aspectos particulares de proyectos y políticas relacionadas con la
iniciativa para la Integración de Infraestructura Regional Sudamericana (IIRSA). Esta publicación está dirigida a un público
diverso de Organizaciones de Sociedad Civil, grupos indígenas, estudiantes, académicos y otras personas o entidades que
siguen las políticas y proyectos de las instituciones financieras internacionales en relación al proyecto IIRSA.
Este boletín es una publicación de Bank Information Center (BIC) y sus contribuidores son de diversas fuentes y naciones.
Este boletín es editado por Vince McElhinny y Christian Velásquez-Donaldson, del proyecto BICECA en colaboración con
otros investigadores que estudian y trabajan en cuestiones de la Iniciativa de Integración IIRSA. Se reconoce los aportes
individuales de los diferentes participantes cuyo trabajo analítico esta citado en este boletín: Glenn Switkes de Ríos
Internacionales, Leonard C. Fleck de Conservación Estratégica. Si tiene usted algún comentario, pregunta o desea usted
contribuir a esta publicación puede comunicarse con el Gerente de Latino América, Vince McElhinny en
[email protected]
Centro de Información Bancaria (BIC)
El Centro de Información Bancaria es una organización independiente, no gubernamental y sin fines de lucro que busca
amplificar las voces de los ciudadanos de países en transición para influir en las actividades del Banco Mundial y otros
Bancos Multilaterales de Desarrollo de manera que promueva la justicia social y sustentabilidad del medio ambiente. BIC
aboga por lograr una mayor participación ciudadana, transparencia y rendición de cuentas públicas.