🇧🇷Brazil

Custos Excedentes de Estudos Ambientais e Análise Técnica Repetitiva

Updated: Feb 20262 verified sources

Definition

IBAMA and state environmental agencies issue a Term of Reference (TR) that guides EIA/RIMA scope. The regulation allows agencies to request 'clarifications and complementation' at steps 4, 6, 7 in the formal licensing procedure. Manual coordination across federal, state, and municipal agencies + multiple public hearing rounds = cumulative delays and scope expansion. Projects with high pollution potential or in sensitive areas (Amazon, Atlantic Forest, Indigenous lands) face extended expert review and re-submissions.

Key Findings

Financial Impact: LOGIC estimate: EIA/RIMA study cost R$ 50,000–500,000 (engineering + environmental consultants). Average re-submission cycle (3–5 iterations) = additional R$ 15,000–50,000 per iteration. Delay cost: 6–18 additional months × R$ 5,000–10,000/month team cost = R$ 30,000–180,000. Total project cost overrun: 10–20% typical for mid-sized development.
Frequency: Per-project cost: 60–70% of projects experience 1–2 re-submission cycles; 20–30% experience 3+ iterations.
Root Cause: Outdated CONAMA Resolution 009/1987 (EIA/RIMA regulation not updated since 2019); inconsistent TR standards across states; lack of pre-application consultation; public hearing delays; unclear acceptability criteria for EIA technical opinions.

Why This Matters

The Pitch: Urban Planning and Community Development projects in Brasil waste R$ 100,000–300,000+ per project on redundant EIA re-work due to inter-agency clarification requests (RFI/RFC delays). Automated TR template standardization and consolidated inter-agency feedback loops reduce rework cycles from 3–5 iterations to 1–2.

Affected Stakeholders

Environmental Consultant/Engineer, Project Manager, Procurement/Budget Controller, Public Affairs Manager (public hearing coordination)

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Financial Impact

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Methodology & Sources

Data collected via OSINT from regulatory filings, industry audits, and verified case studies.

Evidence Sources:

Related Business Risks

Concentração de Receitas de CEPAC e Risco de Inadimplência Pública

Unquantified in sources, but structural: entire municipal PPP payment obligations transferred from private fund (FGTS) to public budget post-2015. Estimated impact: multi-million R$ annual obligation assumption by Rio municipality for duration of PPP contract.

Auditoria de Conformidade de Arrecadação de Outorga Onerosa e Falta de Transparência em Cálculo de Potencial Construtivo

Estimated 15–30 hours/month per municipality on fee disputes, rework, and court briefings (no exact data in sources). Accounts Receivable aging likely 60–120 days for contested fee amounts. Estimated annual delay cost: R$ 200–500K per major UO (opportunity cost of delayed cash collection at 5–8% municipal borrowing rates).

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