ENVIRONMENTAL BRIEF October 10, 1996 (Revised November 20, 1996) PROJECT NAME: Sustainable Development of the Pantanal PROJECT NUMBER: BR-0249 BORROWER: States of Mato Grosso and Mato Grosso do Sul EXECUTING AGENCY: Secretaria Obras Publicas, State of Mato Grosso do Sul Secretaria Planejamento, State of Mato Grosso FINANCING PLAN: Borrowers: US$100 million IDB: US$200 million OECF: US$100 million Total: US$400 million I. BACKGROUND 1.1 Near the geographic center of South America lies the largest complex of wetlands in the world. Known as the Pantanal, the area's 200,000 square kilometers are located principally in Brazil's states of Mato Grosso and Mato Grosso do Sul. The region has been called a "natural switchboard" between the continent's two great river basins, the Amazon and the La Plata. The Pantanal, which is made up of ten large rivers and their deltas and thousands of lakes and salt pans, has been characterized as an "endorheic system" or "enormous settling pond." 1.2 The Pantanal has an extraordinary diversity and abundance of both vegetation and wildlife of Amazon, Chaco and Cerrado origins. Scientific journals report from 657 to 700 species of birds and over 405 species of fish on record. The area is the refuge for many of Brazil's threatened species. The Pantanal also supports an important tourism activity, fishery industry, and many large "fazendas" which graze up to 8 million head of cattle. 1.3 Nearly 1.4 million people live within the Pantanal's hydrological basin (l.0 million in Mato Grosso (MT) and 400,000 in Mato Grosso do Sul). Most of the population is concentrated in urban areas, with eight cities accounting for more than 74% of the urban population. Some 31,000 indigenous people live in the region, mostly in MS. They belong to 7 indian nations, the Terena being the largest group. 1.4 The impact of human activity on the Pantanalßs water courses 1. Current concerns 1.5 Although scientific data are scarce, human activity appears to be having a negative impact on the Pantanal ecosystem. Principal areas of concern are: 1.6 Soil erosion in the upper watershed and sedimentation of the Pantanalßs watercourses: Intensive deforestation and farming of the Pantanal's upper plateau over the past 30 years has created a problem with large loads of sediment entering the region's major watercourses. Around 73% of the soils of the watershed are highly to moderately susceptible to erosion. The expansion of the planting of soja, corn, rice and pasture is producing heavy erosion (from 600 to 900 MT/Ha/year in large portions of the area) and intense siltation in several rivers (e.g. the Taquari river carries around 11 million MT/year). The build-up of these loads has rendered important rivers unnavigable and has subjected large areas to increasingly severe flooding. 1.7 Soil and water pollution by farming, alcohol production, and mining: Changing of agriculture practices in the uplands has meant a significant increase in the use of agrochemicals, especially pesticides, including agent white and agent orange and insecticides including organophosphates, monocrotophos and methyl parathion. Sugar cane mills are also located on the Planalto adjacent to the Pantanal. While most of these industries apply contamination control measures some still evacuate effluents that can lower pH and increase eutrophication of the rivers carrying the effluents. Mercury used to amalgamate gold found in the riverbeds of the Pocone, Cuiaba and Bento Gomes rivers is also contaminating the ecosystem. Traces of mercury have been found in samples throughout the Pantanal. Because the Pantanal is an almost endorheic system, a buildup of noxious substances can be expected to increase exponentially. 1.8 Untreated domestic sewage: Urban centers bordering the Pantanal have grown significantly over the past two decades. However, urban services, including sewer collection and treatment, have not kept pace with urban growth. Currently, less than 3% of the domestic and industrial wastewater generated in these urban centers is properly treated before discharged into the Pantanalßs rivers. Despite a dearth of quantitative data, it is evident that some of the receiving rivers and streams are showing increasing signs of strain from high pollutant concentrations. 1.9 Construction of roads, dikes and dams in the Pantanal: Since 1970, nearly one thousand kilometers of rural roads and hundreds of kilometers of dikes and dams have been built to facilitate access to farms, to protect pasture land from flooding, and to develop agriculture. The result is that migratory routes of high value fish have been blocked and resulting anoxic conditions of the water are causing high rates of fish mortality. This infrastructure also greatly reduces the scenic value of the Pantanal for tourism. 1.9 Low profitability of traditional cattle ranching in the Pantanal: Competition with intensive cattle ranching in higher portions of the watershed, deplorable conditions of the roads within the Pantanal, increasing yearly flooding and, the partition of large ßfazendasß, are reducing the profit of traditional ranchers. In response to these conditions, farmers are changing agricultural practices by planting pastures, building dikes and dams and, even, considering moving to intensive agriculture. 1.10 Excessive fishing and poaching: Specific studies are showing a dramatic decrease in catch (and size) of the better known species. The ßpintadoß catch in MS was 730 MT in 1985 and only 144 MT in 1991. In the period 1994/95 there were around 7,500 professional fishermen in the Pantanal. Of these 3,742 were registered in MS. Simultaneously some 46,000 sport fisherman visited MS. The figures for MT are not known but while professional fisheries may be less important, sport fisheries is at least equivalent. Statistics on extraction are not available. 2. Future actions 1.11 Future actions proposed for the area for the next decade may significantly increase the region's level of economic activity by lowering energy and transport costs, will likely have an even greater impact than the activities described above. These actions include: (i) privatization and modernization of the rail line Corumba-Campo Grande across the Pantanal; (ii) construction of a railway connection linking the northern watershed with the central railway system; (iii) repaving of the trunk road (BR- 0364) from Mato Grosso to Acre, Rondonia and its connection in Porto Velho with the Madeira and Amazon Rivers; (iv) construction of the waterway Parana-Paraguay; (v) construction of a gas pipeline to connect the Urucu gas reserves in Bolivia to Mato Grosso do Sul; and (vi) construction of the road linking Arica-La Paz and Cuiaba. 3. Planning for preservation 1.12 Efforts to closely monitor effects of human activity, plan development in the area, and take actions to preserve the ecosystem have taken place only recently and have met with mixed success. In l988, the Pantanal was declared a national heritage area under the Brazilian Constitution. In l989 research activity in the region intensified and studies for an IBRD financed Alto Paraguay River Conservation Plan (PCBAP), that is part of the National Environmental Program loan, was initiated. Problems identified and priority activities developed under this program generally parallel the conclusions of this plan. B. The strategy of Brazil regarding the Pantanal 1.13 Both states and the Federal Government intend, through the Project, to significantly reduce the causes of environmental degradation of the Pantanal in order to preserve its potential for sustainable economic development. In the Paraguay basin, the States intend to reduce significantly soil erosion that causes siltation and, urban, agricultural and mining originated pollution. Within the Pantanal, the States intend to restore profitability of traditional cattle ranching and promote new promising sustainable economic activities such as ecotourism and managed fisheries. C. The strategy of the Bank 1.14 The project fits within the priorities of the Eighth General Capital Increase regarding to environment and poverty alleviation. It is fully consistent with the Bank's country paper for Brazil (October 1995), regarding actions targeting rural and urban poverty alleviation and environment, especially regarding state institutions strengthening for better monitoring and law enforcement capability. II. OBJECTIVES 2.1 The project would balance the regionßs social and economic growth with conservation of the Pantanalßs natural resources so that sustainable development can be achieved. III. PROJECT DESCRIPTION A. Borrowers 3.1 The states of MT and MS, under separate contracts, will be the borrowers and will be responsible for servicing the debt. State water companies will repay the loan to their states for the water supply and sanitation works to be funded by the project under similar loan terms. Japan's Overseas Economic Cooperation Fund (OECF) will provide most of the counterpart funds with both state financing the remaining counterpart. B. Execution 3.2 The Project will be supervised through a Coordination Committee, composed of high level officers of MT and MS and, probably, by the Ministry of Environment, Hidrological Resources and Legal Amazon . A Consultative Group, with participation of the public and scientists, will advise this Committee. At the State level, the coordinating agencies will be the Secretariat of Planning (MT) and the Secretariat of Public Infrastructure (MS). Each agency will establish a unit specifically in charge of the project and will be responsible for the operation with regard to the states and the Bank. The coordinating agencies will establish appropriate arrangements with executing agencies and the municipal authorities. C. Components 3.3 The proposed project has the following five interrelated components: (i) watershed management; (ii) urban environment; (iii) roads and parkways ; (iv) promotion of sustainable economic activities; and (v) institutional strengthening. D. Description of components 1. Watershed management (US$60,400,000) 3.4 This component is a program of watershed management of the Alto Paraguay River basin. It includes: (i) the preparation of a management plan, based on the results of the previously mentioned PCBAP; (ii) the establishment of a watershed authority; (iii) creation of flood early warning system; and (iv) development of a series of management actions in critical sub- watersheds such as soil conservation practices, promotion of direct planting, rationalization of use of agro-chemicals, restoration of riparian vegetation, demonstrative restoration of a mining site and, diffusion of lesser damaging mining techniques. Monitoring activities for management feedback will be considered. Additionally, environmental and natural resources education and training will be provided. Strong involvement of organized farmers, local communities and municipal authorities is planned. 3.5 In MT, the Project will benefit from the experience of the PRODEAGRO (Northwest Regional Development Program), a technically successful IBRD program of watershed management and soil conservation developed in the vicinity of the Pantanal basin. In MS, a new IBRD program of Management and Conservation of Natural Resources, soon to be initiated in the upper portion of the Pantanal basin, will cover most requirements for critical watershed management in the Pantanal basin, complementing the Project. The basic information for the project development is being provided by the above mentioned PCBAP, an IBRD founded project included in the National Environmental Program under execution. Close coordination with the IBRD projects and with other smaller international and national activities in the Pantanal (e.g. The Nature Conservancy project in Acurizal) is being developed. 2. Urban environment (US$158,000,000) 3.6 Water supply and sewerage services are provided by the state public utilities: Empresa de Saneamento de Mato Grosso (SANEMAT) and Empresa de Saneamento de Mato Grosso do Sul (SANESUL). These institutions administer most of the states' municipal systems through their respective regional and local offices. An overview of the sewerage and wastewater treatment services in both states suggests the need for urgent rehabilitation, physical expansion and institutional improvements. With large segments of the population still unserved by the water distribution systems (20% in MT and 8% in MS) and unacceptably high volumes of unaccounted water (greater than 50% in MT and approximately 45% in MS), the need for programs designed to upgrade existing systems and reduce physical and commercial water losses is significant. However, greater efforts will be required in the expansion of the sanitary sewerage systems of both states, since nearly 90% of the urban population is currently unserved. An equally pressing situation occurs with solid waste collection and disposal, which is a service that, in most cases, is deficiently run by municipal governments. 3.7 This component will include the expansion and improvements to the water supply and sewerage systems of those cities considered most critical from the point of view of public health, community well being and environmental protection. Based on these criteria SANEMAT has preliminarily selected 5 cities where both their water distribution systems and their sewerage networks need rehabilitation and expansion, and 2 more where actions will be directed primarily to expanding wastewater collection and treatment. SANESUL has initially identified 22 municipalities for water supply works and 10 for sanitary sewerage system improvements. It is expected that approximately 700,000 people will directly or indirectly benefit from the proposed works. 3.8 Solid waste collection/disposal and storm water drainage will also be included within the urban environment component. Preliminarily, 4 municipalities in MT and 7 in MS have been identified for actions related to the improvement of their refuse collection and disposal service. Similarly, 10 drainage projects, 9 of which are in MS, have been identified in cities where storm sewers and the proper channelization of urban streams is needed to avoid flooding and reduce erosion. 3. Roads and parkways (US$95,000,000) 3.9 The most pressing need for the development of economic activities that are sustainable in the Pantanal (cattle ranching, ecotourism) is the restoration of the existing road system within the Pantanal. The Project contemplates the rehabilitation of 5 existing roads in MT and 2 in MS, totaling 412 km. and, transforming probably 5 of these roads into parkways. Some of these roads are already classified as parkways, but have not developed as such. The proposal is to establish a special protection status along roads that will prevent developments that are not compatible with the wetland ecosystem and will promote ecotourism. 4. Promotion of sustainable economic activities 3.10 This component will include technical assistance to farmers to make their activity more profitable, planning and support to the ecotourism, management of fisheries and promotion of aquaculture, establishment and of new protected areas and preparation of existing areas to allow visitors and, investment for conservation of sites of tourism interest. 5. Institutional strengthening ($20,000,000) 3.11 This component will ensure an efficient enforcement of environment and natural resources legislation by strengthening the key environmental agencies in both states (Secretariat of Environment (SEMA) and the Environmental Foundation (FEMA) in MT, and the Secretariat of Environmental and Sustainable Development of MS (SEMED). Emphasis will be placed on the economic sustainability of these institutions through better collection of fees rights of use and fines. The Bank's support will provide training and equipment. 3.12 Strengthening of the institutions responsible for public utilities is particularly required in the case of SANEMAT. Efforts will be primarily directed to developing an aggressive program to reduce physical and commercial water losses which, as mentioned before, are unacceptably high. Additional emphasis will be placed on promoting the decentralization of the agency, streamlining its administrative functions and on identifying areas where greater participation of the private sector is deemed appropriate. SANESUL is currently involved in a major restructuring of its administrative functions under a program partially financed by the BNDS and the World Bank. Strengthening activities will therefore become complementary to those already in progress. E. Beneficiaries 3.13 Preliminary estimates indicate that the project may directly benefit around 20,000 inhabitants with water connections and 207,000 with sewage in MS and 90,000 inhabitants with water and 250,000 with sewage in MT. Approximately 100,000 people, mostly rural inhabitants, will benefit from the watershed management and promotion of eco-compatible economic activities components in MT and some 40,000 would be benefitted in MS. The number of people benefiting from other activities such as solid waste management, control of river erosion, urban drainage, etc. have yet to be determined. 3.14 Most population to benefit are urban or rural poor and indigenous people amid these last group in MS. As usual, lack of water and sewerage services impact on the marginal areas of the cities where the project will be executed. River banks and other areas of intervention of the rural components are also frequently occupied by minifundia. F. Project costs 3.15 The total cost of the project is estimated at US$400 millions, corresponding grossly US$200 million for each state. IV. SPECIFIC ASPECTS AND RISKS A. Financial capacity of the states 4.1 In 1995, debt service represented 17% of current revenues in MT and 21% in MS. For this year, this percentage is expected do drop to 15% in MT (due to increase in current revenues) and increase to 23% in MS. The lack of capability of both states to generate a surplus in their current accounts reveals the difficulties that they are presently facing. Under these circumstances, it will prove impossible to set aside funds to finance a new project. To a large extent, increase in revenues will depend on the evolution of the Brazilian economy and the results of government efforts in tax administration and expenditure control. The decrease in current expenditures will depend largely on the State Government efforts to curb salary costs. The satisfactory rescheduling of payments of short term liabilities and part of the long term debts not yet negotiated will play an important role in alleviating the pressures on the State Treasury. Financial resources coming from the privatization of state owned public utilities companies could provide some relief, but will not once and for all solve the problems now faced by the states' administrations. 4.2 The proposed financial strengthening program for the states in Brazil (Programa Nacional de Assistencia Tecnica em Administra½ßo Fiscal para os Estados Brasileiros - BR-0171) will play a crucial role in establishing the viability of the "financial engineering" envisaged for this Program. B. Financial situation of SANEMAT and SANESUL 4.3 In both states, the present financial situation of the water and sewerage companies is less than satisfactory. Performance improvements are to be conducted in areas like control of unaccounted for water, O&M and administrative cost, reestablishing their capacity to invest in new works necessary to increase service coverage and quality. Both companies are executing institutional and financial strengthening programs, but these have not shown real positive results as of yet. However, in both cases there are possibilities of significant improvement before analysis mission. Some municipalities of MS may, in the future, award water and sewerage service concessions to private enterprises or new municipal companies. This issue shall be taken into account in project preparation. C. Economic analysis 4.4 The economic analysis, considering the nature of the Project, will be difficult. It will focus on four aspects. First, the analysis will identify the human problem that is being addressed. Second, the analysis will look at alternative solutions to the problem and examine the cost effectiveness of the solutions preferring the most cost effective ones. Third, for projects that are of the same type, the analysis will try to rank projects in different locations by cost effectiveness in order to maximize the impact of the limited budget available for the program. Fourth, where practical, the analysis will determine the net present value and internal rate of return of the project. 4.5 Committees should understand from the outset that the analysis required to estimate some environmental benefits (such as the willingness to pay of a community for cleaner rivers or to enjoy seeing migratory foul that may disappear if the project is not carried out) is extremely expensive and may not be very precise. In cases where the cost of the analysis is large relative to the cost of the project, no sophisticated analysis benefit estimate analysis will be attempted. V. PREPARATION STATUS 5.1 The water supply, sewerage and drainage projects for the cities initially identified are in a relatively advanced state of preparation, having some of them already developed their respective final designs. Some of the studies, however, will have to be reviewed to take into account technical recommendations made by the Bank. The solid waste studies will be prepared once the final selection of priority projects is concluded. The parkway establishment and rehabilitation projects are also in an advanced stage of development. However, there is little development of the studies for watershed management and institution building as well as for the promotion of sustainable economic activities. Low income group studies are also required. VI. ACTION PLAN 6.1 The analysis mission is programmed for april 1997 and Project discussion in the Committee of the Whole in June 1997. The Project Team in full will conduct one orientation mission and the analysis mission. Some members of the team may be required to do an additional orientation mission. The Team Leader, based in Brasilia, would undertake two to three additional visits during the preparation period. Some consultants will be required (parkways, hydrology, indigenous people, fisheries and ecotourism). It is estimated that 122 staff and consultant weeks will be required until approval and 60 additional weeks will be required during project execution. VII. ENVIRONMENTAL IMPACTS 7.1 The project is conceived to solve current and potential environmental problems in the Pantanal. It is essentially an "environmental" project. However, several negative impacts may be expected if every component (and action within components) is not carefully analyzed on its own merit as well as part of the entire project. A. Description of expected positive environmental impacts 7.2 The expected positive environmental impacts were already discussed in several previous paragraph. An effort to summarize them is made here: 1. Expected positive environmental impacts in the mid and upper watershed a. reduction of soil losses due to erosion by agriculture a cattle ranching; b. reduction of soil losses due to river bank erosion caused by destruction of riparian vegetation; c. reduction of sediment transportation in water due to agriculture and mining; d. rationalization of agrochemicals utilization and reduction of water and soil pollution due to agrotoxics; e. reduction of water pollution (mercury and other chemicals) due to mining; f. reduction of the rate of deforestation and rehabilitation or plantation of already deforested or denuded areas; g. reduction of water and soil pollution of urban origin; h. better conditions for biodiversity survival in addition to the establishment and/or management of protected areas; i. larger and better sources of food and nesting sites for fishas well as facilitation of reproductive migratory patterns; and j. improvement and conservation of natural scenery. 2. Expected positive environmental impacts in the Pantanal a. reduction of rivers and lakes siltation and reduction of the incidence of extraordinary floods; b. reduction of pollution levels of all origins (agriculture, mining, urban); c. improvement of the conservation of the Pantanal ecosystem, reducing deforestation of river banks and "sierras" and reducing the need to establish agriculture or cultivated grasses, build polders, river defenses and barrages or the need to drag the rivers; d. improvement of wildlife habitat by avoiding ecosystem disturbance and reducing pollution and siltation and better offer of food and nesting sites for birds, including migratory species; e. improvement of fisheries stocks, by facilitating fish annual migration, preserving nesting sites, more food, controlling predatory fisheries and reducing pollution levels; f. improvement of biodiversity conservation in general and specifically in better managed or newly established protected areas; and g. improvement of water circulation by improvement of existing roads. B. Expected socio-environmental benefits 7.3 The positive impacts expected are: a. improvement of the quality of life of urban population of lower incomes through provision of basic services (water, sewage, drainage, solid residues management); b. improvement of the quality of life of rural population, including indigenous people, through assistance in sanitation, flood alert system, protection against riparian erosion, reduction of water and soil pollution levels; c. reduction in the level of incidence of human environment-related diseases; d. improvement of agricultural production and productivity through soil conservation, rationalization of agrochemicals utilization, agroforestry practices, afforestation assisting traditional cattle ranching in the Pantanal; e. creation of new work opportunities in cities, towns and rural areas through ecotourism, pisciculture, fisheries management, protected areas management, improved mining practices, etc.; f. reduction of waste in commercial and sport fisheries; and g. prevention and/or solution of water use and related conflicts (or a fora for its solution) through the establishment of a watershed management authority. C. Description of risks or possible negative environmental impacts 7.4 All risks, except one, and potential negative environmental direct or indirect impacts, are originated in specific actions considered in the components and not from the overall project concept. These potentially risky actions are reviewed one by one in the following paragraphs. 7.5 Urban environmental works. Water, sewage, treatment plants, urban drainage, solid waste management, all have several direct and indirect environmental impacts that will require environmental impact assessments for each work. A special problem in the area is that the water table is very superficial. On the other hand, a few minor resettlement may be needed. Resettlement plans will be required in such cases. 7.6 Rehabilitation of roads and their transformation into parkways. All roads in the project are roads already in use for decades. The project is not considering the paving of the roads, but it will improve road surfaces and replace the wood bridges with concrete bridges. The wood bridges have a short duration and the replacement cost is high and difficult, as well as environmentally risky considering hardwood scarcity in the region. The opportunity will be taken to improve natural drainage conditions along the roads, i.e. making longer bridges. Some roads will be transformed into parkways, with inclusion of pertinent modifications. The establishment of the parkways will require specific studies and technical specification for each road. Therefore, a parkway establishment study and an environmental impact assessment for each one will be required. 7.7 Ecotourism promotion. Ecotourism is a double edge action in environmental and social terms. If very well planned, is essentially benign, both in direct and indirect impacts. However, if nature conservancy is not the driving force of regulation of this economic activity it may well result in serious direct and indirect impacts. Matters such as ecosystem and habitat carrying capacity for visitors, direct impact of infrastructure and equipment, social impact and redistribution of gains amid local people, environmental trade-offs, local cultural impact, land use implications, etc. are very important. In the Pantanal the fishing sport is already much more relevant in terms of annual catch than commercial fisheries. Uncontrolled and unsupervised fishing and hunting can cause ecological damage. Therefore, ecotourism will be subject to a development plan which will help to guide an appropriate ecotourism in the region. 7.8 New protected areas. Here the risk is only social, if some of the proposed areas (not yet defined) create a conflict with traditional or local populations or if resettlement is needed. Every proposed new protected area will be required to have a detailed assessment of these issues in the establishment study. 7.9 Pisciculture promotion. The goal of the project is to promote pisciculture of native species. However, there are already several introduced species in the Pantanal and the component will have to discourage it. On the other hand, pisciculture may accrue the risk of fish diseases and parasites. Studies on these risks will be required. 7.10 Rehabilitation of mining sites. The main environmental risk of abandoned mining sites rehabilitation is decurrent from residues removal and disposal, during work. It may release more sediments and, especially, pollutants (mercury) in the rivers and, on the other hand, the risk of work accidents is also important. An environmental impact assessment will be required. However, it shall be noted that probably only one mining site will be rehabilitated with the project, as a pilot experience. 7.11 General social and environmental risks. The main general risk of this operation is related to the failure of the project or the failure of a component or actions. However, in such event the situation would not be worst than today, without project, excepting as a consequence of an unchecked ecotourism promotion. 7.12 Public perception risks. The risk that the entire project be miss- interpreted by the public opinion and by the NGO movement in MT and MS, in Brazil and especially abroad is important. It may be easily associated to the HIDROVIA project, already under public scrutiny. The borrower, the executing agencies and the Bank shall fully apply and even exceed their policies, legislation and rules of openness, transparency and public participation. This is clearly a project which is social and environmentally sound and, especially, necessary to avoid the progressive destruction of the Pantanal and its people. There is nothing in it that cannot be public. VIII PREPARATION STATUS OF ENVIRONMENTAL STUDIES 8.1 Environmental considerations were, to some extent, included in the existing studies of investments in each component. However, these studies are at different stages of preparation and several are yet to be undertaken, especially in the watershed management component. In general terms it can be said that all environmental impact assessments and environmental studies or analysis, as well as resettlement plans, have to be done. IX. ENVIRONMENTAL CLASSIFICATION 9.1 It is recommend this project receive the Environmental Category III. X. RECOMMENDATIONS TO THE PROJECT TEAM 10.1 The Project Team must ensure the following actions and get the following products, during project preparation: a. each investment in urban environment (water, sewage, treatment plants, urban drainage and solid waste management), road improvement and mining sites rehabilitation will have to be based on an environmental impact assessment and its "Relatorio de Impacto Ambiental" (RIMA) and on the respective "Licencia Ambiental Previa" and "Licencia Ambiental de Instala½ßo", following strictly Brazilian and each State legislation and procedures. Exception for very small investments in urban environment can be accepted in application of the Brazilian and each State legislation but shall be carefully reviewed by the Project Team; b. when Resettlement Plans are required, these should be reviewed by the Project Team; c. protected areas to be established, including parkways, must be ecologically and socially analyzed through comprehensive establishment studies; d. other components, especially watershed management and institutional strengthening, as well as ecotourism and fisheries promotion, that cannot be subject to an environmental impact assessment must be environmentally analyzed within the studies that justify them or through special environmental analysis, if required (e.g. pisciculture); e. public participation in project conception and in each environmental study and resettlement plan must be encouraged and facilitated by the States and by the Project Team, according to Brazilian legislation and Bank policies and procedures. Special meetings of the Project Team with interested parties must be held, in close coordination with the States; f. an ongoing mechanism for social participation, such as a consultative group, that might continue to work during project implementation should be established; g. The terms of reference for the preparatory studies must give full consideration to the impacts of the program on indigenous population in the area and to alternatives for these groups to participate in, contribute to, and benefit from the program; and f. the Project Team, with the above indicated information, must prepare a general Environmental Analysis of the project and submit it to the CMA in the format of an Environmental Summary. This document must contain: (i) a description of the monitoring system for progress of the program and for its impact on the area, including a clear baseline, goals and benchmarks, a dynamic process of data collection, evaluation and feedback, and mechanisms to implement any needed adjustments (ii) an explanation of how the consultation mechanism was organized during preparation and how it will work during execution, and (iii)all appropriate annexes including maps and illustrations.