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.