Environmental Licensing

Environmental licensing and recurring obligations handled with technical depth and management control.

The environmental front is rarely resolved with a single license. Compliance depends on continuity across license conditions, reports, waste, water, emissions and parallel obligations that must stay technically aligned with the main process.

CETESBState / Municipal SecretariatsIBAMASP Águas (formerly DAEE) / MMALP / LI / LO / LORRAPPINRSIWATER PERMITWATER MONITORINGEFFLUENTSHAZARDOUS PRODUCTSTREES

Environmental licensing tied to the activity

LP / LI / LO / LOR

The core of the operation is tied to licensing with the regulator, and it is the starting point for license conditions and environmental management.

Waste, effluents, wells, license conditions and trees

Parallel

Parallel activities often go unnoticed, yet they are as essential and as subject to licensing as the main activity.

Continuous environmental management

Continuous

Periodic reports and filings sustain compliance between renewals and prevent the risk of environmental sanctions.

Environmental work is not limited to the main license.

The value of this page is in showing the several layers of routine that must be controlled at the same time.

Layer 1

CETESB

The environmental agency of the state of São Paulo. Responsible for licensing activities with regional impact and for overseeing emissions, effluents and waste.

Layer 2

State / Municipal Secretariats

Environmental secretariats at state and municipal level. Each state and municipality may have authority to license activities with local impact under LC 140/2011.

Layer 3

IBAMA

A federal agency under the Ministry of the Environment. It licenses activities with national impact or affecting more than one state, wildlife and vegetation, and environmental monitoring nationwide.

Layer 4

SP Águas (formerly DAEE) / MMA

DAEE: water use permits in São Paulo. SP Águas: water management in the state and permits for intervention in water resources (formerly DAEE). MMA: the Ministry of the Environment, responsible for federal environmental policy.

Layer 5

LP / LI / LO / LOR

Preliminary License, Installation License, Operating License and Operating License – Renewal. The stages of environmental licensing under CONAMA Resolution 237/97.

Layer 6

RAPP

Annual Report of Potentially Polluting Activities. An annual filing with IBAMA by companies registered with the CTF.

Layer 7

INRSI

National Inventory of Industrial Solid Waste. A mandatory declaration for generators of industrial waste.

Layer 8

WATER PERMIT

Government authorization to use water resources (abstraction, effluent discharge). Issued by the State Water Resources Secretariat or by ANA at federal level.

Layer 9

WATER MONITORING

Periodic monitoring of groundwater and surface water quality, as set out in the license conditions and the environmental agency's rules.

Layer 10

EFFLUENTS

Control of liquid effluent discharge under CONAMA 430/2011 standards and state regulations.

Layer 11

HAZARDOUS PRODUCTS

Reporting on hazardous cargo flows to COMDEC (city of São Paulo) and DNIT (the National Department of Transport Infrastructure).

Layer 12

TREES

Vegetation removal, pruning and tree felling. Requires authorization from the competent environmental agency. Includes environmental offsetting where applicable.

Where the license stops being an event and becomes a routine.

Environmental execution for licensing, license conditions and recurring obligations, with technical depth and continuous control of the regulatory routine.

Step 1

After the license is issued

The company obtains the main license but loses sight of the license conditions and the periodic filings attached to it.

Step 2

In waste management and support operations

The operation creates parallel routines that never feed back into the central regulatory process and turn into liabilities.

Step 3

At renewal

Without a consolidated technical record, renewal becomes a rebuild of the process instead of controlled continuity.

Pruning, felling and removal of trees

Removing or intervening in native vegetation requires prior authorization from the competent environmental agency. Removal without authorization is an environmental offense, with penalties including fines, suspension of the activity and criminal liability. Unity advises on when to request authorization, which agency to approach and how to handle environmental offsetting where applicable.

Requests for pruning or removal (where permitted) require prior authorization
Authority: Environmental Secretariats — municipal or state level
Removal without authorization brings fines and can lead to criminal liability
Environmental offsetting is mandatory in many removal cases

The pieces that keep the environmental front standing.

Licenses, license conditions, water permits, periodic reports and ancillary obligations require integrated document management. Unity organizes these pieces into a control flow that prevents failures, missed deadlines and non-compliance.

Environmental licenses and waivers
Management of license conditions
Periodic reports
CADRI

Risks that spread when the routine becomes fragmented.

In environmental matters, the risk does not sit only with the main license. It also builds up in license conditions, periodic reports, waste, water, hazardous products and supplementary requirements. Non-compliance can lead to severe fines, criminal liability for the company's legal representative and even shutdown of the operation by the environmental agency.

License conditions with no clear owner
Waste and effluents handled outside regulatory governance
Periodic filings with no technical calendar
Excessive focus on the main license, ignoring the ancillary routine

Environmental penalties for failing to comply with the law

Failing to comply with environmental law can result in:

Fines

Amounts that can reach BRL 50 million under Decreto 6.514/2008.

Criminal liability

The company's legal representative may face criminal charges (Lei 9.605/98 — the Environmental Crimes Act).

Shutdown of the operation

Suspension or closure of the activity by the competent environmental agency.

Loss of licenses

Cancellation or non-renewal of current licenses.

Why this front requires continuous analysis.

Regulatory environment, documents and technical recurrence must move together to avoid liabilities spread across the operation.

Sustains licensing beyond the main license
Reduces exposure to liabilities from missed deadlines or ancillary obligations
Integrates documentation, technical routine and filings with the agency
Increases visibility over environmental matters spread across departments

How does the Environmental Licensing service work?

Each step is carried out with technical and documentary rigor to ensure compliance and predictability.

01

Environmental assessment of the operation

Mapping of activities, facilities, waste, effluents and current environmental obligations to identify the licensing stage, outstanding license conditions and the fronts carrying the greatest regulatory risk.

02

Defining the licensing strategy

Assessment of the applicable license type (LP, LI, LO or LOR), the competent agencies (CETESB, IBAMA, DAEE) and the license conditions to be met, in order to define the most suitable regulatory path for the case.

03

Documentary and technical preparation

Organization of studies, reports, waste management plans, effluent and air emission reports, and other technical documents required for filing with the competent environmental agency.

04

Filing and dialogue with the agencies

Formal submission of documents to the competent environmental agency, with technical follow-up of the review, responses to questions raised during the process and direct dialogue with the officer handling the licensing.

05

Managing license conditions and recurring obligations

Continuous monitoring and execution of the license conditions, including periodic reports, SINIR, CADRI and other ancillary obligations, to maintain environmental compliance beyond the main license.

What do the technical terms in Environmental Licensing mean?

Acronyms and regulatory terms that appear in this service, explained plainly.

CETESB

Companhia Ambiental do Estado de São Paulo. The state agency responsible for controlling, inspecting, monitoring and licensing potentially polluting activities in the state of São Paulo, reporting to the State Environment Secretariat.

LOR

Licença de Operação – Renovação (Operating License – Renewal). A type of environmental license issued by the licensing authority for facilities that already hold initial licensing. It requires compliance with the specific technical conditions set by the agency in the previous document so operations may continue.

LO

Licença de Operação (Operating License). The third stage of environmental licensing, authorizing the facility or activity to begin operating once compliance with the previous phases' conditions has been verified and the environmental control systems confirmed effective.

LP

Licença Prévia (Preliminary License). The first stage of Brazil's three-phase environmental licensing, assessing the environmental viability and siting of a facility or activity before installation, approving the concept and setting conditions for the following phases.

LI

Licença de Instalação (Installation License). The second stage of environmental licensing, authorizing the start of construction once the conditions set in the Preliminary License have been met and impact mitigation measures have been demonstrated.

PGRS

Plano de Gerenciamento de Resíduos Sólidos (Solid Waste Management Plan). A mandatory document for companies that generate solid waste, setting out the stages of identification, generation, segregation, containment, collection, storage, transport, treatment and proper disposal of the waste produced.

SINIR

Sistema Nacional de Informações sobre a Gestão dos Resíduos Sólidos (National Solid Waste Management Information System). A federal platform run by the Ministry of the Environment for recording, monitoring and declaring solid waste management by generators, operators and public authorities.

CADRI

Certificado de Movimentação de Resíduos de Interesse Ambiental (Certificate for the Movement of Waste of Environmental Interest). Issued by CETESB, it authorizes the transport of hazardous waste or waste of environmental interest between generators, carriers and disposal facilities, with traceability across the disposal chain.

APP

Área de Preservação Permanente (Permanent Preservation Area). An area protected by the Brazilian Forest Code (Lei 12.651/2012) for its environmental role in preserving water resources and biodiversity. It includes riverbanks, springs and slopes, where vegetation removal is restricted and requires specific authorization from the competent environmental agency.

APRM

Área de Proteção e Recuperação dos Mananciais (Water Source Protection and Recovery Area). A protected area category in the state of São Paulo, governed by specific legislation, intended to preserve the quality and quantity of water from public supply sources, with distinct rules for land use and occupancy.

IBAMA

Instituto Brasileiro do Meio Ambiente e dos Recursos Naturais Renováveis. The federal agency under the Ministry of the Environment responsible for federal environmental licensing, enforcement, wildlife and vegetation control, and environmental monitoring nationwide.

CTF

Cadastro Técnico Federal (Federal Technical Registry), covering both Potentially Polluting Activities or Activities Using Environmental Resources and Environmental Defense Instrument Activities. Registration with IBAMA is mandatory for companies and professionals whose activities may have an environmental impact.

RAPP

Relatório Anual de Atividades Potencialmente Poluidoras (Annual Report of Potentially Polluting Activities). An annual accountability filing required by IBAMA from companies registered with the CTF, describing the activities carried out, the inputs used, the waste generated and the associated environmental impacts over the period.

INRSI

Inventário Nacional de Resíduos Sólidos Industriais (National Inventory of Industrial Solid Waste). A mandatory declaration for generators of industrial waste, recording the quantity, classification and destination of the solid waste produced by the industrial activity in the declared period.

SP Águas (formerly DAEE)

Agência de Águas do Estado de São Paulo (São Paulo State Water Agency). The state government body responsible for managing water resources, granting water abstraction and effluent discharge permits, licensing hydraulic works and overseeing water use across the state.

What are the most common questions about Environmental Licensing?

Structure the environmental front of your operation

The environmental front matures when the company stops thinking only about licenses and starts controlling the routine that keeps the license valid.