Suzano Imperatriz Pulp Mill Project, Brazil
Summary of Social and Environmental Assessment
2012-11-19
1. Background
1.1. The project
The Suzano Imperatriz Pulp Mill in Brazil is a greenfield project for the construction of an industrial
unit to produce bleached eucalyptus pulp in the southwest area of the state of Maranhão, near the city
of Imperatriz. The unit will have an installed capacity of 1.5 million tons per year of eucalyptus market
pulp and the start-up is scheduled for the 4th quarter of 2013. In addition to the pulp mill site itself, the
project includes plantations, infrastructure development, logistics and shipping.
1.2. Purpose of this document
The Suzano Imperatriz Pulp Mill is classified as a category A-project. During the development phase,
a large number of reports have been produced, which describe the Environmental and Social impacts
and mitigation strategies of the project, totalling more than 6000 pages. A majority of the material is in
Portuguese. The purpose of this document is to summarize the status of the project from an
environmental and social point of view and how it benchmarks against international standards with
focus on the IFC Performance Standards and Equator Principles.
2. Activities to date
2.1 EIAs performed according to Brazilian legislation
In Brazil, an Environmental Impact Assessment (EIA) is required during the environmental licensing
process of new projects or expansion projects. The Federal CONAMA Resolution 01/86 requires that
an EIA must be prepared by developers for new projects or expansions of projects listed in its Article
2, which includes pulp and paper production facilities, railways, ports, pipelines, high voltage
transmission lines above 230 kV and energy power plants above 10 MW, among others. However, this
list is only indicative, allowing State or Municipal agencies to require an EIA for other planned
industries or enlargement of existing ones.
An EIA and its non-technical report RIMA (Relatório de Impacto Ambiental) must be developed,
submitted to the environmental protection agency and to a public hearing, reviewed and approved
before the issuance of an Environmental Preliminary Permit.
A number of EIAs and RIMAs have been finalised in Portuguese during the development phase of
Suzano Imperatriz Pulp Mill project for the Pulp & Paper mill, Railway Access, Access Road,
Transmission Line 230kV and plantations in the state of Tocantins and Maranhão.
2.2 Brazilian EIAs vs. Internationally required ESIAs
The EIA required by Brazilian legislation differs from ESIAs (Environmental and Social Impact
Assessment) applied by international financial institutions since it does not consider international
legislation, guidelines or best practices within the sector of the project, including IFC Performance
Standards. In addition, Brazilian EIA:s do not consider occupational health and safety, labour and
working conditions, land acquisition and other aspects of the IFC Performance Standards.
Consequently the environmental agencies follow basically the standards and environmental threshold
limits (i.e. air emissions, wastewater discharge, among others) established by municipality, state or the
union in order to approve or issue the permits. In general, Brazilian environmental threshold limits are
less stringent than those of the IFC Performance Standards and IFC EHS Guidelines.
2.3 Benchmarking against International Standard (early 2012)
Given the differences in Brazilian legislation and International Standard in early 2012, the
international parties involved in the project asked for an external evaluation of the project, prepared by
independent consultants. The purpose was to get a full overview of how the project fulfils international
standard, i.e. the IFC Performance Standards. The evaluations were performed through an assessment
of deviations against international requirements and were based on all relevant background
documentation, site visits and a review of licenses and other permits.
The evaluations looked at both social and environmental aspects, and resulted in two reports:
 Evaluation of EIAs and Benchmark of Environmental Performance of Suzano Imperatriz Pulp
Mill, Final report (ÅF, 12.03.12). pdf-format.
 SUZANO Imperatriz Pulp Mill Project. Evaluation of original EIAs. (Environ, March 2012).
ppt-format.
The reports highlighted a number of gaps or potential gaps, which were reviewed during a site visit
conducted by EKN and other parties in June 2012.
2.4 EKN site visit (June 2012)
Consultancy firm ÅF was hired by EKN to conduct the review of social and environmental status,
including a site visit in June 2012. The review was based on the previously identified gaps and
including the following components.
 Document review:
- Industrial Environmental Impact Assessment - EIA (Pöyry, 05.23.11)
- Environmental and Social Due diligence (Pöyry, 08.03.11)
- SUZANO Imperatriz Pulp Mill Project. Evaluation of original EIAs. (Environ, March
2012)
- Evaluation of EIAs and Benchmark of Environmental Performance of Suzano Imperatriz
Pulp Mill, Final report (ÅF, 12.03.12)
 Site visit in Brazil in June 2012: Suzano head office, pulp mill site, communities, authorities,
plantations, port, infrastructure.
 New evaluation of all reports listed above, with the additional information from the site visit,
meetings and review of selected background material.
The review concluded that some gaps had already been closed during the first months of 2012 and
some gaps remained, while a few new gaps were identified as a result of the site visit.
3. Status as of October 2012
3.1 Updated Gap Analysis and Action Plan (June-Oct 2012)
As a follow-up from the site visit in June 2012, the consultancy firm ERM was hired by Suzano to
update the gap analysis reports from early 2012, again with focus on how the project fulfils local and
international conditions IFC Performance Standards.
ERM’s assessment resulted in an updated Gap Analysis Report, including an Action Plan which
specifies how the remaining gaps shall be met by Suzano. The Action Plan defines objectives,
responsibilities, activities, timeline and results for the implementation.
The ERM Gap Analysis and Action Plan dated December 21st 2012 is available on the EKN webpage.
3.2 Key points in the Action Plan
Examples of key points in the Action plan include:
 Environmental and Social Assessment and Management System (ESMS): Suzano shall review
the corporate management system manual to ensure it includes all relevant aspects for the full
scope of the project. IFC Performance Standard 01, paragraph 5. Timeframe 6 months.
See the attached ERM Gap Analysis and Action Plan for more details.
3.3 Documentation available at EKN upon request
In addition to the ERM Gap Analysis and Action Plan published on the EKN website the following
documents can be obtained from EKN upon request:
-
Industrial Environmental Impact Assessment - EIA (Pöyry, 05.23.11)
Environmental and Social Due diligence (Pöyry, 08.03.11)
SUZANO Imperatriz Pulp Mill Project. Evaluation of original EIAs. (Environ, March
2012)
Evaluation of EIAs and Benchmark of Environmental Performance of Suzano Imperatriz
Pulp Mill, Final report (ÅF, 12.03.12)
Suzano description of the environmental and social program
Itaqui Port description
Suzano presentation of Maranhão Mill Project
4. Conclusion
In summary, EKN approves this project from an environmental and social perspective. It is classified
as a Category A project with a number of conditions:
Before the guarantee is issued an independent consultant, approved by EKN, shall update the gap
analysis, with regard to how the project fulfils local and international conditions (IFC and Equator
Principles). The gap analysis shall result in an Action Plan, accepted by EKN, describing how any
remaining and potential new gaps shall be met by Suzano. The Action Plan shall define objectives,
responsibilities, activities, timeline and measurable results for the implementation.
During the guarantee period EKN has set out a number of environmental and social conditions. The
purpose of the conditions are to ensure that the action plan is executed as agreed and the project
follows and reports on the environmental and social management system.