The Environmental Company of the State of São Paulo (Companhia Ambiental do Estado de São Paulo or “Cetesb”) has already been demanding the payment of the charge for the issuance of technical advice on intervention plans for the reuse of contaminated areas. The charge starts at 750 São Paulo State Fiscal Units (UFESPs), which is currently equivalent to R$ 18,802.50. Such amount must be added to the result of a formula that involves the factor of complexity of the sources of pollution provided for in State Decree No. 8.468/1976, and the total area of the undertaking.

Although the private sector in Brazil is aware of the opportunities for concessions and public-private partnerships related to classic public services and the execution of infrastructure projects, these forms of transactions are still little used for environmental conservation.

The Federal Attorney's Office of the Brazilian Institute for the Environment and Renewable Natural Resources – IBAMA, acknowledged on August 2, 2016, that a change in the ownership of environmental licensing processes is possible at any time, since the object of the licensing is the enterprise, the work, the establishment, or the activity, not the individual or legal entity that requests it. The agency’s decision follows a theory that was already supported in legal scholarship and was practiced by environmental agencies throughout Brazil.

Daniela Stump, Liliam Yoshikawa, and Daniel Guariento    The Public Prosecutor of Minas Gerais ("MP/MG") filed, on April 11, 2016, Public Civil Action No.