OK, time for some good news (well, I see it as good news).....

OK, time for some good news (well, I see it as good news).. Whilst this extract relates to mining, it does preface the activity of exploration, mining and the ongoing operations for the life of the Salobo mine, 12km away in the same forest and as far as I can ascertain, the same jurisdiction..

From the Silver Wheaton Report (2015) - who ... ah bugger it. You can search Silver Wheaton & Salobo and you can read to 263 page report yourself, as I did.

Terms of reference:
Silver Wheaton Corp. (Silver Wheaton) requested that Amec Foster Wheeler Americas Limited (Amec Foster Wheeler) prepare an independent technical report (the Report) in compliance with the requirements of National Instrument 43-101 Standards of Disclosure for Mineral Projects (NI 43-101) and Form 43–101F1 Technical Report on the Salobo open pit mining operations (Salobo Operations or the Project), located in northern Brazil, in the southeastern portion of Pará State. The Salobo Operations comprise the Salobo open pit copper–gold mine (Salobo Mine).
The Report was prepared to support Silver Wheaton’s scientific and technical disclosure on the Salobo Operations in their Annual Information Form for the year ending 31 December, 2015


Key takeaway from their risk profiling to mining and the environmental risk to the operation of mining:

Although the Brazilian legal system provides for two types of titles, one for exploration and one for mining, it does grant security that the holder of an exploration licence can mine any deposit that is discovered within the granted title. The government is required to grant a mining concession to an entity that has explored for, identified a Mineral Resource, obtained DNPM approval of the exploration report, filed applications for a mining concession in a timely manner, and obtained an LI. Reasons for not granting a mining concession would be on the grounds of public interest, or if the Federal Government considers that it could have a negative effect on certain interests which are more important than mineral exploitation. In the latter instance, in those cases where a final exploration report has already been approved, a mining concession applicant is entitled to be indemnified by the Federal Government for any expenses incurred relating to the completed exploration work. Brazil has a concept that is termed “environmental conservation units”, which can be created by either the Federal Government, States or Municipalities, and can be either total protection conservation units, where industrial activities such as mining cannot take place; or sustainable use conservation units, where some industrial activities (including mining) may be carried out as long as they comply with regulatory requirements. Every environmental conservation unit in Brazil must have its own management plan that sets out the regulations for the administration and occupation of the unit. The plan includes regulations applicable to the zone that surrounds the unit

Given we received our EL late last year, commensurate with what is written in the ANN from mgmt, the interpretation of enviro (ICMBio) does not make sense and IMO is indeed red tape delay only.. Any limitation to mining/exploration should have been noted in an EL previously, or attached as caveats to any tenement being applied for - much like a typical land title..

Summary:
In the opinion of the QPs, the information discussed in this section supports the declaration of Mineral Resources and Mineral Reserves, based on the following:
• Information provided by Vale supports that the mining tenure held is valid and is sufficient to support estimation of Mineral Resources and Mineral Reserves
• Information provided by Vale supports that Vale holds sufficient surface rights in the Project area to support the mining operations envisaged in the life-of-mine plans, including access and power line easements
• Vale currently holds the appropriate permits under local, Provincial and Federal laws to allow mining operations (refer to Section 20). Some permits will require renewal over the course of the planned life-of-mine
• The appropriate environmental permits have been granted (refer to Section 20)
• At the effective date of this Report, environmental liabilities are typical of an operating open pit mining area (refer to Section 20)
• Vale is not aware of any significant environmental, social or permitting issues that would prevent continued exploitation other than those discussed in the Report
• There is no active artisanal mining on or near the property
• To the extent known, there are no other significant factors and risks known to Vale that may affect access, title, or the right or ability to perform work on the Project