Afforestation in cities requires regulatory predictability, coordination between land use, climate and vegetation, in addition to effective inspection mechanisms
The overturning of 52 vetoes to the General Environmental Licensing Law (Law No. 15,190/2025) by the National Congress creates a contradictory scenario: while the federal government proposes a National Urban Afforestation Plan (PlaNAU), the Legislature approves rules that reduce requirements for projects with potential impact on vegetation.
Although the plan brings together guidelines, goals and a proposal for the division of responsibilities between the Union, states and municipalities, it still lacks basic instruments for its implementation. It lacks a governance body, a monitoring system, consolidated indicators and sources of financing, remaining as a technical reference, but without real insertion in the administrative routine of the federative entities.
Overturning the vetoes directly interferes with its viability by reestablishing rules that make environmental licensing more flexible, including the License for Adhesion and Commitment (LAC – for low-impact activities) and the Corrective Operation License (LOC – which regularizes existing operations without a license). These devices, criticized for reducing technical controls and eliminating the need to consult specialized bodies, change the institutional environment necessary for the consolidation of environmental policies.
In locations with low technical capacity, protected areas, ecological corridors and fragments of urban vegetation can be affected by projects released without careful analysis, increasing environmental and social risks. This opens up space for the regularization of activities in fragile areas without adequate assessment of cumulative impacts or effective public participation — especially serious in a country with a chronic history of low environmental oversight.
Afforestation in cities requires regulatory predictability, coordination between land use, climate and vegetation, in addition to effective inspection mechanisms, precisely the points weakened by the new legislation. With more autonomy for states and municipalities to define their own criteria, an asymmetrical regulatory mosaic is formed in which municipalities with greater technical capacity will be able to maintain more rigorous requirements, while others, with less structure, will tend to become more flexible. The result? Deepening territorial inequalities and the fragmentation of a policy that should be national.
Instead of serving as a guide for a coordinated public policy, PlaNAU runs the risk of becoming another letter of intent, as implementation will depend on the level of engagement, available resources and local political disposition. In practice, national policy becomes residual, subordinated to the technical capacity and choices of each municipality.
The argument used to overturn the vetoes — unlocking investments and ensuring legal certainty, contrasts with the technical evidence and the real context faced by cities: extreme heat, windstorms, floods and increasingly frequent urban collapses. Replacing technical studies with self-declarations compromises the ability of environmental agencies to prevent significant impacts and protect sensitive areas. Instead of legal certainty, the result may be regulatory instability and the judicialization of controversial projects.
The new legislation imposes a forced realignment of public policies, favoring agility in the implementation of new projects, while structured urban afforestation actions, both social and institutional, face more barriers in a regulatory environment that is adverse to them.
What is at stake is not just the execution of a federal plan, but the country’s ability to recognize urban vegetation as essential infrastructure to face the consequences of the climate crisis. Congress exercised its prerogative by overturning the vetoes, regardless of the technical or ideological reasons that motivated them. It is now up to the Executive and local governments to decide whether PlaNAU will be implemented with coherence and priority, or whether it will continue as another ignored technical document, buried between good intentions and legislation that pulls in the opposite direction.
*This text does not necessarily reflect the opinion of Jovem Pan.
