Praia do Gunga's fame is entirely visual: a coconut-lined sand spit where the Rio São Miguel's tidal lagoon meets the open Atlantic, the water reading bluer at low tide and greener at high tide as the two systems trade places. What that image leaves out is that the beach's actual tourist economy — the part that makes the postcard functional rather than theoretical — spent years running ahead of its own paperwork.

What was actually operating. By July 2017, according to complex administrator Edinaldo Pulcino, the beach supported 14 bar-restaurants, 18 food stalls and 32 craft stalls arranged in a dedicated pavilion. That is 64 individual commercial operations on a single sand spit in a municipality of about 6,500 people. Pulcino put monthly visitor traffic at roughly 5,000 in high season and 2,000 otherwise, and estimated the complex supported around 600 direct jobs and 3,000 indirect ones — a meaningful share of Roteiro's economy, running on a beach most outsiders encounter only as a photograph.

Why regularization, and why then. On 7 July 2017, Gustavo Lopes, director-president of Alagoas' state environmental institute (IMA/AL), met with Roteiro mayor Wladimir Brito and administrator Pulcino to begin drafting a Termo de Ajustamento de Conduta, a TAC. This is the standard Brazilian legal instrument for bringing an already-operating business or development into compliance with environmental law after the fact, rather than requiring compliance before construction. Brazil uses TACs constantly, precisely because so much commercial development along its coastline gets built first and licensed later, if at all. The framing of the 2017 meeting as "the first of several" meetings is itself informative: this was not a formality being rubber-stamped, but the opening move in a negotiation over how a functioning, job-supporting tourist complex would be brought into a compliance framework it had operated without.

The private road underneath the postcard. Gunga's access compounds the informality. There is no public road connecting the beach to the highway network; English-language reference sources describe car access simply as driving "through a private property." Visitors without a car cross the Lagoa do Roteiro by boat from Barra de São Miguel's marina instead, a fifteen-to-twenty-minute trip. Route-distance calculations bear out how indirect the land option is: a road trip from Zumbi dos Palmares International Airport runs about 64 kilometers and 68 minutes, well above the 40.7-kilometer straight-line distance a flat map would imply, because the coast road detours inland around the lagoon system before a final approach that isn't public right-of-way at all. Functionally, this means one of Alagoas' most reproduced tourism images sits on a peninsula where the state has negotiated environmental terms with the people running the kiosks, while the physical route to get there by land runs through the Fazenda Gunga — land the Ministério Público Federal's own 9 May 2017 recommendation names as controlled by ex-mayor Nivaldo Jatobá and his company, Nivaldo Jatobá – Empreendimentos Agroindustriais LTDA, not the state. The 2025 TAC's own recitals note there is no roadside parking on that access road, so arriving by car in practice means paying the complex's parking fee; anyone unwilling or unable to pay it is effectively shut out. Two separate kinds of informal governance sit on top of each other: commercial and territorial.

The ecology arrived on its own terms too. The peninsula's wildlife punctuates this story rather than illustrating it directly, but the pattern rhymes. In January 2018, bathers found a two-meter broad-snouted caiman (Caiman latirostris) on the sand. The species had been locally extinct in Alagoas for roughly two decades; a captive-breeding facility in Maceió's Fernão Velho neighborhood reestablished a wild population, and rising water in inland lagoons during the breeding season periodically pushes individuals toward the coast, Gunga's lagoon included. Eleven months later, a stranded melon-headed whale died on the beach despite intervention from the Instituto Biota. Both events are reminders that the lagoon-and-ocean geography that makes Gunga scenic also makes it a live ecological corridor, not a static backdrop.

And nobody is watching the water. The complex has no lifeguard service. When a speedboat lost power and struck rocks near the beach on 11 September 2017, injuring six people including two children, it was jangadeiros, independent traditional raft fishermen working the area, who performed the rescue, not any official emergency service. On 1 December 2018, a 60-year-old man drowned here; fire, ambulance and helicopter units responded but could not revive him. The ocean side of the peninsula carries a real, dataset-flagged rip current and an annual mean wave height of 1.46 meters, rising toward 1.8 meters in June — conditions that exist regardless of how informally the beach around them is run.

What actually singular about Gunga, then, isn't the color-changing water. Plenty of estuary-mouth beaches shift color with the tide. What is specific to this one is the gap between how it is marketed and how it is governed: a photogenic sand spit that, for years, ran a 64-stall, thousands-of-jobs tourist economy on land it reached through someone else's driveway, while its operator repeatedly failed to meet the terms the state set for it. IMA issued 27 infraction notices on 1 July 2017; a first TAC, TAC/COJ nº 94/2017, was signed with the operator on 28 August 2017; in March 2024 IMA cancelled that TAC outright, citing total non-compliance — no sewage-treatment plant, no solid-waste system, no urban plan, no environmental-education project — and embargoed part of the complex the following month. After a 10 June 2024 meeting between the Ministério Público Federal, IMA/AL and the complex, a second TAC was signed on 10 April 2025: it gives the operator 30 days to file sewage-treatment, hydro-sanitary, architectural, solid-waste-collection, IPHAN and SPU documentation, after which IMA has 60 days to assess it before deciding whether to issue an operating licence, and it requires at least 20% of the complex's lower parking lot to be kept free for reduced-mobility access. As of April 2025, then, the operator had a fresh filing deadline, not a finished permit — whether IMA has since issued an operating licence isn't documented here.