15. Mine closure planning
Mine closure planning and post-closure planning have become important parts of an environmental sub-element of a mining policy. Although these elements should be part of an ESIA, many governments have taken the policy to develop a “mine closure” checklist that is specifically required to address closure issues. Some governments have required that at least the concept for a mine closure plan be required at the outset of mining, a policy that recognises that closure planning can influence the construction of mine infrastructure. For example, at the Selibe Phikwe copper/nickel mine in Botswana, some of the buildings were designed to be converted to classrooms at the closure stage.
The Australian Environmental Protection Agency has developed a good standard for mine closure planning. It notes that “nationally and internationally, industry-leading practice requires that planning for mine closure should start before mining commences and should continue throughout the life of the mine until final closure and relinquishment”. The Minerals Institute of Brazil has also developed a very complete and detailed guide for mine closure planning.
Some policy considerations regarding mine closure planning include:
The process for handling labour issues including timing for layoffs and identification of additional employment opportunities
Management of the impact of cessation of mining company funding for community initiatives
Process for transfer of social infrastructure such as schools and hospitals over to local government; transfer of provision of water or other basic services to local government (if the mining company has taken on these responsibilities)
Requirement for post-closure risk assessment, construction and maintenance programme of mine tailings and other waste facilities
Mine reclamation plans to restore the land base to its prior condition
Securing of the mine site, filling in of holes, closing of shafts, etc.
Another key element to managing environmental impacts from mining concerns the requirement for up-front funding vehicles to manage environmental reclamation requirements.
Many mining authorities are now following a policy that requires upfront funding for mine rehabilitation. Mining companies must demonstrate that they have sufficient funds for environmental rehabilitation at the beginning of a mining project. These are known as “financial sureties” or “mine reclamation funds”. There are many guidelines available to governments to establish a policy around this requirement. The Australian province of Victoria has prepared a good guideline, “Establishment and Management of Reclamation Bonds for the Extractive Industries”.
Other policy issues related to environmental management of mining concern the need for environmental and social audits from time to time.
These audits check the impact mitigation plan in the ESIA and do a detailed investigation to be sure the plan is being implemented.
The way the country organises its environmental authority is also a matter for policy consideration. Some countries have established “Environment Boards” that are usually located in regions close to where mining and other industrial activities are occurring. These Boards have several different government representatives on them. Usually, government authorities in charge of social welfare, labour, environment, mining, justice and treasury may sit on such a Board. These Boards review ESIAs and help to monitor progress. They also can make decisions when environmental issues arise that need a “whole of government” approach to solving problems.
Some countries may decide to develop an environmental guideline for the mining or extractives industries sector. This guideline would use the environmental law as a base, and then fit some of the general pollution control and conservation requirements to the specific nature of mining.
Guidelines for Preparing Mines Closure Plans, Australia EPA, 2015: http://www.epa.wa.gov.au/EPADocLib/153549_WEB%20VERSION%20–%20Guidelines%20for%20Preparing%20Mine%20Closure%20Plans.pdf
Brazil Institute for Minerals. Guide for Mine Closure Planning, 2014: http://www.ibram.org.br/sites/1300/1382/00004552.pdf
Environmental Defender’s office: Environment Law in the Northern Territory (Fact Sheets on Mining and the Environment): http://edont.org.au/factsheets/environment-protection-minerals-mining/