Publication Name

MINING FOR CLOSURE

improved access to land resources from gov-

ernments;

improved access to capital from reputable

lending institutions;

the potential for reduced cost of capital and li-

ability insurance;

continual feedback upon the manner in which

community expectations are being achieved.

As is discussed in essentially all informed sources, it

is in the best interest of business for such activities

to take place at the right phase of mine life in order

to minimise such expenditures. As mine decom-

missioning usually occurs at a point in the life of an

operation where the economic recovery of minerals

has ceased, and cash flows are minimal or non-exist-

ent, then this is not the time to be undertaking the

bulk of rehabilitation operations. The overall mine

decommissioning process should be integrated

with the overall mine operation planning process.

Further, if decommissioning and closure are not un-

dertaken in a planned and effective manner, chances

are that the results will also be sub-optimal.

2.2.2

the governmental case

Traditionally, good governments have had a principal

accountability for considering environmental and

social externalities while the focus of mining com-

panies has been on internal efficiency concerns.

At first glance – and especially for environmentally

aware stakeholders – the case for governments

pursuing the implementation of

best environmental

practice mining

and/or

Mining for Closure

, would

appear clear. If miners do not internalise the costs

of mine site rehabilitation and other social and/or

environmental impacts related to closure, then

Governments will have to do so on behalf of soci-

ety. Such works would have to be paid for from the

public purse. Further, for reasons mirroring those

outlined in Section 2.2.1, their conduct is likely to

less

efficient and less effective than if performed

by the miner.

However, there are arguments that the imposition

of costs on the industry can have detrimental ef-

fects, principally as a barrier to investment and

development.

This said, mining legacies could

be deemed to be the result of past and present

governance failure that is shared by essentially all

mining countries. Herein lies the arguments for

governments to pursue

Mining for Closure

– if regu-

latory frameworks ensuring efficient prevention of

mining legacies, and the rehabilitation of existing

legacies, are not put in place, then future national

tax-payers will have to pay much more for the work

and present stakeholders will have to endure the

environmental and social nuisances in the mean-

time.

The following citation from the Assistant Deputy

Minister for the Province of Ontario’s Ministry of

Northern Development and Mines (MNDM) (Gam-

mon, 2002) underlines the position that Govern-

ments around the world are faced with as a result

of poor governance and industrial environmental

practice in the past:

In coming to grips with the problem Ontario first

felt a need to classify and inventory these site lo-

cations. An initial commissioned survey of paper

records indicated that there would be on the order

of 600 individual features to be dealt with at an

estimated total cost of Cdn$500 million. It was

further estimated that some 40% of these sites re-

mained in private ownership while 60% had re-

verted to the Crown and formed a liability for the

Ontario taxpayer.

The Ontario government has reluctantly recog-

nized that it is not practically possible to apply

the “polluter pays” principle in dealing with this

legacy. The original operators have long disap-

peared, the commodities produced have been con-

sumed and the taxes paid have been incorporated

in general revenues. The current industry consists

of totally different players behaving in accordance

with the regulatory framework that the govern-

ment now has in place. There appears to be no

real alternative than to allocate public funds to

deal with the worst sites.

While there are other advantages defining the gov-

ernmental case for pursuit of

Mining for Closure

, it

suffices to summarise them within the following

broad categories:

the prevention of harmful environmental and

social impacts,

lower risk of non-compliances,

greater acceptance/less resistance from key

stakeholders (in particular local communities

and land owners),

35. These are discussed in more detail in Section 2.4, refer also to

Miller (1998; 2005).

36. Detail references to, and the contents of Canadian work in this

area are addressed in Sections 4.2.2, 5.1.2, and 5.1.3.

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