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66

MINING FOR CLOSURE

who should act and where?

Governmentswill need to lead thewaybecause it isnot

practically possible to apply the “polluter pays” prin-

ciple in dealing with most abandoned or orphaned

sites. The original operators have long disappeared,

the commodities produced have been consumed and

the taxes paid have been incorporated in general rev-

enues. It appears that there is no real alternative to

the allocation of public funds to deal with the worst

sites. However few governments, let alone most gov-

ernments in SEE/TRB, have the resources or the ex-

pertise to take on physical and financial responsibility

for dealing with orphaned (or abandoned) sites. The

costs of ameliorating the most difficult problems may

also need to be spread among parties that would ben-

efit the most from the solutions to the problems.

Collaborative ventures between stakeholders will

be vital in order to deal with abandoned and or-

phaned mining sites in SEE/TRB. Key actors have

been identified as being policy makers and legis-

lators at all levels of government, companies, the

investment community, local communities and

non-governmental organizations.

Responsible parties for abandoned sites should be

involved in the process and financial accountability

within practical limits where they can be identified.

In the context of SEE/TRB, “collaborative involve-

ment” strategies may be more productive than li-

ability actions.

when should these actions be

taken?

Action needs to take place as soon as is practicable.

There is significant potential for ongoing deteriora-

tion in the regional risk situation. This is due in

part, to the cessation of industrial activities with-

out planned closure measures (be it as a result of

socio-economic turbulence, or for other reasons).

Cessation of activities is often associated with rap-

id deterioration in the condition of waste storage

areas in the absence of maintenance activity and/

or any form of monitoring. There are numerous

abandoned or “temporarily abandoned” sites in the

region that are gradually (or even rapidly) deterio-

rating with commensurate increase in risks to both

local communities and international relations.

Actions and sites for action must be prioritised. All

sites

cannot

be dealt with immediately. The action

that must be advanced with all possible haste is the

prioritization of “hot-spots” in each country and

description of potential impacts associated with

each of them, in particular impacts that may cause

trans-boundary tensions and security risks.

6.2

operational sites

what are the key issues regard-

ing operational mining sites?

The many operational mining sites in the region

have great potential to become mining legacies.

In this discussion’s context it is important to note

that an abandoned or orphaned site should be

considered to include both the physical aspects

(the mine site) and the social aspects (the stake-

holders).

That enhancement of

all

options to ensure ad-

equate mine closure is vital. While mines that are

in the middle of their operating life have signifi-

cant opportunities to ensure best practice closure,

operating mines that are close to the end of their

economic life have limited options available.

The preservation of ongoing activities at potential

legacy sites in order to allow ongoing site reclama-

tion may be an important – if not critical – strat-

egy in ensuring improved outcomes. Where mine

operators have become insolvent, or are unable to

finance the costs of reclamation, responsibilities

revert to the State, however State run initiatives

may not be the most efficient or effective manner

in which to reclaim or make safe sites.

That adequate policy and/or regulatory frameworks

are absent or in their infancy.

That the frameworks and capacity to implement

Mining for Closure

approaches as outlined in this

document are not yet in place in the region, yet it is

such approaches that are required to address many

of the challenges.

That current mining operations have not yet adopt-

ed

Mining for Closure

approaches in SEE/TRB.

why should these issues be

dealt with?

Dealing with these issues is required to best serve

the interests of all mining stakeholders.