72
MINING FOR CLOSURE
much larger issue of environment and security
risks posed by mining related in SEE/TRB.
102
what are the key institutional
issues in see/trb?
103
Mining for closure
issues
Institutionalised practices aligned with the precepts
of
Mining for Closure
are undeveloped in SEE/TRB
–
Mining for Closure
activities should commence
before approvals are given for the development of
a mining project. Among other things a conceptual
mine closure plan should be submitted at the feasi-
bility stage that include plans for decommissioning
and rehabilitation of each component of the min-
ing area with cost estimates.
Experiences with financial assurance tools and
funding mechanisms for closure in general are
limited
– appropriate funding mechanisms are es-
sential to ensure sufficient funds are available for
mine closure activities and the completion of all de-
commissioning and rehabilitation requirements.
Traditions of review processes and stakeholder con-
sultations are lacking
–
Mining for Closure
plans
must be reviewed periodically throughout a mine
life in order to cater for changes in the overall min-
ing plan, changes pursuant to environmental re-
views, and needs and aspirations of the communi-
ties. Consultation with all external stakeholders and
their participation are vital for the successful plan-
ning, operation and closure of any mine and to en-
sure social and economic activities are maintained.
Technical, ecological, risk related and “sustainable
development related institutional capacities are insuf-
ficient
–
Mining for Closure
demands combinations
of the aforementioned expertise. These are uncom-
mon in most mining countries, let alone in countries
that have experienced recent institutional flux. The
primary concerns for decommissioning and reha-
bilitation are to ensure public safety and health, en-
vironmentally stable conditions compatible with the
surrounding environment are achieved and to mini-
mize environmental impacts caused by mining. The
overall objectives are to achieve a social, economical
and environmental sustainable development.
Further, present mining legacies around the world
indicate that insufficient institutional capacity and/
or a lack of development in institutional frameworks
are prevalent problems in most countries involved in
mining – including developed nations. Weaknesses in
the following institutional parameters are common:
the general absence of mine reclamation poli-
cies and regulations until the latter part of the
twentieth century indicates that most remain
in their infancy or relatively untested;
ineffective enforcement of mine reclamation
policies and regulations if, and where in exist-
ence has been common;
the absence of financial security mechanisms to
ensure funds for parties such as government to
conduct remediation in the event of miner de-
fault has been the rule rather than the exception;
inadequate financial security to address reme-
diation if, and where such funds were set aside
has been common;
avoidable and/or unnecessarily damaging
technical practices remain in use in many
mining jurisdictions;
loss of mine data including records of under-
ground workings and surface openings may
remain an issue;
political unrest, conflict and political instabil-
ity leading to unscheduled cessation of activi-
ties at mines is still common.
Broader environment and security related issues
Skills
(capacity) availability in the region is often in-
sufficient to perform adequate national and trans-
boundary hazard and risk management.
Data
(both qualitative and quantitative) availability in
the region is insufficient to perform adequate nation-
al and trans-boundary hazard and risk management.
Dialogue
with key stakeholders such as national
and international NGOs, affected citizens, and so
forth is insufficient.
why should these issues be
dealt with?
Mining for closure
issues
These issues should be combated with corporate
governance approaches, regulatory frameworks,
102. Refer to Peck (2004) and Burnod-Requia (2004) for UNEP
related output. There are also a number of other publications pro-
duced by the Romanian Government of great relevance as well
as documents such as that produced by Zinke/ICPDR (ICPDR/
Zinke Environment Consulting, 2000).
103. Many of these points are derived from a paper from the Chilean
Copper Commission (Cohilco: Chilean Copper Commission, 2002).
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