Publication Name

MINING FOR CLOSURE

6.5

mine closure

policies in general

what other key issues exist re-

garding mine closure policies?

The ongoing fundamental divide between the inter-

ests of mining companies and the interests of the

communities where mining is hosted represents a

challenge that must be ameliorated.

The determination of bonds size – the key param-

eter of financial assurance for mine closure and

reclamation – is problematical.

The integrity of financial securities is vital.

Ongoing improvement of existing

and new

closure

policies and regulations is necessary and must be

planned for.

Poorly considered distribution of redundancy

schemes, provision of redundancy payments, and

application of re-training schemes (even where fair

and adequate) can lead to follow-on problems (re-

bound effects).

why should these issues be

dealt with?

If items such as those listed above generally refer

to challenges to be faced when implementing good

practice that one has striven after. Such issues dem-

onstrate that even when

Mining for Closure

practic-

es have been established within sound institutional

frameworks and then put in place, they must still

be managed carefully. Further, that flexibility and

the need for revision must be recognised. The al-

ternatives are sub-optimal solutions or even failure

of the measures.

how can these issues be pro-

gressed?

These items are essentially planning related and

can be catered for (if not resolved) by planning proc-

esses that integrate a range of safeguard measures.

In general terms, such processes should involve:

the definition of a vision of the end result for

mining land that sets out concrete objectives

for implementation;

ensuring that the mine closure plan is an inte-

gral part of a project life cycle;

the preparation of a mine closure plan early

in the process of mine development and in

consultation with the regulating authority and

local communities;

the explicit inclusion of environmental, social

and economic aspects in the planning for min-

ing operations;

allowances for review and evolution that

stretch from the pre-mine planning phase,

through construction, mining, and mine clo-

sure to post-mine stewardship.

As more specific items, such processes should in-

corporate:

the concerns/participation of other stakehold-

ers in the reclamation objectives;

plans for action if ownership reverts to the

state despite all efforts to ensure otherwise;

the preservation of mine management and

geological records;

early delineation of project creditors’ claims on

the site;

legal considerations for ownership, both now

and in the past;.

maintenance of control over tenure if leases

expire and another party wants to obtain rights

to the surface/subsurface;

adequate capacity among regulatory personnel;

ongoing research and testing of remediation

strategies and technologies and integration of

results in

Mining for Closure

review processes;

surveillance of the views and desires for the in-

volvement of local communities (in particular

where such parties wish to ensure the quality

of information that they are receiving – de-

manding a role in site monitoring and access

to information to ensure accountability of op-

erator and governments are examples);

ensuring that communication exists between

private and public bodies to improve closure

policy and regulations;

ongoing searches for financing measures for

clean-up; disaster response; spills manage-

ment and so forth, particularly for orphaned

sites.

In closing, it is necessary to underline that it is the

role of government (as the representative of stake-

holders in the nation state) to ensure that the ex-

pectations of stakeholders are met. Further, it must

be noted that stakeholder expectations are inher-

ently fluid – and indeed that such expectations can

be influenced, and perhaps should be where they

do not best reflect the interests of all.

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