Mine Closure Plan as a guide to Mining Companies – from a Governments’ Policy Perspective

By Ignatius Kamwanje

Mine closure plans are difficult to evaluate without a broader or more strategic perspective. There are many challenges that if mine closure plan is not put in place, there will be impacts that will negatively affect the physical environment.

The reason for closure plans would be to address the cumulative impacts from mines. The key environmental issues of groundwater, surface water, dust, and mine residue deposits are very important and need to be dealt with caution.

1. Steps involved (Policy perspective)

(a)  Formation of a Task Force

It is of paramount importance to establish a governmental task force to lead the development of the mine closure policy. The development of policy will need to take into account the interactions of development goals, existing legal structures, and the interactions between different branches of government. A governmental task force with adequate resources is needed to develop policy and policy updates. A relatively small group of individuals is practical for spearheading the development or assessment of policy where members can represent key ministries, departments, and agencies central to the management of the mining sector. Consideration should also be given to representing areas such as mining, finance, environment, and land use planning bodies, as well as incorporating gender balance. While the number of task force members should be limited for efficiency purposes, it should consult widely with other groups to ensure that a variety of viewpoints are considered. A stakeholder closure forum can also be established to facilitate consultations.

(b) Understanding the Role of Closure Policy

 This aims at ensuring that task force members have a clear and consistent understanding of the roles and limitations of closure policy. Where there is closure legislation, it is expected that the mining company should develop a closure plan. The closure plan should be legally binding and must outline in detail issues to be addressed. At a minimum, the closure plan describes the activities that will be undertaken at the end of mine life, the plan for the site after closure, and the cost of the activities.

There is no universally accepted understanding of what is needed for mine closure and what aspects of closure should be addressed by regulations.

(c) Understanding Closure in the Mining Life Cycle

Understanding ensures the role of mine closure throughout the mining life cycle and the implications for policy. Mine closure policy must ensure that closure planning begins early in project development. Early planning allows flexibility in closure options, resulting in better outcomes. It also enhances the ability of operators to carry out and pay for closure measures during operation while there is positive cash flow to support the activities. Good policy recognizes that planning is an ongoing process, and that plans should be revised on a regular basis, incorporating changes in the project. As more knowledge is gained about risks for closure, and better understanding on how those risks can be managed, the level of detail in the closure plan should increase.

(i)  Policy Implications

  • Regulations must ensure that all mines have a closure plan developed prior to construction.
  •  The earliest closure plans will be conceptual, but should be well thought out and subject to careful preparation and review by experienced experts and approval by the competent regulatory authority.
  • There should be a process in place to ensure that closure plans are updated regularly and oftenly, especially when there are major changes in the mining project.
  • While the level of detail in the plan should be required to increase over the mine life, the plan will usually be largely conceptual (in engineering terms) until a period 5 or more before closure. Care should be taken to avoid policy that specifies too much detail for the closure plan.

(d) Assessing Current Policy and Identify Gaps

The first step in developing mine closure policy, or improving current policy, is understanding where jurisdiction is in relation to best practices. The area that requires most attention is to use the Scorecard. A scorecard can be used as a self-evaluation tool to assess current policy and look for gaps. This scorecard provides a quick way to assess the status of closure policy and relative to the best practices identified. It also tries to help identify the areas that need more attention. The checklist provides practical guidance on policy needs for addressing identified gaps. A scorecard can be used to determine which sections of the document need guidance or to consult for additional supporting information.

(e) Identifying and Engaging with Stakeholders and Partners

 Prior to developing closure policy, it is critical to identify key stakeholders and engage with them in policy development. If a mine closure policy task force has been established, it is ideally suited to identifying and engaging with stakeholders and potential partners. Stakeholders may include community groups, NGOs, mining companies with interests in mining, indigenous people, workers unions, and representatives of other government departments that have an interest in closure policy. Partners are individuals or organizations that may not have a specific stake in the mine closure policy, but can offer useful support to the development of the policy. Typical examples include regulators, international development organizations, consulting companies working internationally in mine closure and CSOs. There are other organizations that may be able to provide specialist input on key technical issues affecting closure. For developing economies some international development organizations have the potential to bring significant support to the government in the development and implementation of mine closure policy.

2. Mine Closure Plan- Developing policy for a closure plan  

This seeks to identify the policy needs that will be addressed through the development of a closure plan, including background on the technical specifications that should be addressed

The closure plan:

  • provides clear documentation of the results of a planning process, which is guided by government policy.
  • must be in place for closing and reclaiming completed mines to meet the objectives of regulators, mining companies, and other key stakeholders.
  • It provides an overview of the needs and content for the closure plan, in the context of mine closure policy development.

The mine closure policy in this case directs the development of explicit objectives based on the vision of the next land use once mining is completed.

  • It should explicitly deal with the issue of plan updating; this is often done on an as-needed basis, where material changes occur. The actual writing of a closure plan should meet regulatory obligations and prepared in such a way as to address company standards and/or financier requirements, although if these differ significantly from regulatory requirements, the mining company may need to develop a separate document to address divergent needs.

(a) The Structure of  Mine Closure Plan

The closure plan as a document does not exist in isolation. In the development of the mine closure policy, the plan should align with other commitments such as Environmental and Social Impact Assessment (ESIA). The regulator should also be aware of the broader context into which the closure plan fits, such as local councils, strategies, plans, including national sustainable development or socioeconomic targets.

 The required structure and contents of a closure plan should be fit for the context and purpose of the mine in question and the stage of mining. Largely, conceptual closure planning can exist at the early planning stages of the project, although these concepts should have sufficient depth to allow adequate evaluation of their suitability. Conceptual design should not be taken as an excuse for failing to address fundamental technical issues. For example, much of the baseline information that may be relevant for closure planning may be available in ESIA studies conducted for the project. Provided these reports are publicly available, they can be referenced rather than included in the plan.  For ease of review, it is advisable to have a clearly defined guideline for the required organization of the closure plan. This helps to ensure that all needed elements are included and presented in a form that is easy for the reviewer to follow.

(b) Evaluating Technical Content

 A good closure plan provides a realistic approach to implementing closure of a mine site in a way that will minimize adverse effects to the public and environment. Ideally, at the earliest stages of mine design, the closure needs have been taken into account, such that the facility has been designed for closure. Approving a closure plan requires considerable knowledge of closure practices over a range of technical disciplines. After submission, the closure plan must be reviewed by the authorities and either approved or returned to the proponent for additional information.  The most important technical aspects for detailed inclusion are hydrogeology, water treatment, geotechnical engineering, sociology, construction, mine design, cost estimation, surface water management, environmental management, demolition, geochemistry, data management.

3. Post closure land use

Post-closure land use is the single most important decision in developing a closure plan, as all closure and reclamation activities will be defined based on the next use of the land. With the evolution of modern concepts around sustainable development, it may not be sufficient to simply attempt to return the land to the pre-mining conditions. Therefore, care should be taken to avoid simplistic policy. Policy should promote a focus on post-closure land use that starts in the early planning stage of the mine and continues through operation as part of a dynamic closure plan that captures regulatory constraints, community input, economic aspects, and needs for post-mining stewardship.

For policy guidance on post-closure land use, the following aspects need to be considered, developed in line with the goals and aspirations;

  • .traditional land use and community expectations
  •  remediation measures and reclamation objectives
  • geomorphic landform design
  • environmental stewardship and ecosystems biodiversity
  •  preventing or minimizing off site impacts to water or air quality
  • protection of health and safety of the public and future users
  •  land tenure ( land ownership after the mine closure)
  •  Any other  relinquishment aspects

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