The draft National Mine Closure strategy 2021 has recently been published for comment. Comment to be submitted to the DMRE by 23rd July 2021.
The draft strategy initially highlights the adverse impacts of mining, more so the irreversible environmental degradation and economic hardship when a mine closes. The importance of the Environmental Management Plans (EMPr), and how these should speak to post-mining impact management are also highlighted. The strategy also recognises the holistic problems and challenges of cumulative impacts on society, health, safety and environmental impacts. It describes how one mine closure might impact on another operational mine in the same area. In essence, the strategy comprehensively documents the integrated nature of post-mining impacts at environmental and socioeconomic levels.
The department seeks to find sustainable closure of mines, linked to what we interpret as clear Post-Mining Land Uses (PMLU’s). It is referred to in the draft strategy as seeking to establish life beyond the mining project. This notion is further explained in the strategy as concurrent economic diversification, looking beyond the non-renewable resource and seeking long-term solutions. The draft strategy recognises, and later lists, geographical areas where clusters of mines are located. These are considered focal areas.
This draft strategy document is positioned well within the current, yet evolving, mine closure legislative guidelines and regulations. Specifically sighting the promulgated financial provision regulations, the guidelines for mine closure contained in the MPRDA, the EIA Regulations and guidelines in the NWA with cognisance to international standard presented by amongst other the ICMM and IFC. The risk-based annual and final closure plans of mining companies, as required by the financial provision regulations, could in future be contextualized by the Regional Mine Closure Strategies (RMCS) as eluded to in the draft strategy.
The problem statement explained in the draft strategy is general and covers the key issues of water pollution, air quality, land degradation and socioeconomic impacts. It is however detailed more in the appendixes. Of interest is how the draft strategy mentions the risk of unilateral closure decisions, and how this could spill over into risk transfers to neighbouring mines – presumably in a cluster. The strategy in various ways speaks of several government departments and statutes and as such makes space for all the SEMA requirements. Again notable is that the responsibility to State, in other references possibly referred to as liability to State, is also not excluded in the contextual text.
The draft strategy aims to, at a high level, define the aim of mine closure and positions the RMCS’s as a reference which might set the specific closure standards for mines in a specific cluster or region to promote closure alignment. It is shown that the RMCS, which is understood to be subjected to a National Mine Closure Strategy (NMCS), will also guide the requirements for; closure application process, inclusions to the EMPr’s as well as financial provisions. The inter alignment of Mine specific closure plans and the RMCS’s are discussed well and in Section 3.2 of the draft strategy are summarised as objectives of the draft strategy. Of standout importance in these objectives would be the concepts of; “demarcated areas”, “mine working together”, “ self-sustaining ecosystems”, “no negative impact on adjacent mines”, “ strategic water management”, “post closure water management strategy for an area”, “post closure provisions”, “post closure stewardship” and “integration environmental and social management plans”.
The draft strategy further describes the focus areas of the NMCS, which includes a regional approach to mine closure, collaborative governance and the identification of mine closure regions drafted already in the draft strategy as a figure proposing Mining clusters. The draft strategy also includes a section on an implementation plan, based on the concept of economic succession planning seeking a method for mines to leverage greater economic benefits during operational stages. The implementation plan further eludes to the importance of economic benchmarking, as such that the mines are individually responsible for formulating their own synergistic strategies for land use and post mining economic needs – presumably with cognisance of the RMCS requirements. It is also clear that the strategy underpins the idea of a diverse post mining economy, potentially to involve the community and various land capabilities as a whole whilst the integration of socioeconomic activities in the closure plans are also highlighted as required focus points tailored for every type of mine and its context.
The recommendations of the draft strategy provides some insight as to what the potential practical effect and/or impact of the strategy might have on the industry. Such that EMPr’s and associated documents might need to undergo further integration with closure strategies. Also that closure plans might need to consider further external aspects and impacts, not to plan unilaterally and in isolation. What stands out in the recommendations is that of a regional mine closure fund, which might be unchartered in many ways. Other recommendations include the development of mine closure policies and specifics around how a mine under care and maintenance should be subjected to the draft closure strategy and its intention.
The Draft strategy concludes with a series of reference tables and figures in which regionality and categorisation of mines or clusters of mines is used to set what is interpretated as strategic KPI’s. In these it is clear that the intention to create common focus points in specific regions amongst mines remains central to the draft strategy’s aim and that the environmental and socioeconomic realms remain central to a sustainable outcome. It also seems that the draft strategy emphasizes a long term relationship between mining, its cessation and the most likely long term outcomes linked to pastural and/or farming lands.
In summary, the strategy does impose a series of challenges, and could when considering the various notions of alignment, clustering and regional integration bring about a rather intensive administrative burden. However, there might be opportunity to be explored and that the principles embedded in the PMLU approach could improve and benefit the post-mining phases of mines. We will participate in the development of the draft strategy and hope to contribute through our own internal research as well as the experience gained on closure projects locally and internationally.
Environmental Assurance (Pty) Ltd. (“ENVASS”) has a wealth of mine closure knowledge and would be happy to assist with any queries or works that may be required of your company. Please feel free to contact us on 012 460 9768 or email email@example.com.
The draft mine closure strategy can be accessed from this link: https://www.gov.za/sites/default/files/gcis_document/202105/44607gen446.pdf