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Closing in on mine closure…from compliance to strategy

By: Dr Christine Vivier, Head of Ukwazi’s Sustainable Mining Practice

In mining, “implement like hell” means making chasing production and making sure each operation meets their quarterly production targets. Consequently, outputs and outcomes tend to matter more than process, strategy or stakeholders. At the same time, the global mining industry is currently being challenged by the need to implement sustainability requirements, while simultaneously being competitive, innovative and reducing environmental impacts. The social license to operate has become increasingly central to governance models, operations, and strategic direction. How can the sector balance all of these elements and still responsibly drive growth?

According to a pre-COVID-19 mining company survey, conducted by Ernest & Young (September 2019), which sampled more than 250 mining companies globally, 44% of respondents stated that the social license to operate was the number one risk they were most worried about. Interestingly, the 2020 Responsible Mining Index (July,2020) which looked at more than 900 mining sites globally amongst 37 major mining companies, also cites the trust deficit with affected communities as the main concern for industry players. This speaks to the fact that equating shareholders with stakeholders, and managing the tensions inherent in this dynamic, is both conceptually and operationally difficult. This tension also manifests itself most visibly when it comes to mine closure.

Rethinking and re-evaluating

Recently, increased regulatory requirements, particularly in South Africa via GNR 1147, which outline the financial provisioning required for closure and public pressure have encouraged mining companies to pay closer attention to mine closure issues.

New frameworks have also prompted these businesses to integrate closure planning into the project feasibility stage, reaffirming their ongoing commitment to rehabilitation and adherence to approval processes. Ultimately, mine closure planning should be an intrinsic element of the entire project life cycle from conceptualisation, implementation, closure, and post closure.

In response to the Sanmarco tailings dam disaster in Brazil in November 2015, the International Council on Metals and Mining (ICMM) published its own guidelines on integrated mine closure. Stipulations suggest that planning should be more iterative in nature and more inclusive of relevant stakeholders. This, of course, requires a clearer and more nuanced definition of rehabilitation and progressive closure as well as post-closure land use. On 5 August 2020, new standards for tailings facilities management will be published in London by the ICMM. Companies will also have to subscribe to these standards in order to join the organisation and must conduct a “human due diligence” and consultation process with interested and affected communities or individual stakeholders who could be affected by the risks of tailings dam failures.

Reconfigure and reconnect

In practice, however, closure planning and consistent compliance with legislation is often overlooked within operational management decision-making processes. In all fairness and in South Africa, the implementation date for closure regulations has been postponed several times and is now set to take effect 19 June 2021.

Additionally, it is common for closure planning to be left behind when other disciplines are in action. This is mainly due to the engineering complexities of incorporating rehabilitation within core mine planning, and the lack of integration between environmental considerations and these strategies. During the design stage of mining projects, complexities are usually managed by solving each component separately using subject matter experts, and then assembling the project from the bottom-up. Hence, the various processes are poorly interconnected, with extensive focus being placed on cost and technical, drivers.

How do we create a better closure for a better tomorrow?

Improved closure outcomes can be achieved by linking people, processes and technology in a systematic way that captures mine closure planning, and by making it an intrinsic part of management operating systems. Given the advances in software, mine planners now can look at the whole operation within one model to determine the true costs of operations, resulting in a practical and compliant closure solution. It also enables the ability to analyse plans in more detail and to make better decisions to fulfil the final agreed post-mining landform use.

Approaches have shifted from a static closure concept to a life-of-mine process. The key components? Progressive and concurrent rehabilitation, in collaboration with stakeholders, and an emphasis on post-closure land use that facilitates economic activity and community development. Not only do we need to change the lexicon and narrative from the concept of mine closure to one of mine transformation, but more importantly, we need to move from compliance to strategy: this provides new opportunities to ease the transition for affected communities, and contribute to securing resilient future livelihoods.

Reflect, revive and reshape

Mine closure should not be viewed as a problem but rather as a natural conclusion to mining and as a catalyst for creative solutions for post-mined landscapes. This could range from transforming land into a tourist destination for skiing like Teck Resources did in a town called Kimberley in Canada or donating revegetated forest land in Indonesia by Newmont or we can draw inspiration for “101 Things to do with a Hole in the Ground” by Georgina Pearman (2009) who examines a range of innovative case studies.

In order to navigate a drastically different operating environment, mining companies can pick a strategy, including a closure plan, and implement the hell out of it – but it needs to be relevant to the context and to stakeholders. What is more, they need to find a sustainability partner that can execute on both strategy and compliance, underpinned by value engineering, clear objectives, measurable outcomes and solutionist thinking.

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