The Environmental Management Plan and closure planning

The Environmental Management Plan and closure planning

During 2009, SRK Johannesburg completed a number of environmental compliance audits as part of due-diligence exercises. These reviews showed that closure planning is frequently limited to strategies presented in an Environmental Management Plan (EMP). These EMPs are generally prepared during authorisation, years before mining and decades before closure. Once developed, these plans are seldom revisited for appropriateness. In SRK’s experience, closure requirements tend to focus on returning the site to some land capability that existed before mining. This strategy tends to mitigate most environmental impacts; however, very costly remedial measures are often required to achieve the objective.

As a result, mining operations that must make provisions for closure to the authorities annually, sequester capital until closure that could be used for other environmental or social purposes. Conversely, if the EMP is inadequate or outdated, significant unaddressed liabilities could arise.

If closure considerations were integrated into the process, and some closure activities undertaken during the operation, the liabilities deferred to the end of the operation could be reduced substantially and significant cost savings realised, for instance, by identifying alternative land use and land capability options and planning for them accordingly. While the post mining land capability may not be the same as the option envisioned pre-mining, it may still reduce impacts to an acceptable level.

Involving communities in closure planning is important to this process. Affected communities, left with the legacy of the mining operations, may miss potential land use that offers some economic return and is likely to be more sustainable. Planning closure early in the mine’s life cycle and revisiting it regularly can potentially reduce social dependencies on mining, while economic realities, properly assessed and analysed, may not have been adequately addressed or even understood when the EMP was being developed.

James Lake: jlake@srk.co.za

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