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Environmental rehabilitation and mine closure

Exciting changes in environmental policy for mine rehabilitation and closure are emerging,
and AusIMM members are making an impact.

Since time immemorial miners have rehabilitated their mine sites to a varying degree of success,
and with varying degrees of commitment to achieving good outcomes.
The degree to which mine sites have been rehabilitated depended on a distillation or integration of
the following perspectives:

Each companys perception of its place in the community/district/region/world.

The companys willingness to invest in environmental outcomes and community benefit,


when weighed against the financial burden that effective rehabilitation may require.

The legislative framework and conditions particular to a mine, and the willingness of
regulators to ensure those conditions are met.

The expectations of governments and the community including sometimes the


effectiveness of local community and environmental groups in applying pressure for good
environmental outcomes.

The efficacy and success of the available rehabilitation technologies and the availability of
appropriately skilled people to lead rehabilitation works.

In some regions/societies these perspectives have come together in relative harmony, and we
certainly have examples of effective mine closure and rehabilitation. In other cases poor outcomes
are achieved, and this can leave an unacceptable legacy for the local community, the environment
and for the mining company(ies) in question. With far too many abandoned mine sites that have not
been properly rehabilitated, this is a huge legacy issue in Australia and around the world.
Mine closure including effective environmental rehabilitation on the site of closed mines has
been the subject of debate, controversy and professional practice for many years. It is a topic of
increasing importance as the legacy of poorly closed mines seriously erodes community confidence
in the mining industry. Anything less than best practice in closure leaves a legacy of a weak social
licence to operate for the mining industry of today and the future.
The subject of mine closure is addressed in two extremely authoritative publications:
1. The Australian Government publication Mine Closure and Completion Handbook.
2. The International Council on Mining & Metals (ICMM) Planning for Integrated Mine Closure:
Toolkit.
Closure planning and management is widely acknowledged as a very challenging part of the lifecycle of mining operations. As the ICMM (2008) says: The risks and opportunities that define the

paths to closure are many and varied, and a disciplined, knowledgeable approach to closure
planning is required to successfully negotiate these paths.

What is AusIMMs contribution to this debate?

As the leading Institute for all minerals professionals, the AusIMM has a great interest in best
practice environmental rehabilitation and mine closure. Many AusIMM members are specialised in
these issues, and many more of us will be involved with planning and delivering a closure strategy
during our careers.
Debate and the sharing of experiences in mine closure work are key ways in which the AusIMM can
contribute to the development and sharing of successful and cost-effectivemine closure strategies.
The Institute also has a key role to play in contributing to government policies on environmental
management for the minerals sector including mine closure issues.
The AusIMMs Community and Environment Society has been working on these issues for some
time, and in June 2013 the AusIMM Board adopted an Institute policy statement on Abandoned
Mines issues (see box).

The AusIMM encourages debate and the celebration of best practice. Closure issues have been
discussed at a range of AusIMM conferences especially the two Life-of-Mine conferences held in
2012 and 2014. These issues have also been the subject of many Bulletin articles over the years.
Just one example is the article by Paulka and Waggitt (2013) reviewing the Nabarlek uranium mine
experience.
In the last year the Institute made positive contributions to the development of new Mine Closure
guidelines being developed by the Government of Western Australia. As a Perth-based professional

with a strong interest in responsible mine closure, I have been lucky enough to be closely involved
in many of those discussions and policy debates, and I think we are seeing promising changes in
thinking and practice.

Developing Government views with a WA focus


During 2013 and 2014 I believe we have witnessed a watershed period where a reality check has
been applied to reviewing the mining industrys and governments experiences in mine closure. As a
result we are now seeing some significant redesign of closure conditions and expectations.
In some regions of Australia there have been cases where the efficacy of rehabilitation has not met
the requirements set by the regulator and agreed to by the company. Contemporary practice in the
Pilbara is a case in point. The 2012-13 Annual Report of the Environmental Protection Authority of
Western Australia make sobering reading. That reports comments include:
Without confidence that rehabilitation can successfully restore comparable ecological function postdisturbance at a large scale, rehabilitation alone has limited value as a mitigation option for
reducing proposal impact. Until there is greater confidence, alternative steps within the mitigation
hierarchy (avoid, minimise, reduce, offset) in addition to rehabilitation may be more relevant to
reduce proposal impact during EIA. (Government of Western Australia, 2013, p 27).
Importantly this is not just the view of one regulator. These comments align with the analysis by
Glenn et al (2014), who commented, we argue that the expectations of rehabilitation outcomes are
sometimes unrealistic, with agreements (albeit in good faith) between proponents and the regulator
that aspire for closure outcomes that are unlikely to be achieved.
I provided a copy of the Bulletin article by Glenn et al to the Chair of the Environmental Protection
Authority of Western Australia, and was most impressed when he cited the article in a presentation
he gave on mine closure challenges on 10 June 2014.
Thinking on these issues by the Government of Western Australia has been evolving rapidly.
Throughout 2014 a process to develop new Mine Closure Guidelines has been underway, and the
AusIMM has actively contributed. The Environmental Protection Authority has continued to debate
and discuss the issues, and their 2013-14 Annual Report notes the challenges of effective mine
closure and emphasises the importance of early planning for effective closure: The EPA recognises
that it may be difficult to restore ecological function within a development footprint, particularly for
large scale mines and that a net environmental benefit may be achieved by applying resources to a
wider landscape scale. The EPA encourages companies to discuss options early with regulators, as
part of the mine closure planning process. (Government of Western Australia 2014a, p 32).

Landscape-scale approaches

The element of the current debate that I am most interested in is the potential to shift from a site-bysite closure focus to landscape-scale approaches to achieving the desired environmental and

community outcomes. The quote above illustrates a shift in thinking by the environmental regulator
of Western Australia that presents some exciting opportunities to achieve better environmental and
community outcomes and lower costs.
Like the WA Environmental Protection Authority, I think the vast majority of mining companies and
minerals professionals are interested in getting the best possible environmental and community
outcome from every dollar spent on closure and environmental rehabilitation.
In pursuing landscape-scale approaches, there is a risk that some in the community may perceive a
negative motivation to avoid making former mine sites safe for the community and the environment.
This is certainly not the case: closed mine sites must be safe and become areas that add to the
regional ecosystem. But a requirement to bring that site back to a fully functional mirror of the
surrounding ecosystem may not be a realistic objective, and we inevitably face diminishing marginal
returns on money spent on trying to achieve that outcome.
I believe that in many cases a better outcome will be achieved through investing in providing postclosure environment where the mine once operated that is safe for the community, has no adverse
impacts on the surrounding environment, and that supports healthy indigenous flora and fauna
communities even if not at the same level of biodiversity of the entire region. I argue that in taking
this approach, we can plan to invest in efficient on site rehabilitation and set aside additional
resources to protect and enhance the regional environment so that the net outcome is an
environmental gain at the landscape-scale.
This approach will no doubt continue to be debated for many years to come, but I hope that with the
support of regulators and local communities, the mining companies and we minerals professionals
are supported to explore these approaches and the potential win-win of better environmental
outcomes for the local community at the same or less cost.

Pooled approaches to avoiding abandoned mines in the future

As a side-issue to my focus on mine closure approaches in this article, I also want to comment
briefly on the recently changed approach to avoiding abandoned mines in Western Australia.
Like many jurisdictions, the Government of Western Australia used to require companies holding
mining rights to provide financial bonds as security to ensure their environmental obligations were
fulfilled. This process was intended to ensure that if the company did not rehabilitate the site as
required by the regulator, then the government could access the bonds to fund that rehabilitation.
This process is very simple in theory, but around the world the experience has been that bonds
have often been set at levels that are inadequate to fund the necessary rehabilitation when a mining
site is abandoned by the responsible company.
After much discussion and consultation, the Western Australian Government put in place a new
approach in the form of the Mining Rehabilitation Fund (Government of Western Australia, 2014b).

The Mining Rehabilitation Fund provides a pooled fund that is managed by the State Government.
Mining companies are levied according to the environmental disturbance existing on a mining
tenement each year. The monies held in the Mining Rehabilitation Fund will be used to finance
rehabilitation where a company abandons a site and the government is unable to ensure the
desired outcome of that company taking responsibility for its own closure and rehabilitation
obligations.
The fund will also enhance the State Governments capacity to manage and rehabilitate abandoned
mines across Western Australia. This is a positive approach to dealing with the significant legacy
issues of abandoned mines and will deliver better environmental and community safety outcomes.
The Mining Rehabilitation Fund is I believe another positive example of thinking at a broader scale
to find a solution that achieves better outcomes for the community and the environment while
minimising the costs of achieving those outcomes.

Conclusion

I hope that this article has given you some issues to contemplate about the role of the AusIMM in
mine closure practice and the approaches that we might advocate for as minerals professionals.
These approaches also open up many avenues for minerals professionals to explore innovative
new options to get better outcomes at lower cost, and I think that is very exciting. I look forward to
seeing a continuing discussion of these issues into the future.

References

Glenn, Vanessa; Doley, David; Unger, Corinne; McCarffrey, Nic; McKenna, Phill; Gillespie, Melina;
and Williams, Elizabeth in The AusIMM Bulletin June 2014, Mined land rehabilitation is there a
gap between regulatory guidance and successful relinquishment?
Government of Australia 2006, Mine Closure and Completion, from the Leading practice sustainable
development program for the mining industry publication series.
Government of Western Australia 2013, Environmental Protection Authority Annual Report 2012-13.
Government of Western Australia 2014a, Environmental Protection Authority Annual Report 201314.
Government of Western Australia 2014b, Department of Mines and Petroleum, Mining
Rehabilitation Fund Fact Sheet May 2014.
International Council on Mining and Metals 2008, Planning for Integrated Mine Closure: Toolkit.

MCMPR (Ministerial Council on Mineral and Petroleum Resources) and MCA (Minerals Council of
Australia) 2010, Strategic Framework for Managing Abandoned Mines in the Minerals Industry.
Paulka, Sharon and Waggitt, Peter in The AusIMM Bulletin June 2013, Nabarlek The history of a
modern uranium mine.