Best practice mine closure planning and environmental impact assessment (EIA) principles share many common features. This research examined how mine closure planning relates to, and can be integrated with EIA by comparing practice in eight African and Australian jurisdictions. Emphasis was placed on key challenges and opportunities associated with: institutional arrangements for mine closure planning; financial mechanisms for mine-site closure and rehabilitation including abandoned/legacy mine-sites; transparency of mine closure planning and financing provisions; and regulation of artisanal and small-scale mining activity. Data was gathered through document analysis, interviews and interactions with practitioners from Western Australia, Ghana, Kenya, Nigeria, Mozambique, South Africa, Tanzania, and Zambia. Issues associated with mine closure planning and rehabilitation under existing arrangements, and opportunities for improvement through existing EIA processes already in place in each jurisdiction are explored. All eight jurisdictions have appropriate regulatory provisions in place already, but implementation capacity remains a challenge. Opportunities for effective practice lie in using mine closure planning and EIA measures in an integrated fashion, avoiding duplication and enabling synergies in management to be realized.

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Available online xxx Keywords:Artisanal and small-scale mining (ASM) Environmental Impact Assessment (EIA) Mine closure South Africa A B S T R A C TThis review considers the potential to better plan for artisanal and small-scale mining (ASM) during the Environmental Impact Assessment (EIA) phase of new major mine developments. We contrast and contextualise the parallel development of comprehensive mine closure regulation in South Africa with the resultant lack of progress in actual rehabilitation of its large and growing negative mining legacy. We discuss socio-economic conditions around the mine and the current tendency/flaw in governance that ignores the extensive ASM activities that exist. The ramifications of omitting the known large cumulative impact of ASM compromises efforts to undertake large-scale mine closure effectively both in theory and practice. This leaves some large-scale mine rehabilitation and closure plans unachievable due to cessation attracting ASM activity, consequently 're-opening' the mine. We discuss the EIA process as an existing legal mechanism to generate wider consultation for post-mine ASM activity options, and to formally recognise and incorporate ASM as a known impact to plan for. Governance obligations for mining companies and policymakers should directly cater for ASM, with the focus directed towards mitigating negative consequences and maximising local socio-economic development benefits that the sector can create, managed through EIA processes.

This viewpoint article was written in response to our attempt to explore mechanisms that promote financial 'transparency' in the minerals and energy extractives. We controversially forward our opinion that the trajectory of existing transparency mechanisms is likely to generate an obfuscating mass of disclosed information -not 'transparency'. Using a jigsaw analogy, we make a distinction between 'disclosure' and achieving the more challenging 'transparency': it is both being able to have the pieces (disclosure), and put them together to see the big picture. It is just as important to identify missing pieces of the puzzle to prevent selective disclosure. We critically analyse extractives financial policy, and provide an example where a 'best practice' mining securities policy has markedly advanced transparency in a major mining state. The policy substantially reduces government financial risk of a mining company default at no additional cost; reduces costs to industry around ten-fold; incentivises ongoing site rehabilitation; creates a fund for historical abandonments; and; sustains an impressive publically available information instrument of disturbed footprints and associated rehabilitation for every tenement at high precision on an annual basis. Yet, it still remains deficient in terms of transparency in particular aspects, of which we clarify and discuss."A lot of people never use their initiative because no-one told them to." -Banksy

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