Critical analysis and mine closure: why do things still go wrong in a swirl of feasibility, regulation and planning?

Abstract

Mine closure planning is attended by increasingly more comprehensive regulatory, technical, corporate and financial planning requirements. However, in some parts of the mining sector in Australia, there are very significant areas of mining disturbance that clearly cannot be relinquished. Further, proposals in the process of approval do not suggest that many of the new developments in these areas will perform significantly better. This paper investigates how this can continue to be the case, when increasing focus continues to be applied to mine closure. Although some of the contributing factors discussed are technical, such as climatic, chemical and physical conditions, modelling and design, several are more centred on corporate, organisational, regulatory and essentially human attributes. These factors frequently involve obstacles to critical analysis that make mine closure predisposed to a failure to meet closure expectations and commitments. These contributing factors are often largely ignored in the processes attendant to understanding long-term mining liability during due diligence, feasibility, approvals, operations and the closure phase. Identifying instances where a number of such factors may be present can indicate that some risks may not be captured in technical risk assessments. In addition to detailing several of the contributing factors which can lead to a failure of mine closure or mine closure planning, this paper proposes mitigating responses for each of the contributing factors presented and expands upon responses which have the greatest probability of being adopted.  Stakeholders disappointed in a reasonable expectation or failure to fulfil commitments to the standards indicated at project approval. https://papers.acg.uwa.edu.au/p/1208_05_Haymont/ Critical analysis and mine closure: why do things still go wrong in a swirl of feasibility, R. Haymont regulation and planning?

Does the integration of enviromental impact assessment and mine closure planning deliver effective mine closure plans in Western Australia?

“…One of the key drivers for the development of early closure plans and evaluation of financial assurances is the risk of early or unexpected mine closure (Haymont 2012;ICMM 2019). However, this wasn't raised in the interview discussions and may be a reflection of the positive mining outlook in the context of improved economic conditions following the mining downturn.…”

“…Otto 1997;Sánchez et al 2014;Morrison-Saunders et al 2016). Both involve the evaluation of dynamic natural processes which are often complex with poorly understood interrelationships and often limited baseline data for greenfield proposals, with an assessment process that takes place in a typically convoluted regulatory setting involving multiple stakeholders and individuals (Haymont 2012; Environment and Communications References Committee 2019). Both are intended to commence as early as possible and continue throughout the lifecycle, employ adaptive management to maximise performance in unpredictable environments, and support sustainable development (International Association for Impact Assessment [IAIA] Transparency is important for accountability and to allow external evaluation of the validity of process and provision (Morrison-Saunders & Bailey 2000;McHenry et al 2015;Environment and Communications References Committee 2019).…”

Closure IS change. Change takes time and needs support. It's a smouldering fuse, not a 'burning platform'

“…Having abundant time to define and redefine a vision as knowledge improves should be an advantage, but all too frequently, the activities needed to plan, design and execute a closure vision are deferred. Common explanations include that there is plenty of time for closure tasks later because closure happens after production ceases, the time value of money makes closure costs more appealing when scheduled later, and short term production targets take priority, as without revenue who will pay for closure (Dowd & Slight 2006;Haymont 2012)? Systemic short-termism erodes any time advantage there may have been for closure and even worse, can increase a company's closure risk and liabilities by constraining opportunities, failing to obtain a shared vision, and failing to test and validate closure assumptions while the people and resources are available (Mackenzie et al 2006).…”