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Mine Closure 2014 – I.M. Weiersbye, A.B. Fourie, M. Tibbett and K. Mercer (eds)
© 2014 University of the Witwatersrand, Johannesburg, ISBN 978-0-620-62875-4
Mine Closure 2014, Sandton, South Africa | 1
Mine closure in South Africa: A survey of current
professional thinking and practice
M. Milaras Department of Geography, Environmental Management and Energy Studies, University of
Johannesburg, South Africa
F. Ahmed School of Geography, Archaeology and Environmental Studies, University of the
Witwatersrand, South Africa
T.J.M. McKay Department of Environmental Science, University of South Africa, Florida Campus, South
Africa
Abstract
There is a large body of literature aimed at directing mining towards positively contributing to sustainable
development. Much of this literature advocates frameworks and principles, which if abided to, should
ensure such a sustainable contribution, specifically with respect to mine closure. Despite this, achieving
sustainable mine closure remains a pressing legacy issue and world wide, mines continue to fall short of
addressing even predictable closure impacts. This is no different in South Africa. Mine closure is a serious
issue for the country, with no less than five thousand ownerless and abandoned mines, as well as, additional
ones on a ‘care and maintenance’ plan due to their inability to secure a government issued closure
certificate. This could be due to chronic residual environmental impacts. There appears, therefore, to be a
disconnect between policy and practice concerning mine closure. This study sought to understand the
reasons for this gap by exploring the experience of mine closure professionals in South Africa. The voices of
these stakeholders are seldom heard in the literature. A cost-effective electronic survey, using the snowball
method and a social professional network to recruit respondents, was undertaken. The survey identified
important challenges facing mine closure professionals. Importantly the survey was able to ascertain key
factors, which if addressed, could significantly improve the practice of mine closure, not only in South Africa,
but internationally.
Résumé
Il y a un vaste corpus de publications visant à diriger les mines vers une contribution positive au
développement durable. Une grande partie de cette littérature plaide en faveur de cadres et de principes,
qui, s’ils sont observés, devraient garantir une telle contribution durable, particulièrement en ce qui
concerne les fermetures de mine. Malgré cela, la réalisation durable d’une fermeture de mine reste un
problème hérité urgent, dans le monde entier, les mines continuant à ne pas être en mesure de répondre
aux impacts même prévisibles d’une fermeture. Ce n’est pas différent en Afrique du Sud. Une fermeture de
mine est un problème grave pour le pays, avec pas moins de cinq mille mines sans propriétaires et
abandonnées, mais aussi, sans plan « d’attention et de maintenance » en raison de leur incapacité d’obtenir
un certificat de fermeture émis par le gouvernement. Cela pourrait être dû à des impacts environnementaux
résiduels chroniques. Il semble, par conséquent, qu’il y ait un écart entre les politiques et les pratiques à
l’égard de la fermeture d’une mine.
1 Introduction
Worldwide environmental discourse is dominated by the concept of Sustainable Development and this
includes attitudes towards mining (ICMM 2014). By its very nature, mining of a finite ore body is a
temporary land use (Robertson and Shaw 2006). Thus, upon reaching the end of viable economic
production, a mine needs to be ‘closed’. It is in this stage that the principles of sustainable development
come to the fore, as any residual negative impacts must be thoroughly ameliorated. Thus, sustainable mine
closure must positively contribute to the area. Crucially, future land use should not be compromised use
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
2 | Mine Closure 2014, Sandton, South Africa
(Limpitlaw et al 2005; Robertson and Shaw 2006; Heikkinen et al 2008; Vladimir and Tomislav 2012). Such
profound commitments make the management of mine closure a significant management problem for
governments, communities and mining companies alike. However:
“Despite on-going advances in mine site rehabilitation it is a fundamental reality that many types
of mining activity will effectively sterilize some of the land surface from virtually all other use.”
Worral et al. (2009)
Thus sustainable mine closure poses significant ethical challenges; and even challenges the very notion of
sustainable development. It may be that when viewed from the long term perspective and taking closure
into account, mining may be viewed as diametrically opposed to the tenet of sustainable development as
espoused by the Brundtland report:
“meeting the needs of the present without compromising the ability of future generations to meet
their own needs.” UNWCED (1987)
South Africa explicitly subscribes to the principles of sustainable development throughout its governance
framework; principally through sustainable development being enshrined in Section 24 of the South African
Constitution:
“24. Environment – Everyone has the right (a) to an environment that is not harmful to their
health or well-being; and (b) to have the environment protected, for the benefit of present and
future generations, through reasonable legislative and other measures that (i) prevent pollution
and ecological degradation; (ii) promote conservation; and (iii) secure ecologically sustainable
development and use of natural resources while promoting justifiable economic and social
development.” RSA (1996)
Accordingly, South Africa is committed, as exemplified in the Mineral and Petroleum Resources
Development Act (MPRDA) (DME 2002) and the National Environmental Management Act (NEMA) (DEAT
1998) amongst others, to addressing mine closure and its associated environmental consequences in a
manner which promotes sustainable development (DWAF 1999; UN 2002a; DEAT 2003; Danielson 2006;
DME 2007; DME 2008; DEA 2011).
As South Africa is a mineral rich country – with a long established and economically important mining
sector – it may be one of the best locations to test if sustainable mine closure, and thus sustainable
development is achievable in the mining context (Global Mining 2002; DEA 2010a, CoM 2011; Stats SA
2012). Historically, closure has been environmentally inept leaving lasting negative consequences. This is
made worse by the fact that South Africa has “in excess of five thousand ownerless and derelict mines”
(DME 2007, pp. 63). As these mines revert to the state when abandoned, it is estimated that the
environmental liability facing the state is at least R 30 billion for environmental restoration (Baartjes and
Gounden 2012). This excludes mines which are not functioning but are under varying levels of care and
maintenance, that is, they do not have final legal closure yet. On the whole, closed mines continue to
generate environmental hazards such as acid mine drainage (AMD), the associated mobilization of heavy
metals, decreased soil fertility, surface instability and airborne PM10 dust amongst others; and in some
cases this may be indefinitely. Closed mines also tend to obviate useful future land use to the detriment of
ecosystem functioning and human health and prosperity (Robertson and Shaw 2006). Making matters
worse is that in practice, mine closure is often poorly planned for, which may make environmental impacts
more severe.
To date, there is no published survey of the voices of professionals on the challenges facing sustainable
mine closure in South Africa. Thus, this study sought to close that gap. It also presents an innovative and
cost effective use of online survey tools. The study begins by discussing the design and administering of the
questionnaire. Thereafter the participants’ responses are given, along with a concurrent discussion and
interpretation of the results. From this, conclusions are drawn and recommendations made.
Socio-Ecological and Economic Aspects
Mine Closure 2014, Sandton, South Africa | 3
2 Methodology
This study sought to contribute to the understanding of the difficulties surrounding sustainable mine
closure in South Africa by establishing the challenges facing professionals working in the field of mine
closure. The research questions were:
1.
What is the nature of mine closure experience gained by respondents?
2.
What is the current status quo of environmental mine closure practices and environmental
indicators measured?
3.
What are the challenges and successes (best practices) in mine closure in South Africa?
For this study, it was deemed that these professionals responded with the breadth of their knowledge on
mine closure practices, rather than testing predetermined notions in this uncertain and complex applied
field. Thus the study opted for 19 open-ended questions. The work of Reja et al. (2003) and Choi and Pak
(2005) found that open-ended questions, despite generating more ‘missing data’ or inadequate answers,
allowed for a wider variety of answers (Gendall 1998). Due to the open ended nature of most of the survey
questions, the responses were interpreted by means of a qualitative narrative but included quantitative
analysis where possible. A web-based questionnaire was drawn up using a freely available web survey tool.
Various web-based survey platforms were assessed and the five best options were shortlisted, from which
one was selected (see Table 1).
The five instruments were weighed up by comparing the ease with which data could be interrogated. Due
to question and respondent limits, a lack of question piping and skip logic (required to administer the six
tailored questionnaires from one weblink), and the inability to export raw data to MS Excel three survey
instruments were excluded: SurveyMonkey, QuestionPro and SurveyGizmo. LimeSurvey is a very powerful
and customisable online survey tool. However it requires independent webhosting making it challenging to
implement. Google Forms was thus selected as the online survey tool as it met all the non-negotiable
requirements although it did not have the ability to automatically manage and track participants’
completion of the questionnaire.
The selection of respondents was confined to professionals with South African mine closure experience.
Respondents were recruited in three ways: (1) Professional networks; (2) Professional profiles on the
LinkedIn network (LinkedIn 2014) and (3) using the snowball technique of asking professionals for referrals.
Based on this, a database of 159 professionals was created and each was then contacted by email. The
questionnaire was piloted with six personal contacts; one from each professional niche sector. Their critical
feedback on the questions was then integrated into an improved final tailored questionnaire. In order to
increase the response rate introductory personalized email cover letters, telephone calls and follow-up
reminders were administered (Solomon 2001, in Archer 2007). Overall, each respondent was contacted five
times. After three unsuccessful follow-ups it was deemed the respondent was a non-responder. A total of
56 complete questionnaires were received, a response rate of 35 percent.
Six broad professional mine closure niche sectors were defined and the questionnaire tailored accordingly
in order to encourage “high quantity and quality of responses” (Dillman et al. 2009, p. 16). Tailoring the
questionnaire accordingly, produces better quality data, as well as increasing the likelihood of respondents
completing the questionnaire. Thus, the six niche professional sectors from which respondents were
selected were: (a) Mine-based – professionals who work for a mining company and are based at a mine; (b)
Office-based – professionals who work for a mining company but are based at a divisional or head office; (c)
Tertiary institutions – professionals employed as academics and conduct research into mine closure; (d)
Consultants – professionals who work for a consultancy firm which offers mine closure services to mining
companies; (e) Public service – professionals working for any level of government departments with their
remit including mine closure and (f) Legal – professionals with a legal background and advise mining
companies on legal matters pertaining to closure. The shortcomings of this study could be seen to be the
relatively low response rate and the consequent low number of total respondents. This may be attributable
to insufficient time available on the part of the professional respondents. However due to all respondents
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
4 | Mine Closure 2014, Sandton, South Africa
having a definite level of expertise in mine closure this was deemed as an acceptable shortcoming in the
context of South Africa as a skills scarce country.
Table 1 Evaluation of free web-based survey platforms
Web-platform Advantages Disadvantages
SurveyMonkey • Popular and easy to use
• 15 question types
• Basic themes
• Charts and basic statistics available
• Survey link and track responses can be sent
• Max 10 questions
• Max 100 responses
• Only online view of responses,
no export of data
• No skip logic and question piping
QuestionPro • Easy to use
• 15 question types
• Survey link and track responses can be sent
• Charts and basic statistics available
• Max 12 questions
• Max 100 responses
• Only online view, no export of
data
• No skip logic and question piping
SurveyGizmo • Easy to use
• Unlimited questions
• Can export to MS Excel
• Charts and basic statistics
• Basic themes
• Max 50 responses
• Only 8 question types
• No skip logic and question piping
• Cannot send survey link and
track responses using tool
LimeSurvey • Powerful customisation due to open-
source
• Unlimited questions and responses
• 28 question types
• Skip logic and question piping
• Survey link and track responses can be sent
• Export to MS Excel – associated
graphing/stats
• Open-source programme must
be mastered
• Requires deployment on a web-
server
Google Forms
• Unlimited questions and responses
• Skip logic and question piping
• Export to MS Excel – associated
graphing/stats
• Setup of questionnaire complex
• No charts or statistics
• No integrated response tracking
– manual response tracking only
• Only 7 question types
Note: The surveys can be found at: SurveyMonkey www.surveymonkey.com; QuestionPro www.questionpro.com; SurveyGizmo
www.surveygizmo.com; LimeSurvey www.limesurvey.org and Google Forms www.google.com/googled-s/createforms.html
3 Results and discussion
In this section aggregated responses from the questionnaire are collated and qualitatively described, with
quantitative details where possible. There are four main sections of results, namely, professional mine
closure experience (3.1), baseline environmental indicators (3.2), operational environmental indicators
(3.3), and challenges and successes of mine closure in South Africa (3.4 and 3.5). The questionnaire
Socio-Ecological and Economic Aspects
Mine Closure 2014, Sandton, South Africa | 5
questions are provided in Table 2. Each section details the results of the survey followed by a discussion of
these results.
Table 2 Questionnaire Questions
Section Questions
3.1 In which sector does your mine closure experience lie? (Limited to a choice of: Academic,
Consultancy, Corporate, Government, Legal, Mine site)
In which mineral/s does your mine closure experience lie?
Which ‘phases of’ and ‘projects relating to’ mine closure have you participated in?
3.2 In your experience, what baseline (pre-mining) environmental indicators exist at mining sites?
3.3 On closure projects, which environmental indicators do you find are the most commonly
measured?
On closure projects, which environmental indicators do you find to be most lacking?
3.4 From your experience, can you detail some challenges encountered in mine closure in South
Africa?
3.5 From your experience, can you detail some successes encountered in mine closure in South
Africa?
3.1. Professional mine closure experience
Respondents’ mine closure experience was categorised as being predominantly in one of six sectors,
namely: Academic, Consultancy, Corporate, Governmental, Legal and Mine Site. Figure 1 depicts the
percentage of respondents by each of these sectors. The vast majority of respondents, 70%, worked either
on a mine site or as consultants to mine site closure. If participants from the corporate (11%) and legal
sectors (5%) are added to this, it can be seen that 86% of mine closure professionals are employed in the
private sector. Respondents were further asked to list the minerals in which they had mine closure
experience. Figure 2 represents the percentage of participants who indicated that they had closure
experience in each specific mineral. If a respondent had experience in more than one mineral, each
individual mineral was counted as an instance of closure experience in that mineral. Coal (33%) and gold
(18%) made up almost half of the respondents’ mineral mine closure experience (see Figure 2). With the
addition of base metals (10%), platinum (9%) and diamonds (8%), almost 80% of the respondents’
experience was covered. That is to say that a variety of ancillary minerals, each accounting for 1% to 3%,
constituted the remaining 20%. Thus, South Africa’s major economic minerals (CoM 2011; Global Mining
2002) command the focus of most mine closure specialists. The majority of corporate and mine based
respondents had only ever been involved in the limited list of coal, gold, platinum, diamonds, base metals,
iron ore and vanadium operations. Consultants had a far broader range of experience (see Figure 2). Of the
few participants who work for government (7%), their mine closure experience was only indicated in coal,
gold and asbestos operations. Further to this, academic research involvement in mine closure only
extended to coal, gold and base metals. Although legal respondents commented that South African mine
closure legislation is not differentiated by mineral; again their experience was limited to coal, platinum and
iron ore.
The results suggest that the larger mining houses (which mine the major economic minerals) employ mine
closure expertise in-house. Minerals of lesser economic importance are dominated by smaller mining
houses. These mining houses are more likely to employ consultants to assess and manage their mine
closure responsibilities. This indicates perhaps a lack of small and junior miners’ capacity to properly
address the complex issue of sustainable mine closure which is likely to result in less comprehensive and
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
6 | Mine Closure 2014, Sandton, South Africa
robust mine closure. As consultants are usually engaged on a short-term, usually project specific basis, the
long-term closure management of smaller mines may not be addressed with the same level of consistency
and efficacy as the larger mining houses mining economically more important minerals. Considering that
the South African government needs to actively address and manage the entire range of mine closures, the
apparent dearth of expertise in this field is of great concern. The results suggest a lack of institutional
capacity in mine closure decision-making, compliance monitoring and enforcement as well as the support
of long-term studies on mine closure impacts and remediation.
Figure 1 Respondents by Sector (Percentage)
3.1.1 Experience by mineral type
Figure 2 Respondents’ closure experience by mineral (Percentage)
Socio-Ecological and Economic Aspects
Mine Closure 2014, Sandton, South Africa | 7
3.1.2 Breadth of closure project experience
In terms of the level and breadth of experience the mine closure professionals responded that they have
experience in: closure planning; auditing; costing; rehabilitation and water treatment and/or reclamation.
Consultants were found to have the broadest range of experience. Furthermore, consultants indicated the
most experience in drafting closure plans, conducting baseline assessments, as well as closure costing.
Respondents working on mines sites are mostly involved in the operational aspects of closure, while
government officials are predominantly involved in closure standards, regulation and monitoring. Only
respondents located on mines indicated that they interacted with government agencies regarding mine
closure applications. Respondents from the legal sector are confined to the legal activities regarding
closure. No other niche professions had any specific legal closure experience. Those working in the
academic sector included experience in drafting mine closure emergency response plans. Lastly, as a sector,
corporate experience was evidenced to be of a strategic nature as is consummate with their function. In
particular, few respondents indicated that they had experience in conducting baseline assessments, closure
studies and trials, post-mining monitoring and community engagement.
The data evidences a broad working practice of mine closure practitioners in South Africa; and while
although there are areas which appear to be lacking in attention, there are no striking omissions when
compared to the considerations of sustainable mining in international literature (MMSD 2002; UN 2002;
Miranda et al 2005; MCA 2005; IFC 2007; APEC 2010; IFC 2012; MAC 2012; IGF 2013; Equator Principles
2014). Such expertise is even perhaps to be expected in a country such as South Africa where a mature
mining and economic sector exists and sustainable development is integrated into national legislation. It is
clear that South African professionals spend a lot of time working on mine water treatment technologies as
a solution for the water issues associated with mine closure in South Africa. The broad range of consultant
experience indicates that mine closure may often be outsourced. It is possible that this is due to legislation
specifying that independent experts conduct certain studies such as EIA’s (Environmental Impact
Assessments) (DEA 2010b). The work of academics may indicate that many mine closure professions do not
make specific planning for emergencies. Overall, there seems to be little attention paid to long-term trials,
post-mining monitoring and rigorous community involvement in the mine closure process.
3.2 Baseline environmental indicators
The monitoring and measuring of specified environmental indicators is legally binding due to the manner in
which mining licences are administered by the Department of Mineral Resources (DMR). All mining licences
require an EIA and an Environmental Management Plan (EMP) (DME 2002). Thus to establish the current
operational environmental monitoring status quo in South Africa, respondents were asked what indicators
are measured at operating and/or closing mining projects they have worked on, as well as to which
indicators they have found to be most lacking. Most respondents indicated that the EIA process resulted in
the production of many baseline environmental indicators, especially for new mines. However most felt the
baseline studies and the subsequent EMPs were poorly conducted and the actual indicators were
inadequate. Specifically, indicators were often later revealed to be too few in breadth and detail to provide
the requisite scientifically robust post-mining goals to work towards. Part of the cause for this was that the
permitting process allows for too little time for conducting the necessary studies. That is, data collected is
often single-sample not longitudinal. Of interest was a number of respondents who found that it was larger
mining houses who had corporate standards which prescribed environmental monitoring that exceeded the
prescribed minimum baseline assessments. Generally speaking, respondents said baseline studies are also
not revisited as mining progresses. Thus, by the time of mine closure, the baseline studies are outdated,
both methodologically and in terms of content. This was especially true for older mining sites. According to
one professional:
“I have never seen any closure process in which the original baseline data were compared at
closure time to the desired end state.”
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
8 | Mine Closure 2014, Sandton, South Africa
Another respondent indicated that another problem was that baseline indicators were often poor points of
reference as mining usually fundamentally changes the biophysical environment, particularly the
hydrogeology of the substrate. Thus, even with the best intentions, the post-mining environment will differ
in its hydrogeological (and thus biological) characteristics in comparison to the pre-mining condition
(Worral et al 2009). Thus, respondents said that the commonly held notion of what it means to aim to
rehabilitate to a pre-mining state needs to be questioned. With this in mind, a comment from a respondent
working for the DMR, noting that his department recognises that the post-mining condition may differ from
the pre-mining condition, recognised this reality. This is corroborated by Government Notice R. 527, which
in Section 56, Principles for Mine Closure, subsection (e) states:
“land is rehabilitated, as far as is practicable, to its natural state, or to a predetermined and
agreed standard or land use which conforms to the concept of sustainable development.” (DME
2004).
It was found that water quality (both underground and surface) was the most cited baseline indicator. This
was followed by biodiversity (faunal and floral), air quality, soil quality and land use respectively. Thus,
excluding waste (a more atypical baseline indicator), and social indicators, these ‘basic classes’ of
environmental indicator are well represented. Social indicators are also poorly represented; although the
questionnaire focused on environmental indicators in the main. Less common indicators were: noise, land
capacity and geology. One respondent also specifically commented that very little geochemistry
characterisation is conducted. This again creates difficulties in closure planning as the characterisation of
potential Acid Mine Drainage (AMD) should be done initially so as to design discard dumps and mine water
flows with a view to the most sustainable closure. In addition, visual baseline assessments – to guide the
contouring and closure of tailings facilities or waste dumps – are neglected. Soil capacity and ecological
relations, both being more detailed and complex studies than soil characterisation and biodiversity
assessments, are also rarely conducted – perhaps due to a lack of expertise and/or funding. Thus, it seems
that studies which deeply interrogate future land use potentials are uncommon.
So, although baseline studies are currently integrated into new mine developments, they may not
encompass adequate detail and recommendations with a view to directing actual mine design toward
sustainable closure from the outset. This hinders closure plans as there are a lack of reliable baseline
indicators for comparative and goal setting purposes. Consequently, local environmental issues are poorly
understood and EMPs become ‘paper and tick-box exercises’. Operational mines too shall have weak
environmental indicators which do not adequately direct closure planning. Old mines lack baseline
indicators and closure must be aimed for without a holistic understanding of the pre-mining environment;
this presents difficulties in sustainably directing reintegration of the mined landscape into the surrounding
environment at closure. This is understandable as environmental legislation and responsibilities, even
twenty years ago, were not as stringent as they are today regarding pre-mining impact assessments
(Glazewski and Posnik 2000). Thus restoration (and the verifiable measurement thereof) to pre-mining
land-use, as South African environmental legislation advocates (DME 2004), is difficult to truly achieve.
3.3 Operational environmental indicators
As with baseline indicators, water monitoring (surface and underground) is the most frequently measured
available environmental variable. This may be partly due to ‘water use’ licencing as stipulated in the
National Water Act, No 36 of 1998 (DWAF 1998). Water monitoring was divided into quantity and quality
aspects. Water quality monitoring was conducted according to Global Reporting Initiative (GRI) guidelines
and South Africa’s water quality guidelines (DWAF 1997; GRI 2011). Basic biodiversity monitoring was also
frequently conducted during the operational phase, and included: relative abundance of species; plant
basal cover; invertebrates status; presence of red data or protected species and some alien invasive plant
monitoring. Again this was driven by legal requirements, such as Chapter 3 of the National Environmental
Management: Biodiversity Act, Act 10 of 2004 (DEAT 2004).
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Mine Closure 2014, Sandton, South Africa | 9
Basic air quality monitoring was also broadly conducted. Primarily for fallout (nuisance) dust, and
nominally, respirable dust monitoring, with merely a few instances of PM10 monitoring, and just one
instance of PM2.5 monitoring. Following on this, soil depth and fertility were cited as recorded parameters
followed by land capability. This set of indicators abides by the ‘basic classes’ used for baseline indicators.
During the operational phase, additional indicators were also monitored (albeit at lower frequencies than
the ‘basic indicator classes’), namely: energy usage; surface subsidence; waste generation; progressive
rehabilitation; noise; blast and vibration; EMS (Environmental Management System) compliance. In
addition, closure planning (backlog liability), greenhouse gas emissions, complaints, tailing seepage
monitoring, erosion, stocking rates and social sustainability indicators were occasionally monitored by a
few mines.
Respondents felt air quality parameters – such as NO
x
, SO
x
, CO
2
and even PM10 and PM2.5 – aside from
dust particulate fallout – went unmonitored. This was also said to be the case for many detailed ecological
indicators and soil indicators – such as soil depth, organic composition, expected agricultural yield, carrying
capacity, stability requirements, erodibility and water infiltration characteristics. Respondents also felt that
complex environmental pathways/interactions were poorly studied and understood. Greenhouse gas
emissions were cited a number of times as environmental aspects which were likewise seldom considered
or measured. Social indicators, such as a sense of place and visual (aesthetic) considerations were also
insufficiently considered. A significant number of participants also made direct comments that
environmental indicators data is frequently of a poor quality, inconsistent and of a variable standard. Weak
data management was also an issue. Numerous respondents said cumulative impacts were either
unidentified or unmonitored. This was partly because each mine is regarded as a single entity for licencing
purposes, when in reality environmental impacts are cumulative. This is regarded as a major shortcoming
of the current legislative approach, despite Section 24R(5) of NEMA providing that the Minister of
Environmental Affairs may,
“by notice in the Gazette, publish strategies in order to facilitate mine closure where mines are
interconnected, have an integrated impact or pose a cumulative impact” (DEAT 1998).
It is posited that the lack of detailed specialist monitoring is partly due to high equipment and maintenance
costs, as well as a shortage of expertise required to accurately operate such monitoring devices. More
detailed and complex environmental studies are also likely hindered by cost implications, although the lack
of gazetting of strategies to deal with cumulative impacts is also a significant problem. This affirms the
alleged status quo of omitting attention to cumulative impact indicators in mine closure. Furthermore,
missing or poor quality data makes sustainable mine closure a serious challenge. For example, with little
data on soils, there is a poor understanding of land capability, which in turn impacts negatively on the
capacity to define and target a final land use.
3.4 Challenges relating to mine closure
Respondents reported that the prime challenge facing sustainable mine closure was the inadequate
funding of and poor cash flow management of the closure process. Thus, long-term remediation measures
were usually sidelined due to budget constraints. This can become especially chronic near the end of life of
mine when cash flow becomes constrained. In addition, closure costing exercises were inaccurate and
unrealistic, thereby permanently hindering mine closure which could be said to be adhering to best
sustainability practices with respect to social, economic and environmental benefits. To cite one
respondent:
“Closure costs can be reduced by paying more upfront to design [and plan] better infrastructure
that will close easier and cheaper.”
It was further stated that mine closure planning was also often poorly conducted and weak. Quoting a
respondent:
“Key failure lies in mine closure generally being pushed out towards the end of the life of mine
when money gets tight.”
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
10 | Mine Closure 2014, Sandton, South Africa
Moreover changes in legislation (the closure ‘goalposts’), as well as senior mine management, were said to
undermine long-term closure planning. Final water quality is also a major challenge facing mine closure in
South Africa. With poor studies, planning and closure budgeting, water related impacts are unlikely to be
adequately comprehended and sustainably mitigated at the end of life of mine. This is especially due to
water management/treatment being a prime closure cost. As one respondent said:
“Water quality is always an issue. This is still the biggest challenge for any mine in any phase of
operation or closure.”
For these reasons a move away from active to passive water treatment was seen to be a sustainable
solution. Specialists commented that it is particularly difficult (even with detailed studies) to predict the
final water quality and make of a mining site, partly due to complex geohydrological issues. The matter of
determining residual environmental impacts included soil capacity, erosion and wind-blown dust from
dumps. Another significant challenge was that of sustainable rehabilitation. Poorly executed topsoil
management, sloping, double handling and material placement were contingent issues. The difficulty of
establishing sustainable vegetation cover in instances of poor soil quality was also listed. Smaller operations
usually lacked the resources to monitor and direct sustainable closure. Interactions between stakeholders
was a recurrent challenge. Communities are seldom cohesive, not capacitated to make informed decisions
and their expectations are often impracticable and/or unaffordable. Furthermore, mines do not conduct
adequate closure consultation throughout the mine life cycle, which subsequently hinders buy in. In
addition, government departments are under-resourced and so battle to both timeously and rigorously
deal with final land use deliberations and closure applications. Other specific issues which were cited
included: lack of post-closure environmental monitoring; procurement issues in remote mine locations;
rainfall causing rehabilitation and reshaping to be difficult; illegal mining and theft of monitoring
infrastructure; the cumulative impacts of numerous mines and poor land use planning. Furthermore, issues
such as poor topsoil management and severe erosion lead to long-term closure issues which are not easily
rectified as soil is essentially a non-renewable resource.
Problems arise in there being numerous government departments liable to be involved in environmental
closure (e.g. DMR, DWA and DEA (Department of Environmental Affairs)), as well as too few successful legal
closure applications to provide as an exemplar; these challenges are best summed up by a quote:
“Achieving sustainable closure requires a supportive, stable and mature administrative regime in
which a closure proponent can find solutions.”
Final closure approval from authorities is essentially viewed as a practical impossibility, as any residual
impacts would become the responsibility of the state; and hence government is extremely unwilling to
issue closure certificates. This is particularly problematic, as explained by two participants:
“The requirement to reduce mitigated risk to zero is unattainable, and since it cannot be achieved,
no mines are getting closure permits. This means that the best possible practices are being
rejected, and since undertaking best practice brings no reward, mines are not bothering to do their
best.”
“No mines have been legally closed in South Africa since 1994 as NUM will not allow it (loss of jobs
for union members). It is a political impossibility.”
The participation of all stakeholders in mine closure planning is also not collaborative enough. In short,
these issues speak to a broader inadequacy in strategic planning, technical capacity and a
cooperative/regional approach all underpinned by sustainability principles.
3.5 Successful mine closure
The majority of respondents indicated that successful mine closure can be achieved if there is top
management buy in. This includes committing to the concept of “mining for closure”, which ensures the
integration of mine closure objectives into operational mine planning and includes concurrent
rehabilitation, as well as ‘on the ground’ research trials. Respondents also indicated that mine closure is
Socio-Ecological and Economic Aspects
Mine Closure 2014, Sandton, South Africa | 11
more successful when trade-off considerations factor in short, medium and long term risks and costs. For
example, continuous rehabilitation and dumping strategies can obviate double material handling and can
save money in the long term. From a corporate standpoint, setting and implementing group wide mine
closure standards (which are also audited) and the strict supervision of closure liabilities also increases the
chances of successful mine closure. Quantitative surveys of the site and its infrastructure allow for a more
detailed mine closure plan (although these must be regularly updated to manage closure costing). A
respondent is quoted as follows:
“Successes are in instances where sufficient baseline information is available and pro-active
planning and client engagement exists in terms of closure planning.”
Closure training and awareness was also seen to be a success factor. The creation and support of a
dedicated closure team was also said to be a significant aspect in success. This included the establishment
of a steering committee and the participation of production staff. Other specific successes which were cited
included: topsoil recovery prior to mining; endangered plant recovery; alien species control; diligent topsoil
management and placement; the planting of indigenous vegetation on rehab areas; shaping to ensure free-
draining topography; the sustainable rehabilitation of waste dumps and particular successes with artificial
wetlands. The implementation of such best practices is evident in the response:
“The successes largely relate to the application of cutting-edge technology in addressing the
residual impacts, including water treatment and rehabilitation practices.”
A specific South African success in this respect is the development of the Emalahleni Water Treatment as a
joint venture between mining houses, with local government receiving the treated (to potable standards)
mine water. Thus there are successes in the cooperation between certain mine projects and government.
As another respondent put it:
“It is difficult to judge success. Mining will always result in change in the landscape and in
biological systems which re-establish in a changed environment. That said, there are some great
examples in the South African coalfield where a return to system functionality is evident 20 years
after cessation of mining. Many of the success stories relate specifically to small operations where
the footprint of impact was contained.”
There are nevertheless other innovative strategies in addressing mine closure beyond the legislative
concept of a closure certificate. This is exemplified in a respondent’s quote:
“There are too few cases of mine relinquishment to establish the overall success of mine closure.
Rather the success of mine closure planning can be judged more by cost savings […] of progressive
rehabilitation [and the] recognition that some mining waste is another company’s resource.”
Thus successes can be seen to be driven by top management buy in to the priority of mine closure, which
supports diligent scientific monitoring and research, which in turn informs detailed closure planning which
must be executed as continuous rehabilitation and/or innovative land-use projects, all while ensuring
stakeholder participation for long term sustainable closure.
4 Recommendations
Based on the responses received and the discussion thereof, certain recommendations can be made to
promote sustainable mine closure in South Africa. Firstly, detailed baseline assessments are an imperative
in underpinning an effective closure plan. These must then translate into comprehensive operational
environmental monitoring (and trials) which recursively advance decision making toward a sustainable end
land use. Such data needs to be accurate, reliable, frequent and well managed. Rigorous liability costings
must be conducted on an ongoing basis, with financial provision made accordingly. Further to this,
continuous (as well as optimally informed and designed) rehabilitation must take place as mining advances,
such that the final landscape restoration does not constitute an unmanageable cost.
Mine closure in South Africa: A survey of current professional thinking and practice M. Milaras, F. Ahmed and T.J.M. McKay
12 | Mine Closure 2014, Sandton, South Africa
It is also an evidently essential to garner buy-in from senior management. In addition, good cooperation
between all stakeholders is essential for long term success. Head office management teams need to take a
close interest in operations’ closure performance, both to support and to ensure compliance with quality
mine closure planning and execution. Mining operations need to commence a closure dialogue with all
stakeholders well in advance. Discussions (in conjunction with environmental studies) with government and
communities can best inform (and manage) the expectations, objectives and outcomes, of the final land
use. Public-private partnerships have been shown to produce win-win solutions to mine closure difficulties.
It is also clear that cooperative governance, with various government departments such as the DMR, DWA
and DEA must work together, sharing a common vision of what sustainable mine closure is. Lastly, legal
regimes and administration thereof needs to incentivise legal closure by recognising it as a compromise.
5 Conclusion
Mining is a temporary land use and mine closure has proven in South Africa, to be problematic, especially
with regard to sustainable mine closure. This is such that amongst mine closure professionals, there is
significant negative sentiment toward these challenges. These professional indicate that one of the most
significant issues is the frequent inadequacies of baseline and operational environmental indicators. In
addition to this poor management, government and public buy in, and proactive planning, are also deemed
as potential failure points in realising closure. However, there are also many proven mechanisms to
engender successes in mine closure. Were all role players in South Africa to endeavour to consciously and
systematically address such issues throughout mining, with an ethic of “mining for closure”, then the ideal
of sustainable closure may in fact be attainable.
Acknowledgements
The corresponding author would firstly like to acknowledge the participants who took the time to complete
the survey. Secondly, the publication workshop arranged by the South African Young Water Professionals
during which this manuscript was partially prepared. The author would also like to convey appreciation to
the Department of Science and Technology, Water Institute of Southern Africa and the University of
Johannesburg for covering the costs of the workshop. And lastly, my esteemed colleagues Emina and
Balthasar for their unflagging work company.
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