Legislative requirements in many jurisdictions require that the mine closure plan include a detailed plan of the post closure land uses. In essence, this plan is required to indicate how each rehabilitated footprint can potentially be used in the post closure environment. SRK has observed that in most jurisdictions in which we practice, legislation not only requires this detailed land use plan, but also requires that the post closure land use is sustainable, with community use as the basis of the sustainability requirement.
This requires the closure proponent to assess past practices, current community and other stakeholder requirements and then, within the constraints and opportunities presented by the socio- economic and environmental systems in the region, identify possible future land uses. The achievement of these uses then becomes the target against which remediation and rehabilitation activities are conducted and the ultimate closure objectives achieved.
However, SRK’s experience in closure planning in Africa and other developing nations has illustrated that this approach may not be the most appropriate. The primary reason is that the mines have little or no control over post closure use once the operation has returned a rehabilitated footprint to the owner, with control of the land vested in the owner or possibly community structure. Therefore, if the owner wants to utilise a rehabilitated footprint for a purpose outside the post closure land use plan, the mines have no influence over changing that. If the land cannot support the owner’s purpose, mining companies could suffer reputational damage.
Furthermore, we have observed that land use of a specific rehabilitated footprint is dynamic: post closure use can undergo a number of changes as community requirements evolve. In addition, many of the mines for which we consult show the land ownership or land use is complex, with multiple stakeholders owning small blocks within the footprint. If post closure land use wants are not aligned, trying to prepare a post closure land use plan based on the multiple owner requirements results in a mosaic of land uses that are not necessarily complementary and very difficult for the mine to implement.
SRK’s approach to mitigating mines’ risks from little to no control over post closure use, and evolving land uses is to recommend an approach of restoring land capability rather than land use. We now develop relinquishment criteria specific to restoring land capability. By planning to implement specific land capabilities on footprints, we can allow the post closure users to choose how to use the land, within the constraints imposed by the environment. This involves determining likely potential post closure land uses and determining how to provide footprints that support these evolving land uses.
