Part 3 – Standardised Completion Criteria
In most mining jurisdictions in the world, mine relinquishment remains a challenge as it is an amorphous concept with no defined end (Holmes et al 2015). In Canada it was found that one of the challenges preventing more sites being relinquished is the lack of streamlined criteria for determining whether rehabilitation objectives have been met and what the regulatory agencies consider acceptable (Charette and Poscente 2012). Closure completion criteria are often ambiguous, ill-defined and/or inconsistent across jurisdictions, resulting in uncertainty in approaches to mine closure for mine operators, unclear standards for regulatory agencies and confused expectations among mine communities and stakeholders at large (Holmes et al 2015). To address this challenge, the Canada Mining Innovation Council’s Environmental Stewardship Initiative (CMIC ESI) is developing a set of standardised completion criteria to apply to all oil sands operations.
In the third article of this series (view articles Part 1 and Part 2), Astron’s Principal Scientist – Rehabilitation, Katina De Sousa, assesses the key components, strengths and weaknesses of standardised completion criteria in addressing the current challenges in achieving mine relinquishment.
The aim of the CMIC ESI is to develop completion criteria that provide a clear path to mine closure and subsequent relinquishment by defining the conditions, which, if met, will enable the government to accept sites into their custody for long-term stewardship (Holmes et al 2015). The standardised completion criteria will be embedded in the legal and regulatory framework the Province of Alberta has established for the relinquishment of oils sands sites. The standardised criteria will include a set of environmental performance endpoints that must be achieved – or be on course to being achieved – to ensure that the overarching objectives of mine closure are met, including minimising public health and safety risks, minimising ongoing negative environmental impacts and achieving an acceptable, productive and sustainable post-mining land use (Alberta Environment and Sustainable Resource Development 2013).
The CMIC ESI has developed a completion criteria framework that covers the major components of mine closure and will be quantifiable where possible:
- Physical stability
- Geochemical stability
- Land reclamation
- Ecosystem rehabilitation
- Site infrastructure and waste
- Financial assurance.
In late 2014, the Alberta Government preliminarily accepted the criteria framework subject to further review, development and field demonstration/assessment (Alberta Environment and Sustainable Resource Development 2013). Over the next four years an extensive stakeholder consultation process will drive the development of completion criteria to flesh out the framework. The main objective of the consultation process is to enable stakeholders to reach broad consensus regarding the acceptable conditions for mine closure and subsequent relinquishment (Holmes et al 2015).
The development of standardised completion criteria to facilitate mine site relinquishment has strengths and weaknesses:
- Sets a minimum standard that must be met consistently across the mining industry.
- Ensures completion criteria will be applied in a fair and consistent manner.
- Provides certainty to mining companies about what they are expected to achieve.
- Assessment of mine closure becomes more structured, managed and streamlined.
- Potentially increases efficiency of approvals processes by simplifying the permitting and consultation process.
- Local stakeholders will have more assurance that mining activities will cease without unacceptable consequences for the location communities and the environment.
- Does not deal with all of the current issues with relinquishment of mine sites if not embedded in a regulatory framework that addresses the relinquishment process and post-relinquishment management of sites.
- Development of the standardised criteria is not complete – only the framework has been developed to date. It may be difficult to get agreement between stakeholders ranging from communities to mining companies on the setting of quantitative targets.
- Lack of information to form the basis for quantitative targets (for example, appropriate level of species richness to be achieved in ecosystem rehabilitation).
- Generally, the same standards are not appropriate across whole states or countries and all parts of the mining industry. For example, in Western Australia:
* Mineral sands mining generally has much lower risk in terms of landform stability than large-scale open pit mining. Therefore, the same criteria around landform design and stability may not be suitable.
* Rehabilitation in the southwest of the state will need to meet very different criteria to that in the northwest.
Standardised completion criteria do provide guidance to mining companies by setting the rules regarding standards expected and what needs to be achieved in order to receive sign off by the regulators. However, this is only one of the pieces missing in formalising a relinquishment process. I believe that other pieces, such as formalisation of the process and setting up the systems for funding and implementation of post-relinquishment management of sites, are more important than standardising completion criteria.
Additionally, the Western Guidelines for Preparing Mine Closure Plans (DMP/EPA 2015) and Strategic Framework for Mine Closure (ANZMEC/MCA 2000) specify that completion criteria should be specific enough to reflect a unique set of environmental, social and economic circumstances. With the diversity of environments and types of mining in Western Australia it would be a very difficult process to set completion criteria that are applicable to every site.
Stay tuned for the final article on this series, on the Institutional Control Program that the Province of Saskatchewan has in place that defines the conditions under which it will accept custodial responsibility for closed mine sites and provides for long-term stewardship of each site.
Alberta Environment and Sustainable Resources Development 2013, Criteria and Indicators Framework for Oil Sands Mine Reclamation Certification.
Australian and New Zealand Minerals and Energy Council (ANZMEC) and Minerals Council of Australia (MCA) 2000, Strategic Framework for Mine Closure.
Charette, T and Poscente M 2012, Criteria and indicators framework for oil sands mine reclamation certification, Cumulative Environment Management Association, Edmonton, Canada.
Department of Mines and Petroleum (DMP) and Environmental Protection Authority (EPA) 2015, Guidelines for Preparing Mine Closure Plans.
Holmes, R, Flynn, M and Thorpe, MB 2015, ‘A framework for standardised, performance-based completion criteria for mine closure and mine site relinquishment’, Proceedings of the 10th International Conference on Mine Closure, Vancouver, Canada, 2015, InfoMine, pp. 121-130.
Pepper, M, Roche, CP and Mudd, GM 2015, ‘Mining Legacies – Understanding Life-of-Mine Across Time and Space’, Proceedings of the Life-of-Mine 2014 Conference, Brisbane, Australia, pp. 449-465.