The development of a mine closure framework: a case study for Namibia

Abstract

Namibia is heavily dependent on the extraction and processing of minerals for export and this is a central pillar of Namibia’s economy. However, while mining presents a significant opportunity for growth and development, the government, civil society and the private sector must work together to ensure that meeting the needs of today’s stakeholders does not compromise the needs of future generations. In 2018, a Mining Policy Framework Assessment revealed that there was a lack of legislation that provided details for progressive rehabilitation, mine closure planning, site relinquishment and associated transfer of residual environmental and financial liabilities from the licence holder back to the government. Based on the assessment and capacity training carried out by the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), there arose a need to develop a mine closure framework from a regulator’s view point since there is already one that was developed by the Namibian Chamber of Mines (CoM). The framework represents a desire from industry to support the implementation of the government’s Minerals Policy, which stipulates that the government will develop guidelines on closure and it will monitor compliance using set performance guidelines. However, the CoM mine closure framework does not prescribe how financial provisions for closure should be implemented and as such, this leaves the determination of the allocation of mine closure funds at the discretion of each mine operator. The present paper therefore, outlines the steps that were undertaken to develop the regulator’s framework and also provides preliminary outcomes from the process. The study was carried out using independent but complementary methodologies. These included a baseline study and data analysis, mining policy framework analysis and report writing. Relevant reports and data from government ministries, public institutions, private sector organisations and agencies were analysed. A benchmarking exercise with leading mining countries such as Australia, Canada and South Africa was undertaken. This was aimed at searching for new ideas and exchanging views and opinions on the developmental outcomes of the mine closure framework. The purposes for the development of the framework were to ensure that mines operating within Namibia align with the requirements of national rehabilitation and closure-related legislation; standardise the approach to rehabilitation and mine closure planning by developing a standard that all operators can use for consistency reporting. The major elements of the proposed framework are that it sets an internationally accepted best practice framework for the Namibian mining industry to achieve the required regulatory rehabilitation and closure compliance. This includes dedicated stakeholder engagement on key closure planning aspects and also identifying the importance of aligning mine rehabilitation and closure planning throughout the mining life-cycle. It also provides the main planning aspects to be considered when developing, refining and implementing rehabilitation and closure plans and specifies the key considerations to determine closure cost estimates and the process to make financial assurance provisions for rehabilitation activities. It also identifies the importance of implementing progressive rehabilitation, frequently refining mine closure plans and continuing ongoing monitoring throughout the mining life-cycle towards the achievement of eventual site relinquishment.