·       Starting mine closure activities early – challenges implementing progressive rehabilitation activities instead of using the capital to extract ore. Looking for opportunities to use mining fleet during quiet times or direct haul opportunities for reclamation.

·       Partnerships - essential for effective mine closure however the diversity of thought can be a challenge for all.

All stakeholders need to be involved from concept stage including Indigenous landowners, communities, environmental groups, governments, etc.

It is unbelievable to think that it was only in 2021 that a standard was developed for consistency and quality of mine closure.

The biggest challenge is the cost of closure and how mining companies factor that in at start up to show shareholders the value in operating, extracting and closure.

(2) Shifting mindsets. Mine closure is often perceived as negative and terminal, without any significant opportunities for value and benefit generation. However, in more recent years many successful mine closures were of positive nature and transitional by bringing benefits through regeneration of value via new economic and environmental ventures. As integrated mine closure becomes more embedded in the initial mine planning, local communities can expect to see multiple utilization and valorization opportunities of their land(s), benefitting many generations in local and indigenous communities.

a)      Early and Comprehensive Planning:

·       Challenges: Many mining projects do not plan for closure early enough, leading to inadequate preparation for environmental and socio-economic impacts.

·       Mitigation Plan: Integrate closure and reclamation planning from the project's start, with detailed plans covering the entire mine life cycle.

b)     Regulatory Inconsistencies:

·       Challenges: There are significant variations in regulations and requirements for mine closure across different jurisdictions, leading to inconsistent practices.

·       Mitigation Plan: Developing and adopting international standards like ISO 21795 for consistent, high-quality mine closure planning, ensuring environmental protection and community well-being.

c)      Socio-Economic Transition:

·       Challenges: Planning for the socio-economic transition of communities and workers post-closure is often inadequate, with many jurisdictions lacking specific requirements.

·       Mitigation Plan: Engage stakeholders early and develop socio-economic transition plans for long-term community well-being, including alternative economic opportunities and providing training and support for workers.

d)     Financial Assurance:

·       Challenges: Ensuring that adequate financial resources are available to cover the costs of closure and reclamation, even if the mining company faces financial difficulties.

·       Mitigation Plan: Establishing robust financial assurance mechanisms and ensuring that closure costs are accurately estimated and funded. This can include setting aside funds or obtaining insurance to cover closure expenses

e)      Stakeholder Engagement:

·       Challenges: Building trust and maintaining transparent communication with local communities, Indigenous groups, and other stakeholders throughout the mine's life cycle.

·       Mitigation Plan: Involving stakeholders in closure planning and address their concerns through regular consultations, community meetings, and collaborative decision-making.

f)       Technical and Environmental Challenges:

·       Challenges: Addressing site-specific technical issues, such as geotechnical stability and water management, to ensure long-term environmental protection.

·       Mitigation Plan: Implementing innovative technologies and best practices for effective closure and ongoing monitoring. This includes using advanced techniques for waste management, water treatment, and land reclamation.

g)      Integrated Planning:

·       Challenges: Developing integrated mine closure plans that consider environmental, social, and economic factors in a holistic manner.

·       Mitigation Plan: Using interdisciplinary teams to develop comprehensive, integrated life-of-mine plans addressing all aspects of closure and reclamation. This involves collaboration between environmental scientists, engineers, social scientists, and community planners. From Sridhar Narayanan (24th Feb2024)

1. Early and continual planning:

   • Failure to plan for closure creates a very reactive approach to the eventual engagement with communities and other stakeholders. This reactivity then requires more time and effort to mend relationships and obtain community perspectives. I was shocked that 24% of countries don't require a mine closure plan as part of mine development.

   • Lack of early planning then results in rushing rehabilitation, without sufficient consultation with all stakeholders.

2. Inconsistent approach from regulators:.

   • There is a lack of clarity on who is accountable for pre-closure planning, and post-closure handover.

   • This lack of clarity, as highlighted in some of the past videos explains why Governments are hesitant to agree to land handovers as they perceive the risk as too high.

3. High costs and monetary risks:

   • Public companies are inherently risk averse as they are pushed to be profitable and pay dividends to shareholders. Where projects are delayed for permitting, this results in negative impacts to the mine NPV (e.g. $20m per week as referenced in the article)

   • Additional consulting and front-loading of closure plans development all requires funding to complete. The higher the complexity, the more people are required, which again negatively impacts on a project NPV.

These challenges highlight the need for early, integrated, and multidisciplinary planning to ensure that mine closures benefit both the environment and local communities in the long term.

^{·       The mining industry has historically had a negative reputation for the abandoned mines left in the 20th century.  Building confidence in stakeholders and communities is critical to gain a social license to operate.  Now, more than ever, mining companies should do what they can to repair the damaging reputation and provide comprehensive and sustainable closure plans.}

^{·       ISO 21795 Mine Closure and Reclamation Planning was not released until October 2021!  That is shocking to me that this governance did not exist until less than 5 years ago.  The standard provides guidance on consistent and quality planning, as well as a holistic approach to ESG.  I personally think it will take time for ISO 21795 to be adopted and implemented at a meaningful global level.} 

^{·       The socio-economic transition seems to be overlooked even more than the other mine closure aspects.  With IGF reporting that 41% of jurisdictions surveyed have no requirements at all for social transition and community impacts.  They sight that there are “…still questions over whose responsibility it is”  Post closure socio-economic impacts are not considered, however, ESG is identified as “…critical” Mining companies and governments need to work together to develop standards to help close this gap.}   

Early planning, continuous modifications to the plan as the mine grows, and ensuring the provisional funds are available for closure activities without affecting the mining operations are essential.  Closure can be planned, designed, and started having a positive impact on the community and environment, there are always unforeseen events such as natural disasters, storm events, or historic mining remains that are not discovered until the closure has started.  These could impact communities, water sources, or even the reclamation that was started.  Closure will be a living activity even after it has been completed by the mining company, this is where the community involvement and relations are so important so they understand all the work, protection, and plans that were put in place during the execution.

 It was good to see there were76%of the countries with formal legal requirements, are still low but with the standards only being in place for a few years it is a good start. The surprising number to me was the jurisdictions with no requirements at all for mine closure, 41%.  This of course will be very difficult to drive forward with so many different countries, governments, and jurisdictions, the largest influencer can be the mining company itself to hold each site to the highest expectations, and sustainability, and set the example to the mining industry, continuing the positive example to the communities.

Post-closure again could be hard to define during the initial stages of planning, socio-economic impacts, land handover, land usage possibilities, and how close the community gets to the operation during the life span of the mine.  With a short life span of 10 years or less there may not be any changes, greater than that the plan may need to be adjusted, options, and opportunities re-evaluated. At the end of the day, I liked how they noted “Building a new legacy and getting recognition for it”.

I feel there are three consistent themes, which will remain a challenge until there is a consistent approach by each country/governing body.

There are also often historical reputations that need to be overcome, and it will take some time to build trust in the process.

Mine Closure Must Be Part of the Plan from Day One

• In the past, mine closure was an afterthought, leading to environmental damage, financial strain, and abandoned sites.

• Many companies focused only on extraction and have treated closure as a costly obligation rather than an investment.

• A shift in mindset is needed—closure planning should start when mining begins, ensuring land rehabilitation, economic transition, and long-term sustainability.

• Early planning reduces risks, lowers costs, and creates opportunities for communities beyond mining operations.

Financial Risk Must Be Seen as Long-Term Value

• Companies often delay closure planning to avoid immediate costs, but this increases expenses and liabilities over time.

• Traditional thinking sees closure as a financial burden, rather than a way to create value through land reuse and community development.

• Securing closure funds early and integrating economic regeneration into closure plans can turn mining sites into ongoing productive assets.

• Regulatory certainty and clear policies will also help companies make informed financial decisions about closure.

Mindset Change Comes Before Community Trust

• Many mining communities, especially Indigenous groups, historically have been excluded from closure discussions, causing mistrust and land disputes.

• Companies often engage communities too late, treating consultation as a requirement rather than a partnership.

• Trust can only be built when the industry shifts its mindset—seeing communities as long-term stakeholders, not just temporary workforces.

• If communities are involved from the start, mine closures can support local economies, preserve cultural heritage, and create lasting benefits beyond mining.

1. We have evidence in Australia in mine closure when closure discussions were not held early or in a continuous manner. This leads to a rushed and unsuccessful community transition. This has seen reputational damage to the mining company and social confusion and disadvantage to the local community, in particular Traditional Owners.

2. The cost vs value question is often overlooked to projects detriment. The western attitude toward cost vs value needs to be challenged with every project. Mine closure is no different. Again, I use the example of a mining company wanting to dig a great big hole to fill mine assets with rather than redistributing to community because that approach was deemed not cost effective. When this decison was reversed, the outcome was a positive one for the local communities. It took a mistake to realise this benefit. Was it a mistake or a different perspective from engineers and community and social performance practitioners/community stakeholders?

3. Risk is at the basis of decision making in business, right? Where does the basis of the risk lay? Government? Mining companies or community? All of the above. In most instances in Australia, mining leases are relinquished back to State Governments. No Government is interested in accepting a prior mining lease site without guarantee that future environmental pollution is mitigated. So, why should Traditional Owners and community stakeholders accept anything less than this? They shouldn't. Closure planning from Agreement development stage is critically necessary to keep up with changes to ISO standards, technologies and statuatory laws. Waiting until 5 years prior to end of mine to start the dicussion is not long enough.

Another challenge I see is in the application of these strategies for existing mines. While there will be many new mines to open in the future, so many are already in existence and are currently approaching closure. How can existing mine sites be supported in the planning process, and how can they improve reclamation practices that were originally designed before ESG became a major focus in mine closure? Many mining companies currently in operation may struggle to meet advancing requirements for social and environmental stewardship if they have not been integrating closure plans and communications from the start.

The key challenges identified  in the Glory in Closing a Mine article by Cim Magazine, are as follows:

Regulatory Requirements:  the article states that out of 84 countries surveyed by IGF, 74 % have a legal requirement for a mine closure plan to be submitted as part of the mine development request.  Across those, there is significant variance across the quality of those plans.  The numbers are even lower with respect to planning concerning social or economic impacts post mining with advancements in this aspect lagging to the technical aspects of mine closure. These variances pose challenges for miners for communities and place pressure on governments. Opportunity exists for global mining companies, such as Rio Tinto, who operate across 35 countries and having to navigate various regulatory requirements within those countries, in developing leading best practice principles in sustainable mine closure, standardised across its portfolio of mine sites.

 Early Planning: 

A.     Life of Mine Planning:  adopting the ISO 21795 Mine Closure and Reclamation Planning standard to support mining companies and regulatory bodies towards early and high-quality planning for mine closure.

B.     ESG considerations:  incorporating high-design parameters at the mine planning stage and allocating adequate funding to support during the life of mine.  This would encompass progressive rehabilitation during the mine operations, positively contributing to the land, the local environment, and the local community.  Additional benefits include reduction of financial burden at time of mine closure, when revenue is declining and risks relating to workforce and skills attrition exist.

C.    Social-economic transition:  early planning to include all stakeholders for a transition to a future beyond mining.  An integrated approach which considers input from Indigenous rights holders, local communities, government bodies and workforce transition professionals to design a roadmap for the transition.  Early preparation mitigates external risks including environmental, economic and industrial which can arise and result in early closure of mines. The current global energy transition and the slow-down of China’s economy are two externalities which should be driving mining companies to commence early closure planning.

Community Trust:  the negative impact to environments and communities created by  mining practices over the years have given rise to community mistrust and lack of support for new mining approvals.  Rebuilding this trust will require incorporating mine closure in the early planning stages, bringing in communities to have a voice and role in the in the planning process. I am uncertain whether this proactive approach has been truly embraced by miners in Australia.

Reading the "The glory in closing a Mine" bring some reflecting area as I identified as challenges:

• Legal framework: laws, guidance’s, standards...have been developed and show some gaps as it treats a specific portion of the closure matters (working silo aspects) and gaps between of some are identified. Adding that, as a guide they are generic, not specific enough to allow clear RASCI in matter of action and implementation. They need to be adapted by taking consideration of local law or reglementation as regulatory bodies rely on local law (Mine code and MECIE decree for Madagscar).

• The other challenges are about how engaging earlier the right stakeholders when the regulation about the right to own the land is not clear (specific case is that at the end of the Mine, is the land return to the Government, which have their own agenda/landscape design or to the community who have another landscape vision as well). Who will be the right COI to engage with? who will be the decision-making aspects between the community/Government/….?

• There is, as well, a risk on co-design with stakeholders due to the priorization of the actual vs future benefits (for progressive rehabilitation with the community for example) that may bring confusion/conflict.

• Highlight the social acceptance/acceptability of closure, about livelihood transition, sustainability may put the technical aspect at a second zone. A multidisciplinary team can solve this, by taking in consideration the interest of some NGOs, environmental leaders...some of them are not technical lead to a heavy process of engagement and may lead to high cost to demonstrate environmental impact and emphasis mitigation.

• As a mine is "temporary use of the land" adequate design should be find and that why in the Social and Environmental Management Plan of project ion Madagascar, they request a generic closure plan to the document to allow the company to incorporate this required in their operational strategy and some KPI of closure embedded in this management plan (rehabilitation KPI,....).

• The involvement of expert (Area of expertise) in specific item as environment (Biodiversity, water management,...) and Community Social performance is keys to increase trust(with appropriate communication)

  
  

Indigenous Participation – One critical gap in the article is the lack of emphasis on Indigenous involvement in mine closure legislation. In regions like the Pilbara, their absence from the process presents a major challenge. How can we ensure Indigenous voices are heard and their rights recognized in closure planning?

The Closure Planning Challenge – Mine closure is still treated as separate from mining operations. If closure planning were integrated into operational frameworks from the beginning, it would enhance transparency and accountability, leading to better environmental and social outcomes. What steps can companies take to make this shift a reality?

Global Consistency – Governments must not only enforce early closure planning but also work collaboratively with stakeholders to ensure policies are implemented consistently worldwide. We should address the challenge of differing regulations and enforcement across jurisdictions

Mine closure should not be an afterthought. It must be a fundamental part of mining operations from day one. We need to find innovative strategies can help mining companies transition from being known for extraction to being recognized for responsible closure.

• Many mining projects lack early closure planning, leading to inadequate socio-economic transition plans. According to the article, 76% of surveyed countries have formal legal requirements for mine closure plans, with varying levels of rigor and scrutiny. There is still much room for improvement, but it is a start.

• Inconsistencies in regulations, especially regarding socio-economic transition, with 41% of jurisdictions having no requirements for planning community impacts. In Canada, regulations on post-closure social or economic impacts remain vague and inconsistent across provinces and territories.

• ESG issues are critical, with increased scrutiny from stakeholders, particularly investors. Delays in critical minerals projects due to stakeholder opposition and environmental concerns can result in significant financial losses.

• Early involvement of stakeholders, including Indigenous rights holders, is essential to create a shared vision for post-closure land use and community development. Building trust with local communities through progressive reclamation and demonstrating commitment to sustainability. The social dimensions of mine closure have received significantly less attention, however, the information from the local community and indigenous groups can not only build trust but also facilitate support for the company itself. There is also the key issue of identifying the right interdisciplinary team, which should include an array of experts to speak directly to their field of expertise (biological, hydrological, hydrogeological, social, traditional owner leads, state/federal approval advisors) to address diverse challenges.

• The high costs associated with mine closure and the financial risks of not meeting ESG standards can be significant barriers. Companies must plan upfront for closure to mitigate financial risks and ensure long-term sustainability.

Some if the primary challenges from the article "The Glory in Closing a Mine" that are crucial for ensuring that mine closures are beneficial and sustainable for both the environment and local communities are:

1. Early Inclusive Integrated Planning:

   Challenges: Lack of forward-thinking closure planning inevitably leads to inadequate preparation for environmental and socio-economic impacts. Many mining projects lack early closure planning, leading to inadequate socio-economic transition plans. While 76% of surveyed countries have formal legal requirements for mine closure plans, the rigor and scrutiny of these plans vary significantly. Developing integrated mine closure plans that consider environmental, social, and economic factors holistically.

2. Regulatory Variations:

   Challenges: There are significant variations in regulations and requirements for mine closure across different continents, countries, governing bodies and local jurisdictions. This makes planning by various global mining companies difficult, inconsistent and often absent.

3. ESG Issues:

   Challenges: Environmental, Social, and Governance (ESG) issues are critical, with increased scrutiny from stakeholders, particularly investors. Delays in critical minerals projects due to stakeholder opposition and environmental concerns can result in significant financial losses.

4. Financial Surety:

   Challenges: Effective financial resource planning for post mine closure is an item that is often overlooked. Ensuring adequate financial resources to cover closure and reclamation costs, even if the mining company faces financial difficulties, is paramount.

5. Stakeholder Engagement:

   Challenges: Building and fostering strong relationships fosters trust and maintains transparent communication. All parties’ local communities, Indigenous groups, civil groups, governmental departments and mining houses need to learn to develop meaningful relationships which will aid in closure objectives being set and met!

1) Change in perspective to ensure there is as much glory in mine closure as it is in new mine development

2) Late planning is a challenge. Not all mining projects planning early for closure.

3) Fragmented thinking is another challenge as some mine closure plans still are prepared as a separate process and by consultants who specialize in mine closure and remediation instead of an integrated mine planning process.

4) Inadequate or vague regulatory -

most of the regulatory guidelines and requirements for socio-economic transition are inadequate and full of gaps.

5) Closure costs are notorious for spiraling out of control.

6) Unclear responsibilities

1. Balancing Environmental and Social Objectives: this requires careful planning, resource allocation and clear detailed guidelines. I can see this being complex with opposing wants and needs.

2. Stakeholder Engagement and Trust:

   Building and maintaining trust with stakeholders, including local communities and Indigenous peoples, is crucial. Mining Companies aren't always good at doing this and trust can be easily eroded and hard to build once broken, eg Juukan Gorge incident in WA

3. Economic Transition and Sustainable Livelihoods: Have in place long term jobs that aren't related to mining. Hard to get people to transition, doesn't just impact employees but whole families too!

Key stakeholder identification and engagement: It's difficult to determine what constitutes a just transition or be able to successfully execute it without consultation with the correct stakeholders. The correct stakeholders would usually involve people from the community, indigenous rights holders. I didn’t think about this previously but from the article, it also includes workforce transition experts and regional economic or community planners which would help bridge a gap between the mine companies plans and the community needs and wants.  

• Conflicting Objectives: The article describes how achieving chemical stability compromised the physical stability objective of the community. All objectives and their strategies o execute should be viewed together and be aligned.

• Inadequate Socio-Economic Planning: 41% of jurisdictions lack requirements for social transition plans, and Canadian regulations remain vague, risking insufficient community support post-closure.

• Financial and Timing Pressures: Without early planning, closure costs can reach billions, and delays from stakeholder opposition may incur losses of $20 million per week.

• Coordination Difficulties: Effective integration of multidisciplinary teams and stakeholders is hindered by unclear responsibilities and inconsistent regulations.

• In many projects, mine closure isn't properly considered until the end.

• This means important environmental and social goals often get overlooked.

2. Teams Aren’t Aligned Across the Mine’s Lifecycle

• Different teams handle different stages of the mine, often without strong coordination.

• As a result, closure plans may not reflect the realities of how the mine has been run.

3. Communities Often Feel Left Out

• Local communities and stakeholders aren’t always included early enough in closure conversations, and decisions around the closure activities were made without consulting them.

• Long-term success depends on making sure communities help shape and benefit from what comes after mining.

4. Rules Can Be Rigid and Limited

• Most regulations focus on ticking boxes, not on delivering real long-term value.

• As a result, mining companies may meet the minimum requirements

5. High Costs

• Closing a mine properly can cost a lot

• Without upfront planning, costs can be high and increase quite rapidly

• Planning ahead helps manage both the financial and environmental risks.

6. No Clear Definition of Success

• Success is often measured by whether the site is technically closed and meets legal standards, and no measurement is put in place for land reuse past mine life and what the land can be used for the communities

7. Past mistakes are remembered

• Abandoned or poorly closed mines from the past have damaged the industry’s reputation.

• Mining company and industry need to regain communities trust

Differing objectives. Sometimes it might be the case that what local communities want as an outcome for their long-term sustainability will create additional or continued pressure on the environment which could result in the impression that environmental concerns were somewhat ignored. Negotiating potential conflicts like that highlights the importance of collaboration and communication.

Misalignment as a result of financial considerations. There is a risk with satisfying environmental and socio-economic factors together that the financial aspects might not be nicely aligned. For example, if environmental factors for closure & relinquishment are too stringent (and costly) during the monitoring phase, it could end up delaying the planned transition for local communities to their new economy post-mining.

Integrated planning for closure typically starts too late. All of the lessons from historical mine closure activities point to challenges as the result of delayed planning & preparation. For an integrated approach to provide benefits to both the environment and the local community, there needs to be more time to consider options, resolve differences, build capacity, and allow for creative solutions.

Questions of responsibility. As the article highlights, although there are guideline documents of various kinds, there are still gaps in understanding where responsibilities sit. Some of these questions could be the result of inadequate requirements but either way, resolving the uncertainties around responsibility (possibly via a dilemma sharing approach) will be increasingly more important for socio-economic transitions being planned for.

Every closure site is different. A consistent challenge that we hear in the mine closure space is that because each mine is different (location, environmental conditions, size, complexity, community, owner, infrastructure, materials, risk etc), it means that every mine closure plan is highly unique and demands bespoke considerations. So, an integrated approach that worked well at one mine site, may have little that can be applied or replicated to another.

Making closure everyone's responsibility. When it comes down to it every participant in the value chain for a producing mine is contributing to, and thus responsible for, the outcomes (good or bad) when it comes to closure. As someone working as a closure SME in Rio Tinto has shared with me - "The Closure business ends up being the garbage dump of all the bad decisions made during operations". If we can make effective mine closure part of everyone's responsibility, from the initial mine conceptualization phase and all the way through operations, then we can go a long way to creating that truly integrated approach.

1. Long history of lack of regulations that keeps everyone accountable and responsible.

2. Lack of financial provisions to fund closures

3. Mindset and missed opportunities to turn challenges into opportunities - Mining operators treated mine closure planning, just transition and post closure as an afterthought.

4. Negative social and environmental experiences resulting in the lack of trust by the communities and environmental bodies.

5. Inconsistencies in regulatory guidelines and requirements across the industry and countries.

6. Unclear responsibilities and accountabilities of government agencies at multiple levels.

7. Lack of stakeholders and rightholders engagement from the beginning and not addressing concerns and issues adequately.

8. Complications in the varieties of mines in different geography and mining methods

9. Lack of a holistic view of the entire value chain from mine opening to mine closure.

1. the mine closure process is approached very differently, depending on jurisdiction, mining commodities, mining companies (public, not public,..). There is a lack of consistency. This leads to the closure process not being adequately thought through and can be overlooked. Some jurisdiction don't have any requirement at all, when some impose a mine closure plan to be submitted as part of a new mine application. vastly different. If the approach was more consistent, this would create

2. Whilst having an integrated mine closure plan is the best approach to maximize environmental and local communities in the long term, such a plan might actually "hinder" the mining company to generate value and cash flow. there will potentially need to be compromises (or at least the mining companies might think so!) between maximizing revenues now, or making the closure more difficult or more costly down the track. the nature of our economies means mining companies might always favour revenues now.

3. the lag and the delay between the mine closing and the socio-economic transition to another type of activity. Often this takes time, and the lack of momentum can undermine that process. The other aspect, from a social economic perspective, is that mining is generally a profitable industry, which create wealth for surrounding communities, and the transition to a post mining economy is likely to create a gap and a significant impact.

• The regulatory space, where guidelines and requirements for socio-economic transition are inadequate.

• Post closure socio-economic impact considerations lagging behind technical closure work.

• Social transition (closure) not being considered early enough in the mine lifecycle.

• Focus of operations to build mines and make them sustainable as opposed to thinking further ahead to closure (short-term vs long-term). Similarly, cost is an issue where focus is on short-term shareholder gains, rather than longer-term minimising of shareholder liability.

• Singular mindset where mines are thought of as a business instead of temporary land-use activity.

In addition to these, I think the following challenges also exist:

• The concept of integrated closure is at odds with a common practice in mining where assets/resources, once they reach the end of their life, are sold at a minimal price and the closure liability then shifts to the new operator. In Australia, particularly Queensland, this is a common approach that sees older operations repeat this process until the mine falls in the hands of a junior mine operator that does not have the capacity to manage the associated environmental liability.

• The community’s ability to adequately translate what it’s vision for closure is. While I think this is a conversation that mining companies can help facilitate, it also requires adequate participation from government and community, as well as acknowledgement that what closure aspirations might be today, could be different tomorrow.

1. High Cost

   
   

   Most of the mining companies are commercial result driven so the billion dollars cost on mine closure will make the companies execute the plan in a longer timeframe than the original plan. This change may impact the future plan for the local communities if a fixed timeframe can't be fully executed.

2. Holistic approach to closure planning

   
   

   The ESG topic has become popular in recent years. Major banks and investing groups had setup their target to achieve the ESG goals. However, the trend has changed in the past two years when companies like JP Morgan and Blackroc announced to abolish the net zero target. It is a big pivot for ESG and also may make mining companies to rethink their closure strategy and budget.

3. The government's role

The government plays a key role in the closure planning between the community and companies. If the

government can't stay neutral and be a good bridge,

the trust and plan will not be fully executed. How to

ensure the government's attitude remains the same

throughout the closure project cycle is another

unpredictable factor.

• Weak Governance and Regulatory Gaps:

  Lack of strong regulatory enforcement allows mining companies to abandon sites without fulfilling their obligations, leading to environmental damage and social distress. Corruption and weak governance can also hinder the implementation of transparent and accountable decision-making, making it difficult for communities to participate in the closure process. 

• Regulatory Uncertainty and Financial Constraints:

  Unclear regulatory pathways and financial limitations can prevent companies from fully addressing the environmental and social implications of mine closure. This can lead to delays in closure and relinquishment, leaving communities in a state of limbo. 

• Inadequate Planning and Lack of Stakeholder Engagement:

  Insufficient planning and communication with local communities can lead to misunderstandings and conflicts over post-mining land use and socio-economic transition. Integrating cultural heritage considerations into closure planning, and actively involving communities in the process, is crucial. 

• Socio-Economic Impacts:

  Mine closure can have significant socio-economic impacts on local communities, including job losses and economic hardship. Transition plans must address these impacts and help communities diversify their economies. 

• Environmental Risks:

  Mine closure poses environmental risks, including water contamination, acid mine drainage, and soil pollution. Closure plans must address these risks and ensure that the site is rehabilitated to a safe and sustainable state. 

• Financial Provision:

  Adequate financial provision for closure and post-closure activities is essential, but this can be challenging for mining companies, especially those facing financial difficulties. Robust financial mechanisms are needed to ensure that closure obligations are met. 

• Lack of Clear Communication and Engagement:

  Open communication and transparent processes are essential for building trust and fostering collaboration between mining companies, regulatory authorities, and local communities. Active engagement and meaningful participation of stakeholders are crucial for ensuring that closure plans are effective and sustainable. 

• Addressing Post-Mining Land Use:

  Closure plans should consider the potential for post-mining land use, including agriculture, forestry, recreation, or other sustainable development activities. This requires a comprehensive understanding of the site's environmental and socio-economic context and should be guided by local needs and aspirations. 

• Addressing Historical Impacts:

  Mine closure is an opportunity to address the legacy of mining activities, including past environmental damage and social impacts. This may involve remediation of contaminated sites, restoration of degraded ecosystems, and compensation for affected communities. 

• Adapting to Changing Regulations and Standards:

  Mining regulations and standards are constantly evolving, requiring mining companies to adapt their closure plans accordingly. This can be challenging, but it is essential to ensure that closure plans are compliant with current regulations and meet the highest standards of environmental and social responsibility. 

As demonstrated by the IGF survey, the state of readiness for mine closure is low as demonstrated by the fact that 24% of countries have no formal legal requirement to include a mine closure plan as part of their mine development. For those countries that do have this requirement in place, it’s overall enforcement and level of detail vary significantly.

Mine closure is still seen as a separate process from mining operations and as such, it cannot be fully integrated into the mining process and implement a “design backward” approach which is crucial for successful closure. On the environmental side, the mine closure plans are reviewed by the regulator (in countries where these plans are part of the regulatory process). On the social & economic impact side of things, the regulation in place remains vague, inadequate and full of gaps. The social aspect of the closure is thus lacking what is currently available and enforced on the environmental side.

Another major challenge of closing large mining operations is simply the very large costs associated with this task which affects both the environmental & social aspects of mine closure. In line with these high costs, it is essential to create multidisciplinary teams that will have the necessary subject-matter expertise to ensure the whole value chains is covered and the environmental & social impacts are properly taken into consideration. An expertise that is often lacking currently is professional logistics expertise.

Lastly, the challenge associated with the time required to obtain all of the key stakeholders’ perspective is highlighted. Ensuring that this is done at the onset of the project and throughout its life cycle also demands a sustained and important level of effort.

International standards (such as the ISO 21795 Mine Closure and Reclamation Planning Standard) provide important frameworks that emphasise early integration, adaptive management, and strong governance in the mine life cycle. Embedding closure planning into the full mine lifecycle, maintaining flexibility as conditions evolve, and co-developing viable post-mining land uses (such as the mountain bike park) with communities are highlighted as being essential. Combing these elements together helps shift closure from being a liability to an opportunity for environmental restoration and community resilience (providing the social licence to operate).

Another challenge is the lack of early engagement with stakeholders and Indigenous rights holders. Without a shared vision for post-closure land use, companies risk missing opportunities to build trust and deliver long-term benefits. The article emphasises that early planning is essential, yet many projects still treat closure as an afterthought and instead focus on the opening of a new mine.

Financial constraints also pose a challenge. Closure costs can reach billions, and unclear responsibilities between companies and governments often lead to poor mine closure practices. The article highlights that responsibilities are often unclear between mining companies and various levels of government. This ambiguity leads to planning gaps, especially when financial provisions are underfunded or rigid. Without clearly defined roles and shared accountability, long term closure outcomes remain uncertain and difficult to implement effectively.

Finally, the technical complexity of closure planning is also a challenge. Each site is unique, and balancing chemical and physical stability requires tailored, multidisciplinary approaches. The absence of integrated teams, including biodiversity, logistics, and social experts, makes it harder to design sustainable solutions that minimise future liabilities.

• Legacy of Fragmented and Short-Term Planning
  Historically, mine closure was treated as an afterthought, resulting in abandoned sites with lasting environmental and social impacts. Many operations still plan closure too late, limiting the integration of sustainability and community considerations.

• Regulatory Gaps and Unclear Accountability
  In many jurisdictions, especially in Canada, regulations around post-closure socio-economic transition are vague or inconsistent. This creates uncertainty around who is responsible for long-term community outcomes.

• Site-Specific Complexity
  Each mine site presents unique environmental, technical, and social conditions. Achieving both chemical and physical stability can be challenging, and solutions are rarely one-size-fits-all.

• Insufficient Interdisciplinary Collaboration
  Closure planning often lacks input from key disciplines such as social scientists, community planners, logistics experts, and Indigenous rights holders. This limits the potential for shared value creation and long-term community resilience.

• Financial Risk and Cost Escalation
  Closure costs for large mines can exceed $1 billion. Without early and adequate financial planning, reclamation and socio-economic transition efforts risk being underfunded, delayed, or compromised.

A major challenge is that mine closure and reclamation are often not considered early enough in the mine planning process. Many mining projects still treat closure as a separate, end-of-life event rather than an integral part of the mine’s lifecycle. This fragmented approach can result in missed opportunities to design for sustainability and shared value from the outset. Without early, high-quality planning, companies risk underestimating the complexity and cost of closure, which can lead to environmental harm and undermine trust with local communities.

Another significant challenge is the lack of clear and consistent regulations regarding post-closure socio-economic transition. In many jurisdictions, including Canada, requirements for planning the social and economic impacts of mine closure are vague or entirely absent. This creates confusion over who is responsible for supporting communities after a mine shuts down—whether it’s the mining company, local governments, or other stakeholders. The absence of robust regulatory frameworks can leave communities vulnerable and hinder efforts to ensure long-term benefits.

Effective integrated mine closure requires meaningful engagement with all stakeholders, including local communities, Indigenous rights holders, and a range of subject-matter experts. Historically, community perspectives have been considered too late in the process, resulting in plans that fail to address local needs and aspirations. Building shared value means involving stakeholders from the very beginning, developing a clear vision for the future of the land, and exploring opportunities for asset repurposing or new ownership models. This approach not only minimizes negative impacts but also maximizes positive outcomes, helping to build trust and a lasting legacy.

I see some of the key challenges for mine planning to benefit both the environment and the local communities to be:

• Developing and nurturing a shared common goal for what the future post mining looks like.

What I mean by this is that a mine developer/operator, the local communities, and the environmental requirements are all at odds with each other. A mining company wants to close a site with the lowest financial and time requirement possible. The local communities want to sustain or grow their level of economic prosperity that they achieve during mining operations. Environmental requirements strive to return the sites to a pristine environmental condition as was present prior to mining operations commencing. With these diverging perspectives, it is increasingly difficult to not only find common ground but to have all parties engaged and working towards a common goal of the what the future looks like in the region.

• Planning a closure transition process that allows for a gradual relinquishment of assets and land.

The sooner an area can be "reclaimed" - whether that means it is re-sloped and forested, cleared of any infrastructure, or opened to public access to use the land etc. - the more confidence there is in continued operations of the mine as well as on the outlook on the local communities and environment. With closure becoming more of an ongoing process throughout the life of mine, this allows for a steady and natural evolution of the communities in terms of jobs available, local expertise, land use changes, and development of alternative industries and commercial enterprise. If closure is only seen as a final state when the mining company is able to walk away from the whole property, this makes for a massive and immediate disruption to the entire region and will have irreversible effects to communities. The more that transition is moved into active mining phases, the easier the final state transition becomes.

Below some of the key challenges:

·       Traditional approach in the mining sector: historically, professionals in the sector have been more motivated to initiate new operations than to ensure a successful mine closure that creates value for all stakeholders. This is largely because mining has been primarily associated with the extraction of minerals, rather than with its broader economic and social potential to contribute to territorial development.

·        Short-term perspective: due to the high costs of postponing an operation, the process of obtaining social and environmental licenses has often focused on securing quick approvals to begin operations. This creates perverse incentives, prioritizing immediacy over long-term sustainability.

·        Fragmented management of the mining cycle: mining has traditionally been conceived and managed in separate phases, rather than through an integrated design that incorporates the visions, aspirations, and concerns of multiple stakeholders.

·        Regulatory and accountability gaps: although regulation has evolved, it remains weak in relation to mine closure. While aspects of remediation and reclamation have advanced in some countries, with requirements for periodic updates, regulation around closure and socioeconomic transition remains insufficient. This lack of clarity increases uncertainty about responsibilities in the process.

·        Limited multidisciplinary management: mine closure requires the participation of teams with diverse expertise—not only in technical and mining areas, but also in human rights, territorial development, social management, and economic transition. Without this multidisciplinary approach, mining operations and closures lack comprehensiveness, limiting the long-term value and legacy for local territories.

·        Weak incorporation of closure into territorial engagement agendas: there is still a perception that it is not relevant to discuss mine closure with local stakeholders, particularly in early stages. This limits opportunities to build trust, foster dialogue, and co-create a shared vision of the future. Bringing closure into the agenda from the start would allow for more robust operational strategies, adaptable over time, and strengthen sustained, positive relationships with stakeholders.

• Regulations for socio-economic transition post-closure are inadequate and inconsistent, even in countries like Canada. There are gaps in responsibility between companies and various levels of government, leading to uncertainty and lack of accountability.

Stakeholder Engagement and Shared Value

• Integrated approaches require multidisciplinary teams and genuine stakeholder engagement to create shared value and future opportunities for communities.

Socio-Economic Transition

• Socio-economic transition is often not considered early enough, resulting in insufficient time to plan, fund, and build capacity for communities to adapt to life after mining. Relying solely on community relations teams is inadequate; broader expertise is needed, including workforce transition and regional economic planning.

Environmental and Technical Complexity

• Achieving both physical and chemical stability of reclaimed sites can be challenging, and sometimes these objectives conflict. Each mine site is unique due to differences in geography, community, regulations, and mining methods, requiring tailored solutions.

Financial Risks and Cost Overruns

• Closure costs can be enormous (often in the billions), and poor planning leads to spiraling costs and financial liabilities. Upfront planning and funding are essential to avoid underfunded closure plans.

ESG Pressures and Reputation

• Environmental, social, and governance (ESG) issues are now the biggest risks for mining companies, with stakeholder opposition and environmental concerns causing costly project delays. Poor closure practices damage reputations and future opportunities for companies.

Building Trust and Legacy

• Progressive reclamation and transparent, adaptive management build trust with communities and regulators. Successful closure projects can help companies gain social license to operate and open future sites responsibly

• Regulatory gaps and inconsistencies between jurisdictions make it difficult for operators to understand their responsibilities, and for stakeholders (e.g. government and communities) to assess compliance with closure plans and regulations.

• Stakeholder engagement in the past focused on simple land remediation without concern for future economic development and land-use. This has led to mistrust and missed opportunities to develop the land in the best interest of affected communities.

• Financial risk and technical complexity. Since no two mine closures are the same, each situation must be carefully studied and planning must start as early as the project stage, before any impact to the land. Poorly developed plans risk environmental liabilities and prolonged monitoring.

• ESG Pressures and Reputation. Poor closure practices impact not only the reputation of the company in question, but the entire mining industry. The mining industry's past poor performance is a large part of why permitting and approvals are so slow now - governments and communities have built in safeguards to protect against repeating errors of the past. If the industry works towards a better reputation for responsible mine closure, it will help improve social license to operate.

1. Developing effective mine closure strategies that benefit the environment and local communities is challenging. Mining’s temporary impact on land requires careful planning from the start, balancing technical requirements for both chemical and physical stability. Conflicts often arise between these priorities, and every project faces different challenges depending on geography, community needs, regulations, and mining practices.

2. Effective project teams require flexibility and diverse expertise, including not just mining specialists but also professionals in biodiversity, social impact, human rights, and supply chains. Considering the full value chain is vital. Early inclusion of professional logistics, such as insights from military logistics, can significantly improve mine closure planning.

3. Integrated mine closure planning stands out for its proactive and flexible approach. It offers ongoing chances to enhance environmental, social, and governance outcomes throughout a mine’s life. Phased reclamation, for instance, reduces the mine’s footprint and builds trust with communities by showing commitment to sustainability. The key challenge is creating closure solutions that last and support both ecosystems and local residents well after mining ends.

A comprehensive mine plan should cover every phase, from development to closure, involve all stakeholders, and provide resources for environmental restoration and social transition.

• Industry buy-in on including mine closure into the early phases of the mine planning process

  • There is the potential for companies to incentive short-term gains without building in the appropriate processes / budgets at the beginning of the mine planning process to account for the longer-term aspects of mine closure

• Regulatory Inconsistencies

  • Differences in regulatory requirements have the potential to create vague and inconsistent outcomes for mine closure. Continued involvement of governments in mine closure working groups can build up the knowledge base of countries attempting to improve their mine closure requirements.

• Ensuring diverse perspectives are included in mine closure planning

  • Building the appropriate multidisciplinary team is important to ensure that the correct perspectives are included in mine closure from the beginning of mine planning phase. There also needs to be consideration of gaps in the team over time as the community evolves with the mine life / closure plan.

• License to operate

  • A company's license to operate is key to current and future success. Reputational damage due to poor mine closure practices has the potential to destroy trust and partnership with local communities.

Some of the key challenges include:

1. Insufficient Planning

   • Despite growing awareness, only 76% of countries have formal legal requirements mandating the submission of a mine closure plan. This gap in regulation often results in closure being treated as an afterthought, rather than an integral part of the mine’s lifecycle.

   • Poor planning can lead to:

     • Inadequate financial provisioning for rehabilitation and post-closure activities.

     • Reduced effectiveness of socio-economic transition strategies.

     • Erosion of trust with local communities, who may feel abandoned or excluded from future land use decisions.

2. Unclear Responsibility for Socio-Economic Transition

   • There is often ambiguity around the accountability and responsibility for supporting communities through the transition once mining operations cease - whether this be the mining organisation, community or various levels of government. This lack of clarity can stall progress and leave communities without the necessary support to adapt economically and socially.

3. Limited Social Transition Guidelines/Regulations

   • 41% of jurisdictions report having no formal requirements for addressing social impacts during mine closure. This regulatory gap means that community needs (such as employment, infrastructure repurposing, and cultural heritage) may be overlooked or inadequately addressed as part of post-closure activities.

4. Stakeholder Engagement in Early Planning

   • Engaging the right stakeholders during the mine planning stage is critical. Their input can shape realistic and inclusive post-mining land use plans, ensuring that closure outcomes align with community aspirations and expectations. It ensures that the post-closure is inclusive of key stakeholder feedback and providing socio-economic benefit.

5. Designing for Minimal Post-Closure Maintenance

   • Mine Closure Plans should ensure that sufficient activities are undertaken to ensure that remaining infrastructure, land or components do not require extensive long-term care. This reduces the burden on local governments or communities and enhances the potential for land to be safely and productively reused.

Many mining companies wait until the end of a mine’s life to think about closure. This makes it hard to prepare communities or design strong environmental solutions. Early planning is key to avoiding surprises and building trust.

·       Closure Planning Is Disconnected;

Closure is often managed separately from the mine’s overall strategy. This can lead to mismatched goals and poor coordination between environmental and social planning.

·       High Costs and Financial Risk;

Closing a mine can be extremely expensive. Poor planning can lead to delays, protests, and damage to a company’s reputation, which can cost millions per week in lost value.

·       Communities Are Not Properly Involved;

Local people and Indigenous groups are often not involved early in the process. Without their input, opportunities for shared value and trust-building are missed.

·       Every Site Is Unique;

No two mines are the same. Each site needs a tailored plan based on its location, community, and mining method. This makes closure planning more complex.

·       Missed Opportunities for Early Rehabilitation;

Some companies wait until the end to start restoring land. Doing it in stages during operations can reduce environmental damage and build community trust.

·       No Clear Plan for Land Use After Closure;

Closure often just means returning land to nature, but it could be reused for tourism, recreation, or business. Without a clear vision, these opportunities are lost.

·       Unclear Ownership After Closure;

It is often unclear who owns or manages the land and assets after closure. This can make it hard for communities to take over and use the site in ways that benefit them long-term.

·       To make mine closure work well for both nature and local communities, companies need to plan early, involve local people, and think beyond just shutting down operations. The article “Glory in Closing a Mine” says closure should be part of the mine’s overall strategy from the start, with experts from different fields working together. Land should be restored gradually, and there should be a clear plan for how it can be reused, like turning it into a park or business space. Rules should be clear, and each site needs a tailored approach. This helps build trust, reduce risks, and leave a positive legacy.

• For the mandated consideration: there are limited regulations requiring closure and post-closure planning during planning for a new mine, let alone ones that address post-closure and the inevitable socio-economic transition of the local community and economy.

  • Even when regulations do exist, there is ambiguity regarding who owns the responsibility for the closure and transition.

• For non-mandated, it seems there still needs to be a fundamental shift among mining companies in accepting and embracing the closure and post-closure elements as part of the overall mining life cycle, ideally embracing an integrated mine closure (or similar) that engages all stake and rights holders and goes beyond lip service.

  • Morally/ ethically, there is glory in closing in mine, as the article punchlines (look at Sullivan in Kimberley).

  • Economically, closure is cheaper and post-closure more efficient when planned for early.

  • Technically, more advanced and effective solutions can be developed when the dialogue starts at the beginning.

Early, fragmented planning often treats closure as a late, separate phase, which can limit sustainability. Embracing integrated, holistic planning from the very start is essential, though it's not yet a common practice. Regulatory gaps and inconsistencies can hinder effective closure, especially when it comes to socio-economic transition planning, with 41% of jurisdictions lacking specific requirements. Even in Canada, regulations tend to vary quite a bit.

Site-specific complexities, environmental, social, and logistical, require interdisciplinary expertise and adaptive strategies to find the right balance between stability and closure goals. Engaging meaningfully with stakeholders, including Indigenous groups and local communities, is crucial. Too often, this engagement is overlooked or delegated, which can lead to misaligned land use and economic transitions.

Closure costs can add up to billions; underfunding and poor logistics planning only increase these risks. Companies need to anticipate high standards and strict criteria to avoid damaging their reputation and finances. ESG pressures also heighten these risks: poor closure practices can lead to opposition, delays, and long-term harm to reputation, threatening future permits and investor confidence.

Proactive, interdisciplinary, community-centered planning from the very beginning of a project is key. It helps mitigate risks, build trust, and ensure lasting environmental and social benefits.

Community Trust and Social License
Gaining trust from Indigenous communities and other interest holders is a challenge for integrated mine closure due to poor closure legacies in recent history. Social license largely determines whether community members will be willing to readily participate in the planning process which is key to ensuring benefits to environment and communities long-term.

High Costs
The financial demands of integrated mine closure present on of the biggest challenges. Even if there is a good plan that balances environmental, technical, and community needs, proponents may run out of funding before they can fully implement the plan.

Regulatory Gaps
Vague or inconsistent policy in Canada means there isn’t a standard expected for environmental and community outcomes, and responsibilities of government and industry remain unclear.

Balancing Technical Objectives
Integrated mine closure needs to address both physical and chemical stability, but these goals can sometimes conflict.

Uniqueness of Each Site
Every mine is different, from geography and infrastructure to the local communities and regulatory environment. This makes it difficult to apply a consistent standard or lessons from other projects, as each integrated closure plan has to be carefully tailored to the mine site’s specific features.

Another problem is that frameworks like ISO 21795 are not being adopted by all regulators, and everyone seems to be trying to reinvent their own wheel. In my experience, it’s becoming even more fragmented in Canada, where First Nations boards are each developing their own closure regulations, and it confuses consultants and mining companies.

As the article mentions, existing gaps make things even harder. For example, there seems to be no clear mandate or national requirement setting a timeline for when companies must complete post-closure work and release the site back to the province or territory. Because of this, closure and post-closure activities often depend on the company’s financial situation in the last quarter, creating inconsistency and delays. The result is that the environment and society must wait even longer to get clean and safe land back.

Though the article is saying ESG performance, legacy, and reputation could be impactful on companies for closure planning, I do not find them impactful enough; sometimes other drivers play a more significant role, and that's where I think change is needed. As much as operations generate profit, closure should do too, and that happens through a change in the Mines Act, and ultimately, the mining business models.

Timing: One of the biggest challenges is timing. Closure planning often starts too late, which limits options for progressive rehabilitation and community transition.

Conflicting goals: I was also struck by the tension between environmental and social goals. For example, what’s best for chemical stability might not align with community land use aspirations. This makes engagement with rights holders and local stakeholders even more important. The idea of a “social licence to close” really resonated—closure needs to be co-designed, not just delivered.

This article raised a key question for me: How do we embed closure goals into operational decisions from day one, especially in areas like procurement and infrastructure design?

The article touched on a few key challenges:

- Closure planning not commencing early enough which doesn't leave enough time or space for successful closure (ie. Missed opportunities for early rehab, regional economic development etc).

- integrated Closure planning is still quite new, the ISO standards are fresh and it's a multi-disciplinary undertaking - its complex both because it hasn't been done for long, and by the nature of it too. Many jurisdictions around the world don't have formalised requirements for mitigating social impacts. I think it was 41% world wide only, that had formal requirements. Less than half! And I know in our situation, where there are regulations - they haven't been stress tested before. The government is learning at the same time as the mining companies because the expectations around closure from society, investors, governments at large are really relatively new in the scheme of mining on earth (the last 20-30 years) and in WA previous mine closures haven't needed to live up to these standards.

- It can be hard to find a balance where social objectives may be in conflict with environmental ones (the example given in the article - but it would also include any combination of objectives from engineering, cost, etc which would not always be mutually supportive).

- A key challenge I would add to this is costing it adequately. If the integrated and interdisciplinary plans are great, but the costing side of it is under-done, it will quickly raise challenges for funding the plan adequately, and actually getting to do it the way you planned.