The term “environmental management” incorporates all the activities necessary to ensure that a mining project is designed, operated and closed in an environmentally sound and socially acceptable manner. The principles of good environmental management are:
• identifying all potentially significant adverse environmental impacts and social effects that would result without mitigation or control;
• defining control strategies to mitigate all potentially significant adverse impacts;
• implementing procedures to instigate control strategies in response to the unacceptable risk of adverse environmental impact;
• implementing procedures to review control strategies in response to performance evaluation; and
• implementing procedures to promote the benefits of any positive environmental or social impacts.
In the life cycle of a mining project it is common for the assessment of the social and environmental impacts to be carried out as a reactive study, once an economically viable mineral deposit has been proved and the mine project concept outlined. This is due to the nature of mining projects and their development and can result in the social and environmental issues being seen as an “after-thought”. In addition, the predictions contained in these assessments can alter completely if the original project design criteria, on which they are based, change. Both these issues may appear to detract from the role of the social and environmental impact assessments and minimize their effectiveness in the environmental management of the project.
The socio-economic impacts of a project are often the most complicated and least understood. It is imperative that when a mine closes it does not leave a social or economic void. On the other hand there is always a danger, especially in remote areas, of mining companies becoming surrogate governments. This must not be allowed to happen as it undermines the role of the real government and is liable to leave an even larger void in the region when the company pulls out.
The Government, at both the regional and national level, needs to work closely with the company and the local community to ensure that the socio-economic benefits of the project are sustainable; that they continue to exist long after the mine has closed. This includes such aspects as the stability of the population, quality of life, health, education, basic services and an economy independent of the mine. There are many ways to achieve these goals, but the solutions need to be chosen to suit the country and the region, and not taken from a recipe book. Ingredients have a tendency to vary from place to place.
The physical environmental effects of a project and the potential negative impacts are, by comparison, relatively easy to predict, monitor and remedy. Comprehensive baseline data, collected over a minimum period (usually 1 year), provide the basis for the environmental implications to be taken into consideration in the design of a project. The location of the actual mine is governed by the location of an economically viable deposit but this does not also have to govern the location of the associated infrastructure. No decisions should be made without close consultation with the community and socio-economic considerations, and final mine closure requirements should be part of the deliberations.
There are a number of environmental management instruments that contribute to the ability of the government and mining company to control and mitigate impacts. These include Environmental Impact Assessment (EIA), Socio-Economic Impact Assessment (SEIA), Environmental Management Plan (EMP), Environmental Monitoring Programme, Environmental Audit, Environmental Management System (EMS), Mine Closure Plan and Financial Surety.
The EIA/SEIA process (see Section 6.3 and 6.4) identifies the potential impacts, by the collection of baseline data, and helps the proponent and regulator prevent, minimize, mitigate or compensate for any adverse environmental and social impacts. The EMP (see Section 6.5) then presents the methods and procedures for achieving the desired environmental and social objectives while the Monitoring Programme (see Section 6.6) provides the evidence to prove that the objectives are, or are not, being achieved. An Environmental Audit (see Section 6.7) is an independent and systematic assessment of the overall environmental and social performance of the project and the EMP and Monitoring Programme. The EMS (see Section 4.1) is the instrument used to manage and improve the environmental performance of the company. Finally, the Mine Closure Plan (see Section 6.8) includes the decommissioning and rehabilitation programmes while the Financial Surety (see Section 3.3) provides the funds to pay for rehabilitation.
6.1 Mine Life Cycle
It is essential to closely link the requirements of environmental management with the project timetable and life cycle. The table below presents a standardized model of how the environmental and social aspects fit in to the project life cycle. For an EIA/SEIA to have a legitimate position in the decision-making process, the issues and implications will need to be established during the concept phase. To achieve this it is advisable to specify
that the timing of the EIA/SEIA process start as soon as a potentially economically viable deposit has been located.
The EIA/SEIA Process
The EIA/SEIA process, however, does not take into consideration the requirements for community consultation or the environmental impacts during the exploration phase. Although community consultation may not need to take place in any depth at this stage, the district or local government and local population should still be informed about what is going on and, where relevant, asked for permission for access. This can be achieved by public hearings for exploration licences, held on site, and instructions for the exploration geologists to communicate with the local people.
The environmental impacts become relevant once exploration moves from prospecting to larger scale sampling methods, such as benching, trenches and drill cores, with a corresponding increase in personnel. The judicious use of “good housekeeping” regulations and an EMP should be sufficient to provide adequate environmental protection during this phase.
6.2 Exploration
Exploration involves the collection of geological, geophysical and geo-chemical data to determine the mineral potential of an area. It is usually a temporary, minimal impact landuse activity, although it may leave visible traces, especially in dry areas, for many years. A proper commitment to environmental and social responsibility by the proponent should include consideration of the rights of other land-users and protection of the natural and cultural values of the area. New technology has reduced the environmental impact of exploration, enabling large areas of land to be evaluated by remote sensing methods, particularly during reconnaissance.
Good environmental management is an important part of any exploration programme. An EMP should be established where land disturbance occurs. This will normally apply only to advanced exploration, which is defined as meaning: “the excavation of exploratory shafts, adits or declines, the digging of test pits and trenches, and the associated removal of material for bulk testing from an exploration or mining licence area, the installation of a portable pilot plant or other temporary facility for ore and rock testing purposes, or any other significant ground disturbance conducted to determine the existence of a commercially exploitable mineral deposit”. However, even preliminary ground surveys are now expected to respect ecological integrity and pay attention to waste disposal issues. These requirements can be outlined in Good Housekeeping Guidelines.
The issues to consider in the preparation of an EMP for an exploration programme are contained in Appendix 3(a). The contents of an EMP should ensure compliance with environmental conditions on both the exploration licence/permit and any financing requirements. It is sometimes necessary for a financial surety to be established for advanced exploration, as a condition of the licence or permit, to ensure all disturbed land is fully rehabilitated.
6.3 Environmental Impact
Assessment and Statement
The Environmental Impact Assessment is the process by which environmental factors are integrated into project planning and decision-making in a way that is consistent with sustainable development. The EIA helps to protect the environment by looking at the likely environmental effects of a project and by providing the information that allows the developer to minimize these effects during construction, operation and decommissioning. Best practice EIA is the delivery of high quality information from the company to the community, the government and other decision-makers. It requires the developer to describe the proposal in its particular environment, to identify the potential impact on the environment and to describe how the company plans to manage those effects. The EIA can then be used as part of the decision-making process as to whether or not the project should go ahead and, if it does, what conditions should be attached.
The level of EIA depends on the nature of the proposal, its complexity, the local environment, its expected effects and the degree of controversy that the project might create. In best practice EIA the developer begins research early in the life of the project by the collection of baseline data. Community consultation, even during the exploration stage, can highlight potential areas of conflict and establish trust. These can then be developed during the scoping phase of the EIA when all the relevant issues that must be considered are identified. The findings of the EIA are then presented in the Environmental Impact Statement (EIS), the basic elements of which should include:
• introduction to the project;
• description of the site and its environment;
• the policy framework;
• description of the project;
• identification of the issues;
• management of impacts;
• evaluation of alternatives;
• assessment, monitoring and review processes;
• rehabilitation and closure plans; and
• commitments of the company.
The formal EIA/EIS process can be summarized as a logical sequence:
• referral of the project to the regulatory authority;
• government decision on whether an EIA is required;
• scoping of issues and community consultation;
• collection of baseline data;
• preparation of the EIS;
• regulatory authority and public review of the EIS;
• company response to issues raised by regulatory authority and public review;
• revised EIS;
• environmental approval (or refusal) with conditions;
• monitoring and reporting; and
• continuing liaison with community and government agencies.
Not all environmental assessments necessarily take the route of the formal EIA. For example, environmental screening for purposes of financing approval, sometimes undertaken by lending institutions, may take a simpler route, as will projects with a minor environmental impact. Invariably, however, the same evaluation criteria are used, as shown by the requirements of the Norwegian government (see the box below).
Example of evaluation criteria for assessments
Mining projects should be submitted to a more detailed assessment if they fulfil one or more of the criteria set out below, or if insufficient information is available, to answer “no” with a reasonable degree of certainty. Will the project:
• create substantial pollution problems and a risk of polluting land outside the actual mining area?
• create substantial waste disposal problems?
• create a risk of accidents that may have serious consequences for the local population and the natural environment?
• affect areas that support animal and plant life worthy of conservation or areas with particularly vulnerable ecosystems?
• lead to major changes in the landscape?
• affect areas with historic remains or landscape elements that are of importance to the population?
• change the way of life of the local population in such a way that it leads to a considerably increased pressure on the natural resource base?
• lead to major conflict with regard to existing land use and ownership?
• obstruct, or lead to substantial changes in, the local population's exploitation or use of natural resources other than those directly affected by the project?
Source: Environmental Aspects of Selected Non-ferrous Metals Ore Mining, UNEP IE/ILO, 1991.
The EIS is a valuable document to the mine operator and the regulatory authority, as it describes all the environmental aspects and issues of the site. It is a logical starting point in the process of optimizing the environmental performance of the operation. The EIS should be updated regularly as part of the EMS. The EIS should be made available to the local community and any other interested parties. Once the relevant authorities have approved the EIS, the findings and recommendations will then become part of the EMP.
6.4 Socio-Economic Impact Assessment
The Socio-Economic Impact Assessment (SEIA) can be carried out as part of the Environmental Impact Assessment process or can be done as a stand-alone study. The danger of it being done as part of the EIA process is that governments usually require the mining company to establish the terms of reference and carry out the work independently, and do not have an input until the report or statement is in a draft form. This could result in valuable knowledge and understanding of the country and the people not being included.
If the SEIA is done as a separate study it could again lose out by not including the physical environmental impacts that may have direct or indirect social consequences. Often the best solution is to establish a steering committee made up of representatives from the national and regional government, the mining company, the community, relevant NGOs and the EIA consultants (if used), to oversee the SEIA.
The socio-economic impacts are the outcome of the interaction between the characteristics of the project and the characteristics of the “host” environment. A consideration of the socio-economic impacts needs to clarify the type, duration, spatial extent and distribution of the impacts. This incorporates: what to include (direct vs. indirect impacts); for which period of time (exploration to closure and beyond); what area to cover (the boundaries of the impact zone); and who will be affected. The content of an SEIA should include:
• the demography and settlement patterns including potential changes due to relocation and migration;
• the land use systems and natural resource utilization, both terrestrial and aquatic, and the possible impacts;
• the cultural and social impacts, including business development, mine related payments, social disruptive influences and law and order;
• the health and nutrition status of the population and adequacy of health facilities and the potential for mine related changes;
• the education facilities and services, employment and income levels of the people in the immediate area of the project;
• the existing other services in the area (including transport, power, water, sewage, waste disposal, police, etc.) and the impact of the project on these services; and
• the influence of the payment of compensation for project-related environmental impacts and social disruption.
It is important to recognize the potential social impacts of mining operations on women and children, and to develop effective mitigation plans, or adjust appropriately. Gender analysis and planning can help identify such impacts. Gender analysis is the systematic examination of the roles, relationships and processes between women and men in all societies, focusing on imbalances in power, wealth, health and workload. Gender typically refers to the socio-cultural construction of roles and relationships between men and women.
It also takes into consideration existing social structures such as race, ethnicity, class and caste. Gender analysis is a useful means of assessing the potential differential impact of proposed mining initiatives and to understand processes for responding with informed and equitable options.
Health and well-being: mining operations can have notable impacts on the health and well-being of women. For instance, mining activities can lead to significant increases in sexually transmitted diseases. In addition, sexual harassment and increased incidences of violence against women in local communities by transient male mine workers is not uncommon.
Various forms of abuse of female partners and other family members frequently increase as a result of long-distance commuting of male mine workers. Effective gender analysis seeks to find strategic solutions to mitigate such negative gender impacts. Impact on women’s traditional roles: women are increasingly being recognized as important environmental caretakers. The International Development Research Centre states that: “women are crucial actors in biodiversity management in their multiple roles as farmers, herders, forest gatherers, primary health care givers, market vendors, selectors and preservers of seeds, soil conservationists and keepers of the natural and built environment”.
Since mining activities, by their very nature, impact the surrounding ecosystem, it is important to identify how mining operations may potentially affect women’s multiple roles in biodiversity management. Gender inequalities in the economic benefits: it is clear that mining can provide significant economic benefits to local communities in terms of direct employment, compensation and in the provision of secondary services. However, women may not necessarily share equally in these economic benefits. Mine operators need to address gender inequalities in the economic benefits of their activities.
6.5 Environmental Management Plan
The Environmental Management Plan (EMP) is the documentation of the methods and procedures by which the company will achieve the environmental objectives and targets. It also identifies the environmental performance indicators used to measure progress towards achieving those targets and objectives. The EMP should be based on the data and information compiled for the EIA/SEIA. It does not need to be overly detailed but should contain sufficient information for individuals to understand their duties and responsibilities.
The EMP should summarize the targets, objectives and regulations, nominate the individuals responsible and give target dates. Regular updates should record the status of the programme, showing progress on achieving the target or objective, or compliance with the regulations. Updates can also incorporate new targets or responsibilities and amendments to regulations. If an EMP is to be established for an operating mine it should be based on information generated from an environmental audit of the operation.
The EMP should provide for a means of adjusting to changes in government and corporate environmental regulations and requirements. It should also include an audit plan that incorporates a regular mechanism for checking the level of compliance with regulatory conditions and the environmental performance of all components of the operation. These procedures need to be structured to enable identification of areas where environmental improvements can and should take place and incorporate a mechanism for initiating an action plan to effect such improvements. The EMP, its targets and objectives, should also be in conformity with national environmental policies (See Appendix 3[f]).
For further details on establishing an EMP see Appendix 3 (g). The factors to consider in the preparation of an EMP for an exploration programme are included in Appendix 3(a). Environmental protection during exploration is covered in detail in Environment Australia's booklet, “Onshore Minerals and Petroleum Exploration”, listed in the bibliography in Appendix 10.
6.6 Environmental Monitoring Programme
The aim of the Environmental Monitoring Programme is to assess the environmental and social performance of the project and to demonstrate to the regulatory authority and the community that the operation complies with the objectives established by the EIA/SEIA process. It provides the information required for periodic review and alteration of the EMP, ensuring that environmental and social protection is optimized at all stages of the development.
In this way, undesirable impacts will be detected early and remedied effectively. The Monitoring Programme also demonstrates compliance with regulatory requirements. The key issues for an Environmental Monitoring Programme are to:
• develop improved practices and procedures for environmental and social protection;
• detect short- and long-term trends;
• recognize environmental and social changes and enable analysis of their causes;
• measure impacts;
• check the accuracy of predicted impacts;
• develop improved monitoring systems; and
• provide information on the impact of the mining project.
The schedule for an Environmental Monitoring Programme should be set up so that it is simple to operate and will provide data that can be directly utilized by the company and the regulatory authority. The box below gives the framework for the design of Environmental Monitoring Programmes as outlined in Environment Australia's booklet, “Environmental Monitoring and Performance”.
Framework for Design of Environmental Monitoring Programmes
• Identify the scope of monitoring and list the sub-programmes corresponding to each environmental issue of the EMP.
• Define the objectives for each monitoring sub-programme.
• Specify how information collected will be used in the decision-making process.
• Define the spatial and pathway boundaries for the work and select, map or plan scales and sites for observation, measurement or sampling.
• Based on appropriate characterization studies, select the key indicators for direct measurement, observation or sampling.
• Define how the data will be analyzed and interpreted and how it will be presented in the monitoring report.
• Define required precision and accuracy in the data.
• Consider compatibility of the data to be collected with historical data and with contemporary related data.
• Set minimum requirements for monitoring air, water, discharges, biological systems, etc.
Source: Environment Australia, “Environmental Monitoring and Performance”.
Appendix 3(g) contains a general guideline for an Environmental Monitoring Programme that focuses on the physical aspects of monitoring. The results of the Environmental Monitoring Programme are usually reported to the regulating authority on a weekly, monthly, quarterly or annual basis, depending on the environmental permit conditions. The authorities are increasingly relying on regular reporting of monitoring results, including any non-compliance or unusual incidents, rather than frequent inspection by their own staff. Where monitoring indicates that environmental parameters are exceeding statutory levels, for example contaminant or sedimentation levels in the natural aquatic environment, a planned response should be determined and set in place to effectively control any adverse effects. Each monitored parameter should be linked to a contingency plan to enable corrective measures to be taken and the department or position responsible for the measures should be identified.
6.7 Environmental Audit
In the context of the environmental management of a project, an Environmental Audit assesses the environmental and/or social performance of an existing operation. It is a method of ensuring compliance with regulatory requirements and of guaranteeing that the performance complies with stated policies and objectives. An Environmental Audit can be carried out for an existing project whether or not it has an EIA/SEIA. Many of the tasks performed for an Environmental Audit are equivalent to those of an EIA/SEIA and so the scope is similar.
A succinct definition of an Environmental Audit is given in the box below.
What is Environmental Auditing?
Management tool: the audit is not an end in itself, but serves to facilitate management control of environmental practices.
Systematic assessment: auditing involves a structured approach following an established protocol.
Periodic: audits are conducted periodically in relation to the overall review process.
Documentation: an audit results in a written report.
Environmental risk: audits highlight environmental risk faced by a company, and should recommend action to minimize risk.
Compliance: some compliance assessment is part of every audit, although the degree to which strict legal compliance is assessed is determined by the audit objectives.
Objectivity: while there is some acceptance of self-auditing for internal review, there is a distinction between such self-assessment and verified independent auditing. Auditors are generally independent of the organization being audited.
Source: Environment Australia, “Environmental Monitoring and Performance”.
Environmental Audits are conducted on the basis of pre-designed, site-specific audit protocols that can take the form of checklists, questionnaires, written guidelines, rating systems and specific questions. A typical Environmental Audit for a mining operation would include the consideration of site conditions, regulatory compliance, potential liabilities, environmental management structure and environmental reporting procedures. The table of contents of the EMP provides a handy and logical checklist for audit purposes.
In addition to general environmental management audits, there are a number of other audits that may be undertaken, although the distinction between each type is relatively arbitrary and there is considerable overlap.
Environmental Management System Audit: for those companies with a formal EMS in place. This audit reviews both the technical and organization aspects of the EMS.
Compliance Audit: to demonstrate compliance, or otherwise, with environmental legislation, regulation, licences, approvals and other documentation, including the corporate environmental policy, and commitment to industry codes, charters and principles that the company has signed.
Technical Process Audit: to determine whether a particular process or operation is having a detrimental effect on the environment. These audits may focus on energy, waste, pollution or site conditions. Environmental Liability Audit: may be requested by potential purchasers or by financial institutions when considering investment or acquisition.
6.8 Mine Closure Plan
Mine closure can have a negative impact on both the physical environment and the socioeconomic structure of the region. An important aspect of mine planning is the rehabilitation of disturbed lands to a stable and productive post-mining land form, which is suitable and/or acceptable to the community. Of equal or greater importance is the socio-economic rehabilitation of the community, thereby ensuring that the benefits of the project are sustainable. The physical and social rehabilitation programmes should be an integral part of the life cycle of the mine.
Before starting any physical mine site rehabilitation, closure objectives and a detailed plan of action need to be established. The essential goal of site rehabilitation is to return all affected areas, as near as possible, to their optimum economic value. This does not always involve returning a site to its original state or use. The main aims of site rehabilitation are to reduce the risk of pollution, to restore the land and landscape, to improve the
aesthetics of the area, to prevent further degradation and to provide for future economic use. Through consultation with relevant interest groups, including the regulatory authority, traditional owners and private owners, the mine operator can establish the required future land use for the different physical components of the project.
Mine closure and rehabilitation can be divided into three main stages, though the boundaries between these stages are often difficult to distinguish and in some cases “active care” may need to continue for several decades, or even in perpetuity. The three stages are:
• The Planning Stage: a rehabilitation plan should be established and integrated into the mine plan and environmental management plan or system at the earliest possible opportunity and regularly updated during the operating life of the project.
• The Active Care Stage: the active care programme immediately follows the cessation of activity in a specific area, i.e.: the closure of a waste rock dump, or the total cessation of mining.
• The Passive Care Programme: the passive care programme is a period of sampling and monitoring designed to demonstrate that the active care programme has been successful and that a “walk-away” state has been achieved.
In many countries local communities, and to a lesser extent governments, will have little information about the development of a mining project. The introduction of a cash economy, contributed to by employment, compensation, royalties and spin-off businesses, can upset the local balance, and ultimately the culture, of the region. Often the mine is the only source of direct employment in the area and also supports the local economy and indirect employment. The closure of a mining project, if not carefully planned, is likely to have a
severe negative impact on the socio-economic status of the community by the sudden removal of this major financial provider with nothing to take its place.
The socio-economic aspects of closing a mine should take into consideration the workforce, the community that has become established because of the mine and the local community who were in the area before the advent of the mine. To try to lessen the blow the mining company needs to work with the local community and government to establish strategies for supporting these communities from the conception of the project.
Consultation should be aimed at establishing a development plan for the region that takes into account the continuation of essential services such as medical care, schools, etc., and the identification of self-sufficient industry, which need to survive after the mining company has left. The tables contained in Appendix 3 (h) outline the issues, objectives and methods of control that need to be considered for mine closure.