MINE CLOSURE PLAN

What happens when a mine's production, after years of operation, is terminated due to the depletion of mineral resources? How can the social and environmental impacts associated with this process be mitigated? How can we ensure that the area is not abandoned and that the burden does not fall on society as a whole?

These and many other questions are related to the topic of "mine closure," which has been discussed and regulated within the mining industry for several years.

According to the Guide for Mine Closure Planning (IBRAM, 2013), "closure is understood as the moment, after the end of production, that marks the termination or conclusion of deactivation activities in a mine. Deactivation (also referred to as 'decommissioning') is the period that begins shortly before the end of mineral production (closure) and concludes with the removal of all unnecessary facilities and the implementation of measures that ensure safety and area stability, including environmental restoration and social programs. The post-closure phase is the period after the complete implementation of deactivation measures, during which actions such as monitoring, maintenance, and social programs are carried out to achieve closure objectives."

From a legal perspective, the subject is addressed in various regulations, such as the Federal Constitution (1988), Article 225, paragraph 2, and Federal Decree No. 9,406, which regulates the Mining Code.  

More specifically, on April 30, 2021, the ANM Resolution No. 68/2021 (Agência Nacional de Mineração) was published, detailing the rules for the preparation and presentation of the Mine Closure Plan, understood as a "set of procedures for decommissioning the mine area after mining activities, involving the demobilization of temporary structures supporting mining and beneficiation operations, the physical and chemical stabilization of permanent structures and their monitoring, as well as the preparation of the area for future mineral utilization or other purposes“.

In general terms, we can say that a well-planned and executed closure should consider environmental, social, and economic aspects from the initial stage of the mine, meaning that closure should be an integral part of the company's core business. Its "foundational principles" would include physical, chemical, ecological, and socio-economic stability.

In this regard, it is always important to emphasize that closure and post-closure commitments should be planned and implemented considering consultations with all relevant internal and external stakeholders, as well as making the necessary financial provisions. The company should monitor local socioeconomic development, and the closure plan should be updated whenever there are substantial modifications to the mine project or the surrounding conditions.