Environmental Impact Assessment Review 82 (2020) 106366

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Environmental Impact Assessment Review

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Evaluating the effectiveness of integrating the environmental impact T

assessment and mine closure planning processes
⁎
Rebecca Gettya, , Angus Morrison-Saundersb,c
a
SRK Consulting (Australasia) Pty Ltd, Perth, Australia
b
Edith Cowan University, Perth, Australia
c
North West University, South Africa

A R T I C LE I N FO A B S T R A C T

Keywords: Integration of environmental assessment tools has long been promoted as best practice with the potential to
Environmental impact assessment bring environmental benefits. In this research, we set out to evaluate the effectiveness of integration of en-
Integration vironmental impact assessment (EIA) and mine closure planning using a simple effectiveness criteria framework,
Mine closure planning applied to current regulatory provisions and practices in Western Australia. The effectiveness criteria for the
Effectiveness
integration of EIA and mine closure planning, compiled from existing reviews of integration and effectiveness
concepts in the impact assessment literature, considers procedural, transactive, substantive effectiveness and
overall process legitimacy. Data analysis consisted of a literature review, examination of regulatory and gui-
dance material and interviews with 12 experienced EIA and/or mine closure practitioners with an industry or
regulatory focus. The results provide strong, positive examples of procedural, transactive and substantive ef-
fectiveness due to the integrated framework. These include behavioural changes, improved knowledge and
learning and better provision for closure at an early stage of mine planning. A trajectory of improvement was
noted by everybody interviewed. However, a key driver for effectiveness is the enthusiasm of key facilitations,
and tension exists due to the different motivations of the two lead regulatory agencies which poses a challenge
for the integrated framework. While it can reasonably be argued that the effectiveness of early mine closure
planning cannot yet be realised, due to a paucity of completely closed mines in Australia this study nevertheless
demonstrates clear benefits and opportunities result from early stage integration of EIA with mine closure
planning.

1. Introduction
Taking an integrated approach to environmental impact assessment
(EIA) has long been identified as an element of best practice (IAIA and
IEA, 1999) essential for achieving sustainable development outcomes
(Gibson, 2006; Hacking and Guthrie, 2008), and thus also an important
consideration for effectiveness (Chanchitpricha and Bond, 2013). In-
tegration can mean many things (Scrase and Sheate, 2002; Hacking,
2019), a topic we return to later. For now, inspired by the Cambridge
dictionary definition of integration to combine two or more things in order
to become more effective (https://dictionary.cambridge.org/dictionary/
english/integration), our focus mainly concerns the integration of dif-
ferent regulatory instruments for environmental protection. Specifi-
cally, we investigated the integration of EIA with mine closure plan-
ning.
Mine closure planning is undertaken to avoid, minimise and
mitigate the potentially adverse impacts of resource extraction and has
become increasingly important internationally in recent years (Mining,
Minerals and Sustainable Development [MMSD], 2002; Parshley et al.,
2009; Franks, 2015; International Council on Mining and Metals
[ICMM], 2019). The requirement to plan for mine closure was first le-
gislated in the USA in 1977 with the Surface Mining Control and Reg-
ulation Act (SMCARA) and by the end of first decade of this century,
there was some form of mine closure regulation in at least 50 countries
and the general principles of mine closure had become internationally
recognised and formalised (Clark and Clark, 2005; ICMM, 2008). As the
significance of adverse environmental, social and economic legacies
have been exposed (Asia-Pacific Economic Corporation [APEC], 2018;
Environment and Communications References Committee, 2019;
European Commission, 2018), international guidance from industry,
research and governments has continued to evolve. It is timely for re-
search that seeks to understand and evaluate how mine closure

⁎
Corresponding author at: SRK Consulting (Australasia) Pty Ltd, 1/10 Richardson Street, West Perth 6005, Australia.
E-mail addresses: rgetty@srk.com.au (R. Getty), a.morrison-saunders@ecu.edu.au (A. Morrison-Saunders).

https://doi.org/10.1016/j.eiar.2020.106366
Received 25 September 2019; Received in revised form 23 January 2020; Accepted 23 January 2020
0195-9255/ © 2020 Elsevier Inc. All rights reserved.
R. Getty and A. Morrison-Saunders
planning is performing in practice.
Numerous similarities exist between EIA and mine closure planning
as documented in Morrison-Saunders et al. (2016). At the most funda-
mental, both provide a framework for the identification and analysis of
risk in complex environmental systems to prevent significant irrever-
sible harm from a project development. Both should commence early in
the investigation and planning stage and be progressively refined with
iterative, adaptive reviews, and as such ‘the two processes should
proceed hand in hand’ (Morrison-Saunders et al., 2016, p118), meaning
that appropriate integration of the two regulatory processes should be
evident.
This research builds on the foundation established by Morrison-
Saunders et al. (2016) who provided an initial account of the integra-
tion of EIA and mine closure planning in Western Australia (and else-
where) based in the main upon comparison of the legal frameworks for
both processes. Our aim for this research was to evaluate the effec-
tiveness of practices for integrating EIA and mine closure planning
processes in the Western Australian context.
The effectiveness of early mine closure planning as a process is re-
latively unexplored in the academic literature and discussion is typi-
cally restricted to conference proceedings, industry publications and
discipline-specific technical journals. As far as we are aware, this is the
first study to explore the integration of the regulatory processes of EIA
and mine closure planning with regard to the perceived effectiveness of
practice.
2. Research design and methods
Our research design and methods were comprised of two key
components: (i) understanding the theoretical foundation underpinning
the concepts of integration and effectiveness based on a review of lit-
erature; and (ii) data collection and analysis based on interviews with
experienced EIA and/or mine closure practitioners and examination of
Western Australia's regulatory and guidance material for EIA and mine
closure planning.
2.1. Theoretical foundation: Integration and effectiveness concepts
In the field of EIA, there is already a well-established body of lit-
erature available that addresses the concepts of integration and effec-
tiveness. It was not our intention to repeat reviews and analyses of these
concepts. Our starting point was to focus upon works that had reviewed
the theoretical literature and had distilled classifications of integration
and effectiveness. Because these works were directed specifically to-
wards impact assessment practice, it was then necessary to interpret
and extract aspects relevant to evaluating mine closure planning.
A comprehensive review of the concept of integration by Scrase and
Sheate (2002) identified 14 ‘meanings of integration in environmental
assessment and governance’ (p278). Of particular relevance to our re-
search is their notion of ‘integration among assessment tools’ (p285)
which was identified to have the potential to be ‘environmentally po-
sitive’ (p290) and relevant in terms of how the processes of EIA and
mine closure planning can be brought together in a united approach.
Here, the key goal is the sharing of common tasks to reduce duplication
of effort and improve efficiency (Lee and Kirkpatrick, 2006; Canter and
Atkinson, 2010). Potential pitfalls to effective impact assessment in-
tegration result from the complexity of integrating multiple assess-
ments, such as inefficiency, poor collaboration, or an unbalanced as-
sessment with some issues masked by the promotion of others
(Geneletti, 2014; Sánchez, 2014; Dendena and Corsi, 2015). Scrase and
Sheate (2002) note that different assessment processes likely stem from
‘different disciplinary and practical origins’ (p285) which in practical
terms may simply extend the scope rather than integrating the assess-
ment, and points to another meaning of integration in terms of dealing
with ‘integrated information resources’ (p277).
Four other meanings of integration identified by Scrase and Sheate
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Environmental Impact Assessment Review 82 (2020) 106366
(2002) have relevance to our investigation of EIA and mine closure
planning. The notions of ‘integration of environmental concerns into
governance’ (p279) and of ‘integration of assessment into governance’
(p286) arguably represent underlying goals of both EIA and mine clo-
sure planning alike. In other words, it is about thinking about en-
vironmental consequences before making decisions and taking action
(Morrison-Saunders, 2018) so as to deliver substantive environmental
protection outcomes through good governance. ‘Integration of the en-
vironment, economy and society’ (Scrase and Sheate, 2002, p282) is the
basis of sustainability assessment and relates to the comprehensiveness
of the coverage of an assessment process (Hacking and Guthrie, 2008;
Hacking, 2019). In part, this is about “how ‘environment’ – that is, the E
in EIA – itself is defined” (Morrison-Saunders, 2018, p8). EIA and mine
closure planning share principles and procedures and both are decision-
making tools that aim to minimise environmental harm and promote
sustainable development (Dipper et al., 1998; Glasson et al., 2005;
ICMM, 2019; Pope et al., 2013; Boerchers et al., 2018). Thus, this form
of integration is implicit in both processes. Finally, Scrase and Sheate
(2002) discuss the ‘integration of stakeholders into governance’ (p284)
where they advocate for ‘wider participation’ involving a ‘diverse range
of actors’ (p284). This invites consideration of the full spectrum of
public participation that might be utilised in EIA and mine closure
planning (Morrison-Saunders, 2019). Given that effective engagement
with stakeholders is a core principle of EIA and mine closure planning
alike (IAIA and IEM, 1999; ICMM, 2019), this form of integration is also
an implicit component of both processes.
Effectiveness has been extensively explored in the EIA literature
since the pioneering work of Sadler (1996) with many iterations that
refer to a multitude of contexts, including philosophical, psychosocial,
practical, strategic and project specific (Elling, 2009; Cashmore et al.,
2010; Chanchitpricha and Bond, 2013; Bond and Morrison-Saunders,
2013). It is beyond our scope to review the various debates on effec-
tiveness here. Instead we focus on the work of Pope et al. (2018) who
provides one of the most recent reviews of the concept, from which they
derived a simple framework of effectiveness comprising of four ele-
ments with test questions as follows (p43):
• Procedural effectiveness – Have appropriate processes been fol-
lowed that reflect institutional and professional standards and pro-
cedures?
• Transactive effectiveness: To what extent, and by whom, is the
outcome of conducting the assessment considered to be worth the
time and cost involved?
• Substantive effectiveness: To what extent does the assessment lead
to changes in process, actions, learning or outcomes?
• Legitimacy: Was the assessment process perceived to be legitimate
by a wide range of stakeholders?
These four overarching effectiveness elements have subsequently
been adapted by Chanchitpricha et al. (2019) into a suite of 26 detailed
sub-criteria (too extensive to list here) that they tailored for application
to evaluation of strategic environmental assessment practice. Here we
focus on points salient to the early stages of mine closure planning and
more specifically to integration with EIA processes.
At this point, it is important to note that effectiveness studies, such
as those of Pope et al. (2018) and Chanchitpricha et al. (2019) typically
undertake their evaluations after processes have run their course (i.e.
ideally once development has taken place and the long-term con-
sequences and outcomes can be realised). Our investigation of the EIA
and mine closure planning processes in Western Australia has been
undertaken at a relatively early stage in the existence of a formal in-
tegrated approach as the underpinning legislation only came into effect
in 2011, as we explain later. Only a very small number of mine sites in
Western Australia have progressed to relinquishment and only one
complete operation has actually attained full relinquishment status to
our knowledge (Bottle Creek, relinquished in 2001 (DIIS, 2016)). None
R. Getty and A. Morrison-Saunders
have been relinquished that were established under the terms of the
current integrated approach to EIA and mine closure planning as many
mining operations have a life of many decades. Despite this apparent
limitation in our research design, we maintain that mine closure plan-
ning is specifically intended to be a dynamic ongoing and adaptive
process. In this context, elements of these types of effectiveness can be
understood even for relatively early stages of the closure planning
process and its degree of maturity in the Western Australian context. It
is also important to understand what is or is not effective in current EIA
and mine closure planning practices regarding their integration to ap-
propriately guide ongoing practice. Waiting only until after mines are
fully closed and relinquished would ignore this potential learning and
the benefits that might be realised.
In light of these characteristics of mine closure planning, we ex-
amined the effectiveness concepts expressed by Pope et al. (2018) and
Chanchitpricha et al. (2019) in the context of the previously discussed
meanings of integration from Scrase and Sheate (2002). We chose to
adopt a simplified approach that falls somewhere between the high-
level overarching questions of Pope et al. (2018) discussed previously
and the 26 specific sub-criteria of Chanchitpricha et al. (2019). This is
because we found that similar to previous evaluations of the concepts of
integration and effectiveness, the details of individual components can
be addressed in multiple ways. For example, several topics featured
within the criteria of Chanchitpricha et al. (2019) appear for more than
one of the four effectiveness elements. Allocation or specification of
practitioner roles is a consideration in their criteria for both procedural
and transactive effectiveness, while the arguably related notion of
collaboration between stakeholders features as a sub-criterion for sub-
stantive effectiveness. Each of these topics could be relevant to the
Scrase and Sheate (2002) notion of integration of stakeholders into
governance. To avoid repetition and over-complication, we devised a
simple framework for evaluating the effectiveness of integrating EIA
and mine closure planning that relegated each topic into just one of the
four effectiveness elements as follows.
2.1.1. Procedural effectiveness
An effective integrated EIA and mine closure planning process re-
flects relevant institutional and professional standards. The jurisdic-
tional regulatory context of the assessment is important, as with other
forms of impact assessment (Marsden, 1998; Runhaar and Driessen,
2007). As Pope et al. (2018) note, an assessment against international
standards may be unfair to proponents operating in compliance and
within the bounds of local regulation and societal norms.
2.1.2. Transactive effectiveness
An effective integrated EIA and mine closure planning process is
worth the time and cost involved. Implicit here is the availability of
sufficient personnel with the necessary skills (Chanchitpricha et al.,
2019) undertaking the process. Notwithstanding that financial and time
frames may be specified in regulations, it is also noted that an eva-
luation of transactive effectiveness is dependent on the perceptions of
key stakeholders, especially regulators and proponents.
2.1.3. Substantive effectiveness
An effective integrated EIA and mine closure planning process leads
to changes in process, actions, learning or outcomes. It is an adaptive
process intended to continually evolve and mature. In terms of early
mine closure planning this can also be described as achieving it's in-
tended outcomes including both project specific and wider learning
(Pope et al., 2018). Although it is not yet possible in the time since the
integrated framework was implemented to determine the success of
rehabilitation and closure as a result of early mine closure planning, the
integrated process is intended to force early consideration of mine
closure with ongoing evolution and maturation as the planning process
advances towards the ultimate end point of relinquishment (ICMM,
2019).
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Environmental Impact Assessment Review 82 (2020) 106366
2.1.4. Legitimacy
An effective integrated EIA and mine closure planning process will
be perceived to be legitimate by a wide range of stakeholders. Using the
rationale of Pope et al. (2018) this includes normative effectiveness
such as sustainability, transparency and meeting stakeholder expecta-
tions, as moderated by pluralism and the power of diverse political and
ideological views.
2.2. Document analysis and interviews
Our methods for data collection were based on an initial review of
international and Australian EIA and mine closure literature and an
analysis of mine closure legislation and regulatory guidance doc-
umentation in Western Australia. This was used to explore the in-
tegrated process and effectiveness of early mine closure planning and
guide the composition of interview questions. Semi-structured inter-
views were conducted with a sample of 12 professionals comprised of
four industry-based environmental managers, four consultants and four
regulators (from three regulatory departments, Environmental
Protection Authority (EPA), Department of Mines, Industry Regulation
and Safety (DMIRS) and Department of Water and Environmental
Regulation (DWER)) with at least nine years' experience in EIA and/or
mine closure planning. We decided to pose simple open-ended inter-
view questions to allow unconstrained exploration of the interviewee's
perceptions regarding how influential EIA is to mine closure planning
(and vice versa), how they view the integrated assessment process in-
cluding what they considered to be effective for early stage project
planning and what could be better integrated in practice. These were
supplemented by unscripted probing questions to stimulate further
discussion or obtain more detailed information (Leech, 2002; Saunders
et al., 2009).
Interviews were audio recorded and transcribed to enable coded
thematic analysis using NVivo 12 Plus software using both a top down
deductive approach based on the generic research questions and themes
of effectiveness, and a bottom up inductive approach to identify re-
curring themes that ‘represent some level of patterned response or
meaning within the data set’ (Braun and Clarke, 2006, p82). Coding
was a recursive process and interviews were revisited for coding mul-
tiple times. The interviews were a rich source of data. Over 74,000
words were transcribed, with the length of individual interviews ran-
ging from 3000 to over 10,000 words.
Participants were recruited by convenience and snowball sampling
with a focus on obtaining a range of opinions from professionals with
the most experience in the application of mine closure regulation for
preliminary evaluation. The small, opportunistic sample was not in-
tended to be representative of the wider community of EIA and mine
closure practitioners operating in Western Australia. Only environ-
mental managers from mid-tier companies were interviewed and the
views of environmental managers employed by multinational or junior
companies are likely to have different views. Only one site environ-
mental manager was interviewed due to constraints of time and loca-
tion and the rest were corporate managers. Despite the small sample
size, analysis of knowledge saturation from qualitative interviews (e.g.
Guest et al., 2006; Namey et al., 2016) indicate identification of
80%–92% of themes within 12 interviews, dependent of heterogeneity
of the sample group and the interview questions (Guest et al., 2006). A
detailed profile of interviewees is not provided here in accordance with
conditions in the ethics approval for this research.
3. Results
Before presenting the interview findings, it is important to place the
context of the regulatory framework in perspective. This is especially
important for understanding procedural effectiveness as indicated ear-
lier in our framework for evaluating the effectiveness of integrating EIA
and mine closure planning.
R. Getty and A. Morrison-Saunders
3.1. Regulatory context
The primary environmental approval required for implementation
of a proposed mine in Western Australia arises under the provisions for
EIA in Part IV of the Environmental Protection Act 1986 (EP Act) which is
administered by the EPA, an independent statutory authority who
provides advice to the Minister for the Environment. The EPA de-
termine if a proposal is likely to have a significant adverse effect on the
environment and must therefore undergo a formal EIA process. The EP
Act prohibits any other regulatory approvals from being granted until
the Minister for the Environment has been decided if a proposal should
proceed and a Ministerial Statement of approval is then issued.
The Mining Act 1978 (Mining Act) is the governing law in Western
Australia for mineral exploration and extraction activities and is ad-
ministered by the DMIRS (previously known as the Department and
Mines and Petroleum, or DMP). Minerals are generally owned by the
State and under the Mining Act a Mining Proposal must be approved by
DMIRS before operations can commence. Where a formal EIA is re-
quired, a Mining Proposal cannot be approved until a Ministerial
Statement has been issued. DMIRS are also the regulatory authority for
safety, compliance and environmental management, regulation and
rehabilitation of resource activities.
Amendments to the Mining Act which became effective in 2011,
aimed to improve regulatory transparency and compliance with mine
closure planning requirements (Minister for Mines and Petroleum,
2012), which until then had been principally managed by approval
conditions and contractual obligations. The changes require that a Mine
Closure Plan (MCP) is approved alongside every Mining Proposal and
bestowed legal status (Mining Act, s70O) on guidance co-authored by
the EPA and the DMIRS. The co-authored guidance, the ‘Guidelines for
Preparing Mine Closure Plans’ (DMP and EPA, 2011, revised 2015) state
that a MCP must be submitted with documents provided for the EIA
(under s40 of the EP Act), and that a revised MCP is submitted and
approved at a minimum of every three years. The aim is to leave a safe,
stable non-polluting environment that is ecologically sustainable fol-
lowing closure (DMP and EPA, 2015). We note that these guidelines are
currently under review. The MCP process aims to promote effective
mine closure planning through early and ongoing consideration to re-
duce the financial, environmental and social liabilities to the State that
accompany unplanned mine closure. By this mechanism, closure plan-
ning has thereby been formally integrated with EIA at the project ap-
proval stage in Western Australia. Further collaboration between the
two lead agencies is supported by a Memorandum of Understanding
(MoU) which aims to eliminate duplication of effort.
The changes to regulatory processes to integrate EIA and mine
closure planning coincided with reforms in financial securities for mine
rehabilitation through the passing of the Mining Rehabilitation Fund Act
2012. This regulatory reform represented a fundamental change from
the use of individual bonds which were subsequently refunded to the
mining companies, to a central Mining Rehabilitation Fund which is ‘a
pooled fund, with revenue into the fund generated by contributions
through annual, non-refundable compulsory industry levies upon te-
nement holders according to the environmental disturbance existing on
a tenement’ (Gorey et al., 2016, p374). Interest earned on the accu-
mulated fund is used to fund the rehabilitation of historical abandoned
mine sites.
3.2. Interview findings
We compared common themes identified from the coded analysis of
interview responses and assessed these in terms of our framework for
evaluating the effectiveness of integrating EIA and mine closure plan-
ning. Evidence in support of effectiveness and aspects that could be
improved were identified and exemplary quotes have been provided in
the following sections in italics.
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Environmental Impact Assessment Review 82 (2020) 106366
3.2.1. Procedural effectiveness
A regulatory framework clearly exists for an integrated EIA and
mine closure planning process in Western Australia. The common gui-
dance provided by DMP and EPA (2015), hereafter simply the ‘Guide-
lines’, describes a performance standard and identifies the different
roles of the proponent and the relevant decision-making authorities.
These local prescriptions are consistent with international views sug-
gesting that integration occurs best when managed by key, driven fa-
cilitators (Sroufe, 2017), and the ICMM guidance (2019, p64) empha-
sises the importance of a closure champion to lead and engage the
closure process.
A MCP must be approved by the lead authorities as part of the in-
tegrated EIA process and prior to development of a proposed mine
thereby upholding local standards. As one environmental manager said:
if you don't have that as an absolute minimum, you get knocked back. The
common guidance and regulatory collaboration which is supported by
the MoU between the lead agencies were viewed by the regulators as
essential for the effective evaluation of mine closure risks within the
integrated EIA process. Not only does the integrated process promote
early consideration of mine closure, but mine closure can also feed back
into the EIA with closure specific conditions. As one regulator put it: if
there is a biodiversity issue that sits [beyond DMIRS assessment of safe,
stable and non-polluting], then the EPA considers if additional conditions
[should be recommended].
Every interviewee believed that the most important outcome of the
integrated framework when considering the effectiveness of the process
was that it forces early consideration of mine closure and promotes the
early development of more rigorous [mine closure] plans. It allows reg-
ulators to have an overview of closure planning at the beginning of the
life-cycle of a mine and therefore helps minimise the problem of le-
gacies that are only realised later, which has implications for sub-
stantive effectiveness as well. This also feeds back into a more holistic
assessment at the EIA stage. As one regulator said: why would I allow you
to open hole in the ground if you didn't have any clue how you were going to
close it?
However, issues were identified by all the consultants that stem
from the different motivation and therefore a mismatch or lack of con-
sistency between the two lead agencies. The EPA was noted to have a
more strategic and conceptual focus regrading environmental legacy
whereas the focus of the DMIRS is on operational feasibility and fi-
nancial liability. One consultant said: In theory they are [integrated], in
practice they're not… It should flow through, but it doesn't… That's a failure
of the framework and it just needs to be tweaked. The focus of the DMIRS,
as an agency whose activities also include promotion of mining as well
as environmental regulation under the Mining Act was also raised as an
issue by one consultant as the fox managing the hen house. This suggests a
lack of integration that stems from the different focus of the lead
agencies that therefore results in and extended process as noted by
Scrase and Sheate (2002), or two separate parallel processes.
It was also acknowledged by most interviewees that procedures
could be avoided, and that it was possible to pay lip service to the
process and still achieve regulatory approval, with the drive to conform
to industry good practice being largely dependent on the enthusiasm of
the key facilitators for both proponents and regulators. There was a
recurring theme throughout the conversations with the consultants and
most of the regulators that early MCPs often described storytelling with
the implication that they were not realistic, and sometimes deliberately
so. As one regulator said: They'll commit to outcomes that they're not likely
to achieve… there's a need for upfront realistic conversations around what is
possible in the future, and a consultant said: it's words on paper.
Storytelling was mentioned multiple times by several interviewees as
being associated with approvals teams who just want to get the project up
and approved, just tell us what you want we'll write it in and move forward.
These procedural side-steps also degrade the opportunity for sub-
stantive and transactive effectiveness. One environmental manager re-
cognised synergies in the process but still considered mine closure
R. Getty and A. Morrison-Saunders
planning to be tagged on at the end.
Risk assessment is integral to EIA and is central to the integration of
the environment into mine closure planning. An embedded risk-based
methodology is explicitly required by the Guidelines and forms the
basis of impact prediction and mitigation to minimise liabilities and
focus closure planning strategies (EPA, 2018; Amirshenava and
Osanloo, 2018). As one consultant said: risk should drive the whole pro-
cess and the interview responses identified flagging of risks and fatal
flaws before project approval to be the most important outcome of the
integration of mine closure planning with EIA especially as noted by
three consultants: few mines end up closing in the way that they proposed.
The identification of fatal flaws integrates the environment into the
decision-making process and the framework integrates closure risks
into the EIA process. Baseline data was also described by most inter-
viewees as essential for mine closure planning, with a poor knowledge
base at the start contributing to legacy issues and having one opportunity
at the start of the mine to actually get some of that information. Risk as-
sessment is only as good as the quality of the data behind it. Everybody
interviewed described early planning as essential for the collection of
baseline data, identification of red flag risks, for options analysis and for
achieving cost effective mine planning that would be difficult to
achieve later. As one regulator said: having [mine closure planning] as
part of the EIA is definitely is a good idea, because it can if it's done well
influence the operations positively and save them headaches down the track
and that would be by far the most critical element.
The interview responses demonstrated some contradictory views
regarding prescription versus flexibility in the integrated regulatory
framework. The flexibility of the risk-based and outcomes-based fra-
mework, instead of prescriptive conditions was seen by all to be im-
portant for an effective integrated framework, to enable site specific
criteria to be addressed, and to permit innovation and technological
development over time. As one environmental manager said: With the
controls that are now in place with the mine closure guidelines, it doesn't
dictate to us, but it sets out a risk-based approach on what we should be
considering before we even start looking at… developing mining assets.
It was recognised by all interviewees that a MCP was site specific
and it was strongly maintained that prescription limited opportunities
for flexibility and to allow innovation and improvement over time, with
statements such as: prescriptive… reduces flexibility for operational and
project planning… and may inhibit design considerations and flexibility. As
one consultant put it: You can't make [MCPs] prescriptive, the process you
can make prescriptive but not the actual design. The design has to be fit for
purpose. However, a suggestion that more prescription would be ap-
propriate was also made by the consultants and environmental man-
agers.
Three of the consultants raised issues regarding the statutory gui-
dance (i.e. the Guidelines), which were described as vague, or a table of
contents, open to interpretation and allowing companies to commit to
unrealistic outcomes and completion criteria. One environmental
manager stated that: conceptual is too conceptual, you can put anything in
a conceptual mine closure plan. One consultant and one environmental
manager thought that a greater level of detail, or minimum codes of
practice would improve the effectiveness of early closure planning. This
tension between flexibility and prescription to guide enforcement is
strongly representative of the plural nature of EIA (Bond et al., 2015;
Pope et al., 2018) which was also identified in the interviews in the
mine closure planning process.
A difference of opinion was observed between the environmental
managers and consultants who noted that prescription of guidance and
conditions had increased over time due to risk averse regulators. As one
consultant said: there's that tension between the developer and the gov-
ernment because the developers are saying well here is the risk, trust us…
and the regulators take a precautionary approach. In contrast to this the
regulators indicated that it was important to them to minimise pre-
scription, that a risk and outcomes-based approach was important, with
prescriptive conditions for EIA and MCPs only to be recommended as a
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Environmental Impact Assessment Review 82 (2020) 106366
last resort.
Every interviewee believed the integrated framework had the cap-
ability to enable procedurally effective mine closure planning, and that
it had been improving as both government and industry matured over
time. As one respondent said: It's not perfect, but I think we've come a long
way in a very short period of time… and it will only improve over time.
Every interviewee also agreed that there was some form of integration
between EIA and mine closure planning, although the perceived extent
of integration was variable. Some regulators and environmental man-
agers believed that there are multiple synergies, and that mine closure
planning is integral to the EIA process. However, closure planning was
noted to be a different process to EIA, with broader information re-
quirements than impact assessment alone thus reducing the potential
for integration. As one consultant said: You need to understand the
Environment to make some decisions about your development… and this is
where EIA plays a part in mine closure… but closure planning is a little
different… and EIA is only a small part of it.
To enable integration of the two processes to occur, several inter-
viewees noted that the procedural effectiveness works best when lead
by someone with enthusiasm and experience, as one environmental
manager said, [early] mine closure planning integrates so well with the
approvals process… [the question is] whether it is the closure plan that's
driving that or the people with the experience, but I tend to think that the
closure plan at least sets the scene for what people should be considering.
3.2.2. Transactive effectiveness
When considering integration in the context of sharing common
goals and tasks to reduce duplication of effort and improve efficiency
(Sánchez and Hacking, 2002; Sánchez et al., 2014) and as discussed in
the ‘integration among assessment tools’ by Scrace and Sheate (2002,
p285), early mine closure planning is widely recognised to have mul-
tiple benefits for efficiencies, improving the chance of rehabilitation
success and reducing the overall cost of mine closure (DIIS, 2016; Keith
and van Rensburg, 2017). All interviewees were of the view that early
mine closure planning as required by the integrated framework could
provide financial benefits by maximising design efficiency, reducing
material handling and allowing time for rehabilitation efforts to es-
tablish. As one respondent said: it's about getting it right from the start… it
can save millions of dollars. Almost all of the interviewees provided
anecdotal evidence in support of design efficiencies, with examples of
good practice as well as knowledge of previous poor design resulting in
expensive remediation. As one consultant said: the reality is that you
really only get one chance to get some of this information.
The incentive to improve transactive effectiveness by integration
was identified during the interviews by the majority of environmental
managers and regulators, as only part of the process, and the im-
plementation of the Mining Rehabilitation Fund Act 2012 (MRF Act) levy
delivered a tighter framework. As noted previously, the MRF Act requires
mining companies to pay an annual levy based on the disturbance area,
with higher premiums for land that has not yet been rehabilitated and
was described as bringing closure costs to the attention of the ac-
countants and corporate managers (i.e. a positive account of transactive
effectiveness). However, there were also alternate views to the effect
that the MRF Act levy was insubstantial compared to the actual costs of
rehabilitation and therefore may be less of an incentive. It was also
noted by one regulator that the lack of financial assurance bonds re-
quired a different style of regulation: we have to encourage and coerce
and incentivise as much as we can because we don't have the ransom of [a
withheld bond and the ability to say] “well you're not going to get your
money back”.
Integration of the assessment through collaboration between the
lead agencies was seen to improve procedural and substantive effec-
tiveness. For example, one regulator noted that: coordination is there
[between DMIRS and the EPA throughout the assessment] to make sure that
when the EPA recommends to the Minister that if the proposal was to go
ahead that there is a high likelihood of success because the [mine closure]
R. Getty and A. Morrison-Saunders
preplanning has been done. However, one consultant indicated that de-
lays regularly occurred due to the different strategic focus of the two
lead agencies, as a greater level of detail is required by the DMIRS for a
MCP at the later Mining Proposal stage than by the EPA for the EIA.
Another perspective along similar lines was that: there's a lot of back-
wards and forwards… if we answer all the questions [at the EIA stage] then
when you put the mining proposal [in to be assessed by DMIRS] will it be
approved? The answer is no. This reduces the potential for transactive
effectiveness as a MCP prepared at a conceptual level for EIA is not
sufficient for the DMIRS who have a different risk focus.
The competency and capacity to deliver an efficient and effective
integrated assessment was identified by the consultants and regulators
as being variable, for employees within industry, consultancies and
regulators alike. All the consultants were frustrated by a lack of con-
sistency leading to delays both within and between the regulatory
agencies (DMIRS and the EPA) due to differences in the understanding,
capabilities and skills of the assessing officers. The assessing officers
were often described as graduates who had worked their way up, or
inexperienced, with a revolving door as some regulatory staff move to
industry and higher wages, leading to inconsistences and immaturity
when assessing MCPs. On the other hand, regulators expressed frus-
tration with the practice of industry and their consultants as follows:
I hear [concerns] about people not understanding the framework, [or]
regulators not applying the framework as it's supposed to… there's a ten-
dency to pull things into the MCP right at the start and that probably reflects
an immaturity of the assessment process.
Effective integration between EIA and early mine closure planning
was described by one regulator as: It's down to the environmental passion
of the company and it usually comes from the top. The strategic view and
capacity of key facilitators was reported by most of the interviewees as
essential for the provision of sufficient resources (time and money), for
efficient and effective collaboration during the integrated process, and
to drive the delivery of progressive closure plans (spending money ‘up-
front’ rather than leaving closure until the end of the life of a mine).
Less experienced facilitators may not have previously dealt with mine
closure legacies, may be too focussed on a tick and flick approvals
process approach rather than a holistic assessment, or may have a short-
term view such as the approvals team whose focus is simply to get fi-
nance and get the project up and running and someone else has to [deal]
with it [down] the track. Some companies exist that have a strategic plan
to on-sell the mine prior to closure implementation, and therefore de-
tailed closure planning would be seen as an unnecessary cost.
3.2.3. Substantive effectiveness
A common theme that was repeated throughout the interviews, and
is also relevant to procedural and transactive effectiveness, was the
importance of having key enthusiastic facilitators to enable EIA and
mine closure planning realise substantive goals and to the drive the
integrated processes. For example, one environmental manager said:
It comes down to each company how effective it is. There's still times
when people can bury their head in the sand and think it's so far off it
doesn't really matter… it's not necessarily the closure plan that's driving
it, it's more the professionals that know that we've got to get this done and
make sure that we get the right material balances that we need for further
down the track.
The role of strong leadership and ‘ownership’ in effectively mana-
ging generational change is well documented in the management lit-
erature (e.g. Pirola-Merlo et al., 2002; Stoeglehner et al., 2009) and the
role of facilitators in influencing EIA quality and decision-making has
been emphasised by Morrison-Saunders (2018) and Kågström (2016).
In theory EIA and mine closure planning share many common goals
and as such integration should be beneficial to both, allowing a more
holistic assessment and greater environmental protection (Sánchez and
Hacking, 2002; Morrison-Saunders, 2018). Both aim to be iterative and
enable progressive learning and improvement (Ortolano and Shepherd,
6
Environmental Impact Assessment Review 82 (2020) 106366
1995; ICMM, 2019). Mine closure planning as a learning process should
generate knowledge with a broader scope not only and the mine site but
also to the wider industry and this has also been theorised to do so for
EIA and SEA (Sadler, 1996; Sánchez and Mitchell, 2017; Pope et al.,
2018).
The integration EIA and mine closure framework in Western
Australia is the starting point to facilitate iterative reviews in-
corporating adaptive management and continual learning. The
Guidelines require that MCPs must be updated and approved at a
minimum of every three years. One regulator stated that: just requiring
mine closure planning at the front by itself won't deliver, but also without
early regulatory oversight there is limited opportunity to respond to
companies with poor planning that results in poor closure outcomes.
Another regulator perspective was that, without a plan, people will do
what they want anyway. This aligns with the views of two consultants
who considered early MCPs to be a useful strategy rather than plan, that
could be later refined as operational risk profiles and data becomes
available.
Both EIA and mine closure planning aim to ensure that any en-
vironmental harm due to development of a proposal is minimised to an
acceptable standard. Regarding mine closure planning, the interna-
tional perspective is that starting the conversation early improves that
chance of success at the project level and can promote wider knowledge
sharing (e.g. ICMM, 2019). This is mirrored in Australian best practice
literature (DIIS, 2016) and the Guidelines. Incorporation of MCPs in EIA
means that closure plans are made public and can be reviewed by the
broader community. Early planning enables early decisions regarding
the design and scheduling of components that can be costly or im-
possible to adjust later, such as landforms and material segregation and
provides time for rehabilitation trials (Nehring and Cheng, 2016;
McCullough et al., 2018). Although the ultimate outcomes of complete
mine closure have seldom been realised, based on their experiences
everybody interviewed agreed that early discussion of mine closure was
important and upheld these perspectives. As one regulator said: pro-
gressive rehabilitation is not just greening up brown dirt; it's research.
Although the legislative integration has promoted early closure
planning, early integration of closure considerations into the planning
process was noted by most (all the consultants and most of the en-
vironmental managers) to be implicit and essential for business in the
first instance. They suggested that the more proactive and in particular
multinational mining companies already consider closure planning
matters much earlier than the formal MCP and EIA stage, albeit less
detailed, as part of due diligence and corporate governance. However,
most interviewees either explicitly or implicitly upheld the value of
having formal procedures in place that apply for all operators across the
mining sector, to ensure that appropriate early mine closure planning
does occur.
The most profound responses regarding the substantive effective-
ness of the integrated framework for early mine closure planning were
to the effect that the legislative change was changing people's beha-
viour and attitudes and driving wider knowledge development through
adaptive learning. As companies have been compelled to identify and
close knowledge gaps regarding mine closure, and behavioural changes
as the requirement for early plans and regular reviews keeps mine
closure planning in the forefront of the company's mind. When describing
the relatively recent development of landforms specifically designed for
closure one consultant stated that: there's a lot of positives when you look
at it over the long term.
Most of the consultants and environmental managers described a
cultural shift within industry towards effective mine closure planning.
Several indicated that the early requirement for closure planning in
combination with the MRF Act levy had led to broader discussion and
engagement of mine closure across different levels of the business (fi-
nanciers, planners, closure managers), the establishment of multi-dis-
ciplinary teams that include mine closure planning, as well as greater
dialogue between regulators and industry. In the words of one
R. Getty and A. Morrison-Saunders
environmental manager:
With this whole integration process, it allows good dialogue between all
parts of the business… and to give [the regulators] an update on where
things are at. That's very common with DMIRS, probably not so much
with the EPA.
Closure targets in the performance indicators of mine managers to
promote longer-term goals, and multi- disciplinary teams that regularly
meet to discuss issues such as closure planning were also mentioned by
interviewees. This is an important step towards the vision of integrated
mine closure described by the ICMM (2019) however, it is yet to be
embedded across the industry. One consultant described the increased
expectations around material characterisation as the only change… to
substantially influence better mine closure planning. One environmental
manager expressed it this way:
They say ‘why we're not closing‘. That's the genuine comment you get...
We don't raise the mine closure title too many times. We say, ‘this is a
condition on a tenement’.
Learning and knowledge development was not restricted to in-
dustry. A change of process was identified described by on environ-
mental manager where the mine closure planning framework was back-
influencing the approvals process through recognition of previous poor
closure outcomes due to a lack of knowledge and unrealistic or poorly
defined approval conditions in the past. This implies that poor out-
comes incentivise better processes rather than a there being a reg-
ulatory driver to improve through evolution processes and checks and
assurances coming from mine closure. Such feedback processes further
enhance not only substantive but also procedural effectiveness.
Drivers that could improve the substantive effectiveness of mine
closure planning external to the integrated framework were described
by most of the consultants, regulators and environmental managers in
terms of using a more strategic, or regional view. They suggested that a
more strategic approach would benefit mines that are currently
working in isolation to achieve their rehabilitation goals due to the
‘polluter pays’ position. One consultant thought that achievable, ef-
fective closure solutions may be better addressed at a regional planning
scale, which should be led by government. The regulators provided
good examples of collaborative rehabilitation efforts in the Goldfields
and the Pilbara regions of Western Australia. Although it was noted that
commercial sensitivities may make this difficult, opportunities to im-
prove substantive effectiveness through initiatives such as those cur-
rently underway by the Western Australian Biodiversity Institute
(WABSI) that integrate funding and knowledge between industry,
government and research agencies. In this case the focus is on sharing
knowledge on biodiversity resources and status in Western Australia so
as to guide development planning and decision making across the State.
Similar strategic approaches for other aspects relevant to mine closure
planning and relinquishment could be envisaged, as evidenced by the
current CRC-TiME application of rehabilitation research (https://wabsi.
org.au/our-work/projects/crc-resource-sector-environmental-
management/). Such approaches can benefit the broader landscape ra-
ther than a single mine site.
3.2.4. Legitimacy effectiveness
As indicated in Pope et al. (2018), the concept of legitimacy is af-
fected by a combination of procedural, transactive and substantive ef-
fectiveness considerations with the test being whether an assessment
process overall is perceived as legitimate by a wide range of stake-
holders. Although at this point in time we were unable to comprehen-
sively determine the legitimacy of the integrated EIA and mine closure
planning process in Western Australia owing to only having solicited
the views of a small number of industry, consultant and regulatory
professionals, it will be useful to observe and understand reactions of
the full suite of stakeholders over a longer time frame (i.e. allowing for
some mine sites to complete the entire process through to relinquish-
ment). Meanwhile, though, we find it encouraging that the 12
7
Environmental Impact Assessment Review 82 (2020) 106366
interviewees were overall supportive of the integrated framework for
mine closure planning as evidenced in the previous results and dis-
cussion. The sense we have derived is that these stakeholders generally
consider the process to be legitimate thus far.
4. Conclusions
In this research we set out to explore the effectiveness of the in-
tegration of two regulatory instruments in Western Australia, realised
following legislative changes to the Mining Act that came into effect in
2011 to bring EIA and mine closure planning together. The literature
suggests that integration of environmental assessment tools has the
potential to improve efficiency by reducing duplication of effort as well
as improving environmental outcomes by enabling a more holistic
proposal assessment.
One contribution of this paper is a simple framework to enable
evaluation of the effectiveness of the integrated EIA and mine closure
planning framework with a focus on mine closure planning. We de-
veloped this framework based on the earlier work of Pope et al. (2018)
and utilising some of the detailed sub-criteria of Chanchitpricha et al.
(2019) where we considered it appropriate to this research. Although it
can reasonably be argued that the effectiveness of early mine closure
planning cannot yet be realised, as only a handful of mines have been
completely relinquished to date, we believe that elements of effective-
ness can usefully be applied to the goals of mine closure planning as
described in the international literature. To only reflect on potential
learnings once a mine is fully closed and relinquished, especially when
mines may operate for generations, misses the opportunity to under-
stand some of the potential benefits of the integrated framework.
In the preceding discussion we demonstrated from interviews, the
literature and the regulatory material for EIA and mine closure plan-
ning, that closure planning at an early stage in a mine's life which has
been compelled in Western Australia as a result of the integrated reg-
ulatory framework shows good alignment with at least three of the four
effectiveness criteria described by Pope et al. (2018). We found that
there were strong, positive examples of procedural, transactive and
substantive effectiveness that result from the integration of EIA and
mine closure planning in our Western Australian study. In summary,
key benefits of this integrated framework are as follows:
• The regulatory framework of Western Australia that requires the
integration of EIA and mine closure planning is aligned with inter-
national good practice and is supported by guidance which has been
collaboratively prepared by the lead regulatory agencies, providing
the foundation for procedural effectiveness.
• It is widely accepted (at least anecdotally and theoretically) that
early mine closure planning if implemented properly can reduce
costs and improve the environmental outcomes of mine closure,
implying transactive effectiveness with the potential for substantive
effectiveness over time.
• Early inclusion of mine closure into the planning process across all
mining proposals, which is internationally accepted as best practice
and arguably drives substantive effective, has occurred in Western
Australia due to being ‘forced’ at the project approval stage by the
legislative changes.
• The requirement for early mine closure planning has broadened
understanding of the importance of mine closure for procedural,
transactive and substantive effectiveness, between different levels of
business and mining teams and will continue to improve over time.
The interviewees overall were supportive of the integrated EIA mine
closure planning framework, implying legitimacy of process at least to
date. Ultimately though it is too early and the full suite of stakeholders
need to be canvassed to evaluate legitimacy effectiveness, and the
perceptions of a broader range of stakeholders could also bring further
insight into substantive, transactive and procedural effectiveness.
R. Getty and A. Morrison-Saunders
Our research also detected tension in the integrated framework,
related to the different origins and motivations of the lead agencies,
whereby the EPA has a more strategic view, concerned with environ-
mental legacy, and the DMIRS who have a greater focus on operational
feasibility and financial liability as well as environmental management.
Although integration was noted to occur at least in some form, this
tension may ultimately mean that full integration of the two processes
(e.g. in the ways envisaged by Scrase and Sheate, 2002) may not be
fully realised.
Common issues were identified where opportunities for enhancing
practice in Western Australia remain. These consisted of a lack of ca-
pacity and capability for industry and regulators (time, understanding
or experience), and the necessity for collaboration and drive of facil-
itators to enable effectiveness. That the drive and enthusiasm of key
facilitators to enable procedural, transactive and substantive effective-
ness was repeatedly emphasised in the interviews suggests a weakness
in the current framework. However, a trajectory of improvement over
time was reported in all the interviews, and it is our opinion that there
is potential for subsequent reviews of the framework to improve gui-
dance and provide opportunities for greater knowledge development
and adaptive learning over time.
Declaration of Competing Interest
The authors declare that they have no known competing financial
interests or personal relationships that could have appeared to influ-
ence the work reported in this paper.
Acknowledgment
We thank the reviewers for their constructive and insightful feed-
back on the manuscript which has enhanced the research.
References
[APEC]Asia-Pacific Economic Corporation, 2018. Mine Closure Checklist for
Governments. Australia-Pacific Economic Cooperation Secretatiat, Singapore.
[DMP & EPA] Department of Mines and Petroleum & Environmental Protection Agency,
2011. Guidelines for Preparing Mine Closure Plans. Department of Mines and
Petroleum, East Perth.
[DMP & EPA] Department of Mines and Petroleum & Environmental Protection Agency,
2015. Guidelines for Preparing Mine Closure Plans. Department of Mines and
Petroleum, East Perth.
[EPA] Environmental Protection Authority, 2018. Environmental Impact Assessment
(Part IV Divisions 1 and 2) Procedures Manual. Environmental Protection Authority,
East Perth.
[IAIA & IEA] International Association for Impact Assessment and Institute for
Environmental Assessment UK, 1999. Principles of Environmental Impact Assessment
Best Practice. Available at. http://www.iaia.org/uploads/pdf/principlesEA_1.pdf.
[ICMM] International Council on Mining & Metals, 2008. In: Starke, Linda (Ed.), Planning
for integrated mine closure: toolkit, ICMM, London, ISBN: 978-0-9553591-8-7.
[ICMM] International Council on Mining & Metals, 2019. Integrated Mine Closure. Good
Practice Guide, 2nd ed. London, ICMM.
[MMSD] Mining, Minerals and Sustainable Development, 2002. Breaking New Ground:
Mining, Minerals and Sustainable Development. IIED.
Amirshenava, S., Osanloo, M., 2018. Mine closure risk management: an integration of 3D
risk model and MCDM techniques. J. Clean. Prod. 184, 389–401. https://doi.org/10.
1016/j.jclepro.2018.01.186.
Boerchers, M., Sinclair, A.J., Gibson, R.B., Halden, N.M., 2018. “Sustainability is finding
the next mine”: the complicated relationships among legacies, sustainability, and EA.
Environ. Impact Assess. Rev. 71, 84–93. https://doi.org/10.1016/j.eiar.2018.01.002.
Bond, A., Morrison-Saunders, A., 2013. Challenges in determining the effectiveness of
sustainability assessment. In: Bond, A., Morrison-Saunders, A., Howitt, R. (Eds.),
Sustainability Assessment Pluralism, Practice and Progress. Taylor & Francis Group,
Oxon, UK, Routledge, pp. 37–50.
Bond, A., Pope, J., Morrison-Saunders, A., 2015. In: Morrison-Saunders, A., Pope, J.,
Bond, A. (Eds.), Chapter 1: Introducing the Roots, Evolution and Effectiveness of
Sustainability Assessment. Handbook of Sustainability Assessment, Edward Elgar.
Braun, V., Clarke, V., 2006. Using thematic analysis in psychology. Qual. Res. Psychol. 3
(2), 77–101.
Canter, L., Atkinson, S.F., 2010. Adaptive management with integrated decision making:
an emerging tool for cumulative effects management. Impact Assess. Proj. Apprais. 28
(4), 287–297. https://doi.org/10.3152/146155110X12838715793002.
Cashmore, M., Richardson, T., Hilding-Ryedvik, T., Emmelin, L., 2010. Evaluating the
effectiveness of impact assessment instruments: Theorising the nature and
8
Environmental Impact Assessment Review 82 (2020) 106366
implications of their political constitution. Environ. Impact Assess. Rev. 30, 371–379.
https://doi.org/10.1016/j.eiar.2010.01.004.
Chanchitpricha, C., Bond, A., 2013. Conceptualising the effectiveness of impact assess-
ment processes. Environ. Impact Assess. Rev. 43, 65–72. https://doi.org/10.1016/j.
eiar.2013.05.006.
Chanchitpricha, C., Morrison-Saunders, A., Bond, A., 2019. Investigating the effectiveness
of strategic environmental assessment in Thailand. Impact Assess. Proj. Apprais.
https://doi.org/10.1080/14615517.2019.1595941.
Clark, A.L., Clark, J.C., 2005. An international overview of legal frameworks for mine
closure. Retrieved from. https://www.elaw.org/content/clark-clark-jc-2005-
“-international-overview-legal-frameworks-mine-closure.
Dendena, P., Corsi, S., 2015. The environmental and social impact assessment: a further
step towards an integrated assessment process. J. Clean. Prod. 108, 965–977. https://
doi.org/10.1016/j.jclepro.2015.07.110.
[DIIS] Department of Industry, Innovation and Science, 2016. Mine Closure - Leading
Practice Sustainable Development Program for the Mining Industry. Canberra,
Commonwealth of Australia.
Dipper, B., Jones, C., Wood, C., 1998. Monitoring and post-auditing in environmental
impact assessment: a review. J. Environ. Plan. Manag. 41 (6), 731–747. https://doi.
org/10.1080/09640569811399.
Elling, B., 2009. Rationality and effectiveness: does EIA/SEA treat them as synonyms?
Impact Assess. Proj. Apprais. 27 (2), 121–131. https://doi.org/10.3152/
146155109X454294.
Environment and Communications References Committee, 2019. Rehabilitation of Mining
and Resources Projects and Power Station Ash Dams as it Relates to Commonwealth
Responsibilities. Canberra, Commonwealth of Australia.
European Commission, 2018. Extractive Waste. Retrieved from. January 1 2018. http://
ec.europa.eu/environment/waste/mining/index.htm.
Franks, D.M., 2015. Mountain Movers: Mining, Sustainability and the Agents of Change.
Routledge, London.
Geneletti, D., 2014. Integration of impact assessment types improves consideration of
alternatives. Impact Assess. Proj. Apprais. 32 (1), 17–18. https://doi.org/10.1080/
14615517.2013.872846.
Gibson, R.B., 2006. Beyond the pillars: sustainability assessment as a framework for ef-
fective integration of social, economic and ecological considerations in significant
decision-making. J. Environ. Assess. Policy Manag. 8 (3), 259–280.
Glasson, J., Therivel, R., Chadwick, A., 2005. Introduction to Environmental Impact
Assessment, 2nd Ed. London, Taylor Francis.
Gorey, P., McHenry, M., Morrison-Saunders, A., Mtegha, H., Doepel, D., 2016. Critical
elements in implementing fundamental change in public environmental policy:
Western Australia’s mine closure and rehabilitation securities reform. Australas. J.
Environ. Manag. 23 (4), 370–381. https://doi.org/10.1080/14486563.2016.
1179227.
Guest, G., Bunce, A., Johnson, L., 2006. How many interviews are enough? An experiment
with data saturation and variability. Field Methods 18 (1), 59–82. https://doi.org/10.
1177/1525822X05279903.
Hacking, T., 2019. The SDGs and the sustainability assessment of private sector projects:
theoretical conceptualisation and comparison with current practice using the case
study of the Asian Development Bank. Impact Assess. Proj. Apprais. 37 (1), 2–16.
Hacking, T., Guthrie, P., 2008. A framework for clarifying the meaning of triple bottom
line, integrated, and sustainability assessment. Environ. Impact Assess. Rev. 28 (1),
73–89.
Kågström, M., 2016. Between ‘best’ and ‘good enough’: how consultants guide quality in
environmental assessment. Environ. Impact Assess. Rev. 60, 169–175. https://doi.
org/10.1016/j.eiar.2016.05.003.
Keith, A., van Rensburg, F., 2017. Reimagining mine closure and rehabilitation. In:
AusIMM Bulletin, April 2017.
Lee, N., Kirkpatrick, C., 2006. Evidence-based policy-making in Europe: an evaluation of
European Commission integrated impact assessments. Impact Assess. Proj. Apprais.
24 (1), 23–33. https://doi.org/10.3152/147154606781765327.
Leech, B.L., 2002. Asking Questions: Techniques for Semistructured Interviews, Reutgers
University, PSOnline www.apsanet.org. pp. 665–668.
Marsden, S., 1998. Importance of context in measuring the effectiveness of strategic en-
vironmental assessment. Impact Assess. Proj. Apprais. 16 (4), 255–266. https://doi.
org/10.1080/14615517.1998.10600136.
McCullough, C.D., Harvey, B., Unger, B.C.J., Winchester, S., McCarthy, B., Coetzee, J.,
2018. From start to finish – a perspective on improving sustainable development
aspects of life-of-mine practices. In: From Start to Finish: Life of Mine Perspective,
Spectrum 24. AusIMM, Carlton Victoria, Australia.
Minister for Mines and Petroleum, 2012. Petition No. 143 – Environmental Legacy of
Mining, [letter to the Standing Committee on Environment and Public Affairs].
Morrison-Saunders, A., 2018. Advanced Introduction to Environmental Impact
Assessment. Edward Elgar, Cheltenham, United Kingdom.
Morrison-Saunders, A., 2019. The action is where the social is! The ecosystem services
concept and other ideas for enhancing stakeholder engagement in integrated mine
closure planning. In: Fourie, A.B., Tibbett, M. (Eds.), Mine Closure 2019: Proceedings
of the 13th International Conference on Mine Closure. The Westin Perth, Australia,
pp. 5–18. Australian Centre for Geomechanics, Perth, ISBN 978-0-9876389-3-9, Mine
Closure 2019 conference: 3–5 September 2019. https://papers.acg.uwa.edu.au/p/
1915_02_Morrison-Saunders/.
Morrison-Saunders, A., McHenry, M.P., Sequeira, A.R., Gorey, P., Mtegha, H., Doepel, D.,
2016. Integrating mine closure planning with environmental impact assessment:
challenges and opportunities drawn from African and Australian practice. Impact
Assess. Proj. Apprais. 34 (2), 117–128. https://doi.org/10.1080/14615517.2016.
1176407.
Namey, E., Guest, G., McKenna, K., Chen, M., 2016. Evaluating bang for the Buck: a cost-
R. Getty and A. Morrison-Saunders
effectiveness comparison between individual interviews and focus groups based on
thematic saturation levels. Am. J. Eval. 37 (3), 425–440. https://doi.org/10.1177/
1098214016630406.
Nehring, M., Cheng, X., 2016. An investigation into the impact of mine closure and its
associated cost on life of mine planning and resource recovery. J. Clean. Prod. 127,
228–239. https://doi.org/10.1016/j.jclepro.2016.03.162.
Ortolano, L., Shepherd, A., 1995. Environmental impact assessment: challenges and op-
portunities. Impact Assess. 13 (1), 3–30. https://doi.org/10.1080/07349165.1995.
9726076.
Parshley, J.V., Bauman, W., Blaxland, D., 2009. An evolution of the methods for and
purposes of mine closure cost estimating. In: Fourie, A.B., Tibbett, M. (Eds.),
Proceedings of the Fourth International Conference on Mine Closure. Australian
Centre for Geomechanics, Perth, pp. 187–200.
Pirola-Merlo, A., Hartel, C., Mann, L., Hirst, G., 2002. How leaders influence the impact of
affective events on team climate and performance in R&D teams. Leadersh. Q. 13 (5),
561–581. https://doi.org/10.1016/S1048-9843(02)00144-3.
Pope, J., Bond, A., Morrison-Saunders, A., Retief, F., 2013. Advancing the theory and
practice of impact assessment: setting the research agenda. Environ. Impact Assess.
Rev. 41, 1–9. https://doi.org/10.1016/j.eiar.2013.01.008.
Pope, J., Bond, A., Cameron, C., Retief, F., Morrison-Saunders, A., 2018. Are current ef-
fectiveness criteria fit for purpose? Using a controversial strategic assessment as a test
case. Environ. Impact Assess. Rev. 70, 34–44. https://doi.org/10.1016/j.eiar.2018.
01.004.
Runhaar, H., Driessen, P., 2007. What makes strategic environmental assessment suc-
cessful environmental assessment? The role of context in the contribution of SEA to
decision-making. Impact Assess. Proj. Apprais. 25 (1), 2–14. https://doi.org/10.
3152/146155107X190613.
Sadler, B., 1996. Environmental assessment in a changing world: Evaluating practice to
improve performance. In: Final Report of the International Study of the Effectiveness
of Environmental Assessment. Canadian Environmental Assessment Agency and
International Association for Impact Assessment, Ottawa.
Sánchez, L.E., 2014. From neighbors to future generations: we are all together! On in-
tegration in impact assessment practice. Impact Assess. Proj. Apprais. 32 (1), 14–16.
https://doi.org/10.1080/14615517.2013.872845.
Environmental Impact Assessment Review 82 (2020) 106366
Sánchez, L.E., Hacking, T., 2002. An approach to linking environmental impact assess-
ment and environmental management systems. Impact Assess. Proj. Apprais. 20 (1),
25–38. https://doi.org/10.3152/147154602781766843.
Sánchez, L.E., Mitchell, R., 2017. Conceptualizing impact assessment as a learning pro-
cess. Environ. Impact Assess. Rev. 62, 195–204 DOI: 10.1016.j.eiar.2016.06.001.
Sánchez, L.E., Silva-Sánchez, S.S., Neri, A.C., 2014. Guide for Mine Closure Planning.
Brasília, 2014.
Saunders, M., Lewis, P., Thornhill, A., 2009. Research Methods for Business Students,
Fifth edition. Pearson Education Limited, Harlow England.
Scrase, J.I., Sheate, W.R., 2002. Integration and integrated approaches to assessment:
what do they mean for the environment? J. Environ. Policy Plan. 4, 275–294. https://
doi.org/10.1002/jepp.117.
Sroufe, R., 2017. Integration and organizational change towards sustainability. J. Clean.
Prod. 162, 315–329. https://doi.org/10.1016/j.jclepro.2017.05.180.
Stoeglehner, G., Brown, A.L., Kørnøv, L.B., 2009. SEA and planning: ‘ownership’ of
strategic environmental assessment by the planners is the key to its effectiveness.
Impact Assess. Proj. Apprais. 27 (2), 111–120. https://doi.org/10.3152/
146155109X438742.
Rebecca Getty is an environment and mine closure consultant with SRK working on
projects within Australia and abroad, providing closure cost estimates, mine closure plans
and due diligence evaluations. She has been involved in the mining industry for more
than 11 years with a background as an exploration geologist in Australia and Canada
before moving into environmental disciplines. Rebecca is particularly interested in the
complexities of mine closure planning.
Angus Morrison-Saunders is Professor, Environmental Management, Edith Cowan
University, Australia; Extraordinary Professor in the Research Unit for Environmental
Sciences and Management, North-West University, South Africa; and Fellow of the
University of Cambridge Institute for Sustainability Leadership. Angus has over 30 years
of experience researching, teaching and training in impact assessment. He is especially
interested in the contribution of impact assessment to sustainable development.