THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021

The Centre for Environmental Rights (CER) supports the creation of a National Mine Closure Strategy but argues that the draft must prioritize 'mining affected communities' over 'mining dependent communities' and ensure that closure planning begins at the pre-feasibility stage. The CER emphasizes the need for meaningful public participation, the integration of land reform and economic diversification to support a just transition, and the alignment of the strategy with the National Environmental Management Act (NEMA) to prevent 'temporary closure' from becoming a gateway to mine abandonment.

• The CER argues that the term 'mining dependent communities' is inappropriate because many people are affected by mining without benefiting from or depending on it; they propose using 'mining affected communities' instead.
• The CER contends that closure planning must start at the pre-feasibility stage and continue throughout the mine's operation to ensure that closure costs are factored into the calculation of a mine's economic viability.
• The document highlights a risk that 'temporary closure' or 'care and maintenance' status is used as a loophole for mine abandonment because the draft strategy does not explicitly mention the persistence of environmental and water-related licenses and obligations during this phase.
• The CER asserts that the definition of 'Life of Mine' should be expanded beyond the period of economic operation to include the time until all environmental and water impacts, including latent ones, cease to manifest.
• The CER recommends that the strategy prioritize land reform and access to land for those most affected by mining to address historical dispossession and inequality.
• The CER emphasizes that for the strategy to be effective, it must be inclusive of other government departments, specifically the Department of Forestry, Fisheries and the Environment (DFFE), the Department of Water and Sanitation (DWS), and the Department of Rural Development and Agriculture.

APA

Centre for Environmental Rights (2021). THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021. https://cer.org.za/wp-content/uploads/2021/07/23-07-21-CER-submissions-on-the-Mine-Closure-Strategy_.pdf?x21779

Chicago

Centre for Environmental Rights. THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021. 2021. https://cer.org.za/wp-content/uploads/2021/07/23-07-21-CER-submissions-on-the-Mine-Closure-Strategy_.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021 |date=23 July 2021 |url=https://cer.org.za/wp-content/uploads/2021/07/23-07-21-CER-submissions-on-the-Mine-Closure-Strategy_.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2021centre, author = {{Centre for Environmental Rights}}, title = {{THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021}}, publisher = {Centre for Environmental Rights}, year = {2021}, month = jul, url = {https://cer.org.za/wp-content/uploads/2021/07/23-07-21-CER-submissions-on-the-Mine-Closure-Strategy_.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }