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

The Centre for Environmental Rights (CER) provided written comments on the Draft National Mine Closure Strategy 2021, published by the Department of Mineral Resources and Energy (DMRE). While supporting the initiative to increase certainty in mine closure and rehabilitation, the CER argues that the strategy must better protect mining-affected communities, ensure meaningful public participation from the pre-feasibility stage, and align strictly with existing environmental legislation like the National Environmental Management Act (NEMA).

• The CER argues that the term 'mining dependent communities' used in the draft strategy is inappropriate, suggesting 'mining affected communities' instead because many communities suffer impacts from mining without benefiting from or depending on it.
• The CER emphasizes that closure planning must include meaningful public participation starting at the pre-feasibility stage and continuing through to closure certification, noting that current evidence shows little consultation with communities.
• The CER contests the draft strategy's definition of 'Life of Mine' as only the period of economic operation, asserting it should extend to the point where environmental and water impacts, including latent ones, cease to manifest to avoid externalising impacts.
• The CER warns that the concept of 'temporary closure' can be abused as a 'gateway to mine abandonment' because it is not sufficiently regulated regarding environmental and water-related licenses and obligations.
• The CER recommends that the strategy prioritize land reform and access to land for those most affected by mining, noting that community resettlement for mining has aggravated historical inequality and dispossession.
• The CER stresses that the strategy must not set a lower regulatory bar than binding legislation, specifically the Financial Provision Regulations under the National Environmental Management Act (NEMA), to ensure compliance and enforcement.
• The CER suggests that for the strategy to be effective, it must be inclusive of other government departments, specifically calling for buy-in from 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} }