Closure planning is part of early project design and is often included as part of the Environmental, Social, and Health Impact Assessment in the Pre-Permitting phase. It should account for the community vision for long-term development, if the community so desires. Often, companies practice progressive closure in which a pit or facility is closed and restored as soon as its mineral use is depleted, while other operations continue.
If a closure plan is developed early on, the company often supports capacity building throughout the project that will help prepare the community to achieve its longer-term vision, or can help to convene government or other parties that may contribute to achieving the vision.
If managed correctly, the closure planning and implementation process can create meaningful, positive long-term outcomes for a community and an opportunity for resolution of outstanding grievances or concerns. Without this intentionality, there is risk of new or escalating grievances that can undermine any positive legacy of the project. A poorly closed project can be a major long-term social, environmental, and economic liability for communities.
Closure can significantly impact community members in myriad ways. A large project that created several job or procurement opportunities for local communities during operations may find that the area’s economy is now largely dependent on the company. Without creation of or linkages to alternative markets and livelihoods, closure can result in economic recession and out-migration. This in turn can negatively affect public services, housing markets, and more. Without appropriate handoff to the government or another actor, communities may lose access to services or infrastructure previously operated by a company, or that infrastructure may fall into disrepair. These effects can be compounded by the absence of tax revenue and royalties once production ceases. Communities are ultimately dependent on government capacity to enforce adequate closure; where this is lacking, communities may be left with an unsafe and even toxic environment.
Advance, inclusive planning can ensure that closure creates benefits for communities. Companies can offer re-training and support livelihood transitions, support landscape-level planning and help to catalyze alternative economies, and address and remedy legacy issues. Social impact assessments in advance of closure are particularly critical for informing processes that can best address the rights, needs and aspirations of the community.
A closure plan should provide for continuity in agreements about environmental impact management including a framework for communications and consultation during and post closure, especially if problems or new risks emerge.
As with the Pre-Permitting Phase, it is important that communities have an opportunity to understand and consider the risks and opportunities associated with closure, in order to consent to a closure plan. For instance, does the community wish to retain company buildings or other infrastructure after the project has concluded, or should the site planted with native species and features to encourage natural reclamation? If community ownership of land was not previously acknowledged by the government, how might the land be returned to the community with acknowledgement of legal title? How can local businesses that provide services and goods to the company diversify their customer base to ensure the business’ longevity following site closure?
Communities do well to push for these discussions early on in the project life, as this can:
- ensure that corporate and government resources are allocated to support implementation and enforcement of closure plans
- provide time for full development of a long-term community vision
- allow communities to maximize and leverage community development funding and resources from the company toward that long-term vision
- minimize community economic or other dependence on a single project, in order to smooth the transition when a project is completed
- leverage the company’s convening power to bring in other industry and government actors who may be part of that long-term vision
Of course, communities are neither monolithic nor static, and needs and interests may shift throughout the project lifecycle. Plans and processes developed early on can and should be periodically re-evaluated and re-calibrated to reflect the community’s evolution. It is necessary to strike a balance: company commitments and government engagement are needed to ensure that closure is properly planned, and at the same time, that formal agreements do not preclude the ability of the community to evolve alongside the project.
A company committed to securing FPIC for a project must also secure consent for a closure plan.
Planning for closure should begin very early in the project life. Companies can help to convene discussions with nearby communities and businesses to consider how the site can contribute to a larger vision for regional development, conservation, and other priorities. This big-picture or “landscape-level” approach to planning can help to reduce communities’ economic dependence on a single project or actor and ensure maximum community value from the life of a project.
Because FPIC has only relatively recently been conceptualized and widely adopted, and as extractive projects often have a long lifespan, projects currently entering closure are unlikely to have been developed under an FPIC process from the outset. However, companies which have made FPIC commitments in recent years can still work to incorporate FPIC processes and principles in latter project stages, including closure; special resources may be needed to build internal and external understanding of FPIC and to establish new engagement processes accordingly.