Mine closure is often described as the final chapter of a project.

In practice, it’s closer to a long-form investigation, part engineering, part governance, part community expectation, part evidence trail. And like any investigation, the outcome is usually decided long before the headline is written.

Across multiple closure projects and practitioner discussions, the same themes keep surfacing: the moves that accelerate progress, the factors that quietly stall programs, and the repeat “gotchas” that can turn a tidy plan into years of delay.

Here’s what the IEMA – Integrating Sustainability, Business & Community team is telling me.

What works when closure goes well

It starts with the right team, and the right mandate. When closure is led by a closure-capable team that’s empowered and properly resourced, the program behaves like a project, not a scramble. The contrast is stark: strong teams hold scope, manage interfaces, and make decisions early enough to matter.

The best sites treat closure as a standalone project. Not an add-on to operational roles. When closure has its own governance, schedule, and delivery rhythm, it doesn’t get bumped every time operations get loud. It gets managed like the major program it is.

Closure is baked into Life of Mine planning and KPIs. The strongest programs don’t bolt closure on at the end. They integrate it into LOM plans and performance measures so progressive rehabilitation, monitoring, and closure readiness become “business as usual.”

They plan early, before they ‘need’ to. Early planning creates room to stage investigations logically, sequence dependencies, and avoid decision-making under time pressure. It also allows for early identification of “no regrets” activities, practical steps that deliver value quickly (cost removal, risk reduction, or momentum).

They build confidence through regular stakeholder engagement. Closure doesn’t happen in isolation. Regular engagement, internal and external, – reduces churn, surfaces issues early, and prevents late-stage surprises that derail scope and expectations.

They put discipline around evidence, not just engineering. Teams that succeed treat document control and action tracking as core technical disciplines: decisions, assumptions, versions, QA/QC evidence, owners, dependencies, captured and accessible.

They lock final land use early and align everything to it. Final land use isn’t a “nice-to-have.” It anchors the criteria for contamination, rehabilitation design, and regulator acceptance. Without it, teams can spend years producing work that becomes irrelevant with a single change of end-use direction.

They manage complexity by structuring the work. Clear work breakdown structures, defined domains, and closure management areas aligned to risk and footprint allow proportional assessment and prioritisation. Strong PM tools and shared communication keep technical experts aligned and deliverables consistent.

They reduce duplication by integrating studies. A consolidated sampling plan (SAQMP) can prevent multiple campaigns across geochem, geotech, and contamination—saving time, cost, and friction.

What fails—or takes far longer than expected

The failure points aren’t mysterious. They’re repetitive.

The wrong team, or a late start. Closure left too late – planning, implementation, and monitoring starting after momentum is needed, nearly always costs more and takes longer.

The wrong specialists, for the wrong reasons. A common trap is engaging experts whose strength is operations rather than closure. Another is choosing the cheapest option or “easy pathway forward”, only to discover later it doesn’t meet regulator expectations and triggers rework.

One practitioner story illustrates the cost: a site relied on its incumbent operational geotechnical consultant for closure guidance. The advice was inadequate, but there was resistance to engaging a closure specialist. When the specialist was finally brought in, recommendations were materially different. The mismatch led to peer review and contributed to roughly five years of delay. The technical issues weren’t impossible, the governance and expertise sequencing was.

Cross-discipline staging misalignment. Closure studies are interconnected. Delays in one stream cascade into others. Without active interface management, the critical path will be decided by whoever slips first.

Water remains the universal schedule killer. Teams repeatedly report that almost every technical study takes longer than planned, especially water. Water interacts with everything: geotech, geochem, landform, ecosystems, approvals. A recurring pain point: not having a closure groundwater model in place early enough to inform decisions and regulator confidence.

Approvals are often not fit for closure. Many approvals were written for operations, not closure execution or post-mining land uses. Modifications can take years.

And the reality that’s rarely planned for? Consent modifications to enable closure are often a 2–3 year exercise. If you don’t treat approvals as a long-lead workstream, it becomes the hidden critical path.

Legal advice takes time, often critical-path time. Legal input is essential, but it’s commonly underestimated in schedules, especially when left late.

Scope, time, and budget creep. Where schedules, timelines, and decision gates aren’t pinned early, projects drift. And when “guidelines” are treated as rigid rules rather than adaptable guidance, teams can overcook studies or block practical, site-fit solutions.

The repeat “gotchas” that keep biting

These are the issues that repeatedly turn “closure completed” into “relinquishment delayed.”

Land use changes shift the goalposts. Criteria change by end use. Contamination standards for residential use differ from native ecosystem targets. The practical implication is simple: lock land use early, or frame assessments to a conservative envelope so you don’t preclude future options.

Closure complete ≠ relinquishment. Relinquishment is evidence-based. QA/QC, records, and defensible documentation are non-negotiable.

Record keeping failures create expensive rework. Poor record keeping during operations becomes a closure tax. Poor record keeping during closure becomes a relinquishment blocker.

Approvals obligations and relinquishment requirements are misunderstood. Many teams underestimate obligations, and it shows up late – when it’s most expensive to fix.

Resourcing is underestimated. People, equipment, money, and the time required after closure for monitoring, maintenance, and reporting.

Due diligence during acquisitions is weak. Acquisitions can inherit unknown liabilities and weak records. Closure is where those realities surface.

Regulator turnover changes the ground under you. Verbal advice evaporates when personnel change. Key decisions and agreements need to be captured in writing.

Risk assessments are treated as one-off events. They shouldn’t be. Phase-based risk reviews and regular check-ins are essential so actions and controls stay valid as the project evolves.

SMEs drift, and coordination fails. Technical experts can drift into “interesting” work without tight scopes and interface management. Weak coordination allows earlier actions and controls to quietly expire.

External expectations escalate beyond requirements. Councils and communities can push for more during closure than approvals require. The practical point: understand your obligations, document agreements, and hold the line through clear governance—while still managing expectations through transparent communication.

The closing insight

The projects that achieve closure outcomes fastest don’t necessarily have the most sophisticated modelling.

They tend to have the simplest fundamentals: the right team, a clear end land use, strong interface management, approvals treated as long-lead workstreams, and relentless attention to evidence.

Because in mine closure, the real finish line isn’t when the works are done.

It’s when the site can be relinquished—and proven.

This week I had a meeting with a client who gets it. They understand that closure is a major project, they’re supportive of lifting maturity, and they’re pushing for stronger governance and delivery discipline. The challenge they’re wrestling with is a familiar one: how to communicate this reality through a corporate executive team where closure can still be viewed as “rehab” rather than a nine-figure delivery program with long-tail risk and a clear relinquishment end point.

Closure is routinely a nine-figure endeavour. In many cases, it is one of the largest “projects” a site will ever deliver. And yet, across the sector, closure is still too often managed as something other than a project, treated as a technical program, a compliance activity, or an operational afterthought.

This isn’t an abstract idea. It’s coming through clearly in conversations with clients right now, as they navigate internal discussions about how closure should be planned, governed, resourced, and delivered. In many organisations, there’s a genuine push to lift maturity. But there’s also a persistent mindset that closure sits outside “normal” project discipline.

That difference in mindset matters. Because when closure is not governed like a project, the costs and liabilities don’t disappear, they compound. And just as importantly, the pathway to timely relinquishment becomes harder to see, harder to manage, and harder to achieve.

The mismatch: capital discipline everywhere… except closure

If a business was building a wash plant, an expansion, or a new piece of critical infrastructure, the early questions would be familiar:

• Who is the accountable owner?
• What is the baseline scope, schedule and budget?
• What are the decision gates and governance?
• How will risk be identified, tracked and controlled?
• What does “success” look like and how will we measure it?

Our experience is closure doesn’t always get the same interrogation, despite the fact that it often carries higher uncertainty, longer time horizons, and more stakeholder scrutiny than many capital projects.

The result is a predictable pattern: closure drifts, decisions can get deferred, scope creeps quietly, and obligations are left to “future teams” to solve which almost always means relinquishment moves further away, not closer.

Closure is a product (and it needs delivery discipline)

Closure isn’t just “rehab.” It is a product with defined outcomes, and those outcomes need to be translated into clear goal posts that a site can work toward, measure, and ultimately demonstrate for sign-off and relinquishment:

• landform and water performance criteria
• erosion stability and geotechnical integrity
• habitat establishment or end land use delivery
• regulatory sign-off and long-term monitoring obligations
• community expectations and reputational exposure
• material movements, civil works, and infrastructure decommissioning

All of this sits on top of a simple truth: the liability exists whether you manage it or not. The only choice is whether you control it early with clear completion criteria and decision discipline or pay for it later through extended monitoring, rework, and delayed relinquishment.

A missing piece: a closure risk profile that flows through delivery

One of the biggest challenges I see in discussions is that closure risk is often recognised, but not consistently identified, owned, and managed end-to-end.

On strong capital projects, risk is not a one-off workshop. It becomes a living system:

• identified early, as part of option selection and design maturity
• quantified, prioritised and assigned owners
• tracked through controls (schedule, cost, approvals, technical performance)
• reviewed at decision gates
• used to shape contingency, staging and delivery sequencing

Closure needs the same approach, because closure risk is not only “environmental risk.” It spans technical performance, approvals, stakeholder trust, cost, schedule, safety, and long-term liability. And if the risk profile doesn’t flow through the program, it shows up later as avoidable delays to sign-off and relinquishment.

Practically, this means:

• building a risk register aligned to closure outcomes and completion criteria (the goal posts)
• linking risks directly to the work program (mitigations are actions with owners, budgets, and dates)
• linking risks to assumptions (and actively testing/retiring assumptions through studies and trials)
• maintaining a clear line of sight between risks and relinquishment blockers (what will stop sign-off?)
• routinely re-baselining risk as the design matures and site conditions evolve

In short: closure should have a risk story that is coherent from strategy → plan → execution → monitoring → sign-off.

What happens when closure isn’t treated like a project?

Below is a breakdown of the most common risk categories that emerge when closure is managed without strong project governance, study management, and delivery controls, and without clear goal posts that keep relinquishment in view.

1) Cost blowouts and “late surprises”

What it looks like: Budget estimates based on incomplete studies, optimistic assumptions, or outdated inventories.

Why it happens: Without structured definition phases (think pre-feasibility/feasibility equivalents), closure scope and quantities remain fuzzy. Unknowns become “contingency” until they become real invoices.

Impact:

• escalating provision and cash calls
• sudden capital reallocations
• loss of credibility with executives, Regulators and investors
• pressure to cut corners to “get back on budget”
• relinquishment pushed out as “fix later” becomes the default

2) Schedule slippage that quietly becomes permanent

What it looks like: Rehab targets that roll year after year; “we’ll do it next shutdown / next FY / next phase.”

Why it happens: Closure schedules are often treated as aspirational, not controlled. Dependencies (approvals, seasonal windows, material availability, access constraints) aren’t managed like a proper program.

Impact:

• extended monitoring and maintenance costs
• delays in relinquishment
• prolonged risk exposure (erosion, water, safety)
• legacy burdens handed to future leaders
• a growing gap between “activity completed” and “goal posts achieved”

3) Regulatory non-compliance and loss of trust

What it looks like: Late submissions, misaligned commitments, conditions that can’t be met, or reporting that doesn’t match reality.

Why it happens: If closure isn’t governed, decisions get fragmented across departments. Commitments are made without integrated planning, and “compliance” becomes a scramble.

Impact:

• s240s, enforcement action, notices, and tighter licence conditions
• delayed approvals for future operational changes
• higher oversight and scrutiny
• reputational damage with regulators and community
• longer pathways to sign-off because trust and evidence are weakened

4) “Scope creep” through a thousand small decisions

What it looks like: Small changes in landform design, water controls, material sourcing, infrastructure removal, or final land use… each sensible in isolation.

Why it happens: Without change control and decision gates, closure evolves informally. The cumulative effect isn’t visible until budgets and timelines blow out.

Impact:

• loss of design integrity and performance intent
• misalignment between plan and execution
• large rework packages late in the piece
• completion criteria become moving targets, delaying relinquishment

5) Safety and operational conflicts

What it looks like: Closure works competing with production priorities; unclear interfaces; inconsistent contractor management.

Why it happens: Where closure is not treated as a project, the interfaces between operations, maintenance, environment, and projects are not formally managed.

Impact:

• elevated safety exposure for crews and contractors
• disrupted production schedules
• higher incident likelihood during decommissioning and earthworks
• delays as work is stopped, re-scoped, or re-approved

6) Poor closure outcomes that create long-term liability

What it looks like: Landforms that don’t perform, drainage lines that fail, erosion that escalates, vegetation that won’t establish, water quality issues that persist.

Why it happens: Closure performance is often only fully understood over time. If the upfront studies and performance criteria aren’t robust, and if execution isn’t controlled, you run the risk of building in failure.

Impact:

• repeated remediation cycles
• ongoing maintenance obligations
• difficulty achieving sign-off and relinquishment
• higher financial assurance and long tail costs
• a widening distance between “work completed” and “relinquishment achieved”

7) Stakeholder blowback and reputational damage

What it looks like: Community frustration, social licence issues, and increased scrutiny from investors and boards.

Why it happens: Closure is highly visible, emotionally charged, and often linked to perceived “promises” made over years. Weak governance leads to missed expectations and reactive communication.

Impact:

• delays due to stakeholder resistance
• reputational harm that affects future approvals
• loss of trust that takes years to rebuild
• more difficult and slower relinquishment conversations

The governance shift that changes outcomes

Treating closure like a project doesn’t mean adding red tape. It means applying a level of discipline that matches the scale of the liability and keeps the pathway to relinquishment visible and achievable.

• Clear accountability: a single accountable project owner with authority
• Front-end definition: baseline studies, options analysis, and staged design maturity
• Controls: schedule, cost, risk and change management that are live and reported
• Decision gates: formal approvals at key points, not informal drift
• Performance criteria: measurable completion standards tied to closure objectives (the goal posts)
• Integrated delivery: operations, environment, approvals, and engineering aligned to one plan
• Risk flow-through: a closure risk profile that is owned, reviewed, and actively managed from strategy through to sign-off

In other words: closure should be managed like any other nine-figure delivery program…….because it is one. And because timely relinquishment depends on discipline, evidence, and keeping those goal posts stable and measurable.

A $100+ million closure deserves $100 million project discipline — with clear goal posts that lead to timely relinquishment.

If you’ve seen closure managed well, what made the difference? And where do you see the biggest gap between intent and delivery?

By: Andrew Hutton, Managing Director, IEMA

For Australian mining companies, Competent Persons (CPs) are now operating at the junction of JORC, ESG, approvals, climate risk and mandatory reporting under the Corporations Act. That’s exactly where environmental and sustainability specialists – working in an aligned way with a deep understanding of the mining and resources sector – can de-risk disclosure and add real value.

What’s changing fast is not just the regulatory environment, but JORC itself. The 2012 JORC Code is under active review, with strong expectations that the next iteration will sharpen requirements around ESG, social licence and risk. When that lands, the demand for integrated technical–ESG capability around the CP will only increase.

This is how that landscape is shifting – and where practitioners like us IEMA – Integrating Sustainability, Business & Community can help CPs produce defensible, finance-ready Public Reports.

1. ESG moves into the Competent Person’s line of sight

The JORC Code (2012) is built on three principles – Transparency, Materiality and Competence – and requires Public Reports to include all information an investor would “reasonably expect” a CP to comment on. JORC Table 1 is clear: it is not a token appendix; it is a checklist of criteria that must be considered, with commentary provided on an “if not, why not” basis. [1]

For Ore Reserves, the Code goes further. Environmental, permitting, legal, social and mine closure issues are not “soft add-ons” – they sit explicitly within the “modifying factors”. If these factors can materially alter the economics, timing or viability of a project, they are squarely within the CP’s line of sight – even where detailed work is led by environmental, approvals or social specialists. [1]

Layered over the Code are powerful global frameworks:

• The Equator Principles (EP4) shape how project financiers assess environmental and social risk in mining and infrastructure projects. [2]
• The ICMM Mining Principles set expectations on climate change, water, biodiversity, social performance and mine closure for many of the world’s largest mining houses. [3]

In this world, a “purely technical” JORC report increasingly won’t pass muster – not with financiers, ESG-focused investors or regulators.

And with the JORC review widely expected to bring ESG and social licence issues further into the core of the Code, CPs will be under even more pressure to demonstrate that these modifying factors have been properly considered and explained by experts – not simply parked with “someone else in the team”.

2. The new regulatory overlay: Corporations Act, ASIC and climate risk

The risk for CPs and boards is no longer just reputational. The regulatory context around mining disclosure has tightened significantly.

• ASIC Info Sheet 214 on Mining and resources – Forward-looking statements sets expectations for production targets, financial forecasts and other forward-looking statements often built on JORC Resources and Reserves. [4]
• Kym Livesley’s paper Liability of Competent Person for JORC Reports is a blunt reminder: misleading or deceptive Public Reports can expose CPs to civil and criminal liability under the Corporations Act, as well as professional discipline. [5]

Climate has now been pulled into the same orbit:

• The Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024 (Cth) introduces mandatory climate-related financial disclosure for large businesses and financial institutions, phased in for financial years beginning 1 January 2025. [6]
• In-scope entities must lodge a Sustainability Report alongside their annual report, aligned with emerging Australian Sustainability Reporting Standards (ASRS), including climate scenario analysis, governance, strategy, risk management and metrics/targets (including emissions). [7]
• ASIC’s Regulatory Guide 280 – Sustainability reporting sets expectations for consistency and comparability in climate-related financial disclosures, and for clear linkages back to the OFR, prospectuses and other regulated documents. [8]

In practice, this means JORC numbers now feed directly into:

• life-of-mine production profiles used in climate scenario analysis;
• emissions baselines and growth trajectories;
• assumptions about closure obligations, rehabilitation liabilities and social transition.

If the JORC narrative is silent on key ESG risks or approval constraints – yet those same issues feature prominently in sustainability or climate disclosures – inconsistency and liability risk appear very quickly.

Add an updated JORC Code with clearer ESG expectations, and the standard for what is “reasonable” for a CP to consider is likely to rise again.

3. Where IEMA-style expertise fits around the CP

IEMA www.iema.com.au is now focused on competence in mine closure, environmental management, climate resilience and stakeholder engagement. That competency framework dovetails with the CP’s technical responsibilities.

Working alongside CPs, IEMA can:

• Translate complex approvals and ESG risks into clear, JORC-style “Materiality” terms.
• Structure impact and risk assessment so JORC Table 1, the Equator Principles and ICMM expectations speak the same language.
• Make sure the environmental and social assumptions used in climate scenario modelling under the Corporations Act are internally consistent with the resource/reserve story being told in the JORC report.

In short, IEMA expertise brings structure, depth and auditability to the non-technical aspects of the JORC narrative – precisely the areas now attracting regulator, investor and financier scrutiny, and the areas where a revised JORC Code is likely to sharpen expectations further.

4. Aligning JORC with Equator Principles and ICMM Mining Principles

Financiers applying the Equator Principles expect to see: [2]

• robust environmental and social impact assessments aligned with IFC Performance Standards;
• evidence that key impacts and mitigation measures have been identified, consulted on and built into project design;
• explicit consideration of climate risks and human rights.

ICMM member companies, meanwhile, commit to Mining Principles that require: [3][10]

• continual improvement in environmental performance, including climate and water;
• conservation of biodiversity and integrated land-use planning;
• strong community engagement, effective grievance mechanisms and responsible closure.

A CP working with IEMA can:

• Map JORC Table 1 commentary – especially for Ore Reserves – directly against Equator and ICMM requirements on community impacts, biodiversity, water, tailings, closure and human rights.
• Help articulate environmental and social modifying factors in language familiar to banks, export credit agencies and ESG investors.
• Flag gaps where additional baseline data, permitting commitments or community agreements are needed to support both Ore Reserve classification and financing due diligence.

The result: a project that is not only JORC-compliant, but also finance-ready – and better positioned for whatever a revised JORC Code demands on alignment with these global frameworks.

5. Mine closure: the discounted tail investors can no longer ignore

For decades, mine closure planning, outcomes and costs have sat at the far end of the cashflow model – deeply discounted in NPV terms and often treated as a problem for “later”. In practice, “later” is arriving much sooner.

Under JORC, closure is already a modifying factor. For Ore Reserves, CPs are expected to consider whether rehabilitation, closure obligations and post-mining land uses could materially affect the viability or timing of extraction. [1] That expectation is only likely to harden under a revised Code.

Several forces are pushing closure from the footnotes to centre stage:

• Accounting and sustainability reporting are bringing closure and rehabilitation provisions onto the balance sheet and into Sustainability Reports, where they can no longer be quietly absorbed in a distant terminal year. [7]
• ESG investors and lenders are scrutinising closure strategies as a litmus test of genuine responsibility – looking not just at cost estimates, but at final land use outcomes, long-term environmental risks and social transition for communities. [2][3][10]
• Regulators and communities are increasingly unwilling to accept vague end-of-life promises; they expect progressive rehabilitation, post-closure monitoring and credible funding arrangements to be locked in early.

For the CP, this means three things.

1. Closure assumptions shape the resource and reserve envelope. Final land use scenarios, waste placement strategies, tailings designs and water management all feed back into pit limits, cut-off grades and mine life. If closure is tightened by new laws, standards or expectations, some material that looks economic in a spreadsheet may, in reality, have no “reasonable prospects for eventual economic extraction”. [1]
2. Closure costs are increasingly material, even when discounted. In a classic NPV model, a big chunk of closure spend sits in distant years and is heavily discounted. But in the real world, closure obligations influence bonding requirements, corporate valuations, community trust and – under climate and sustainability reporting regimes – the story told to the market about long-term liabilities and risks. A CP who blindly accepts legacy closure assumptions without probing them risks signing off on an economic case built on outdated or incomplete liabilities.
3. Closure outcomes are now part of the social licence test. ICMM principles and modern ESG expectations focus on responsible closure, post-mining land uses and community transition as core performance indicators, not afterthoughts. [3][10] Projects that cannot demonstrate credible closure outcomes may struggle to secure approvals, financing or community support – directly affecting the timing and classification of Ore Reserves.

This is a space where IEMA – Integrating Sustainability, Business & Community expertise is particularly valuable:

• developing realistic, scenario-tested closure pathways that reflect environmental, social and regulatory realities;
• checking that closure costs, timelines and outcomes used in the CP’s cashflows align with those disclosed in the company’s sustainability and climate reporting;
• ensuring that closure-related modifying factors are described clearly in JORC Public Reports, rather than buried in internal documents that investors never see.

In other words, closure is no longer just a distant clean-up bill; it is a present-day strategic and financial variable that warrants serious investigation and explicit treatment as a modifying factor.

6. Climate scenario analysis: joining the dots with JORC

Mandatory climate-related financial disclosure in Australia requires entities to undertake climate scenario analysis and to explain how climate risks affect strategy, resilience and financial performance. [9]

To do that credibly, companies need, for each scenario:

• realistic production profiles and mine lives grounded in JORC Resources/Reserves and mine planning;
• emissions trajectories (Scope 1, 2 and, where material, Scope 3);
• assumptions about physical climate risk (flooding, heat, water stress, fire) and how these influence operating costs, cut-off grades and closure timelines.

This is where structured environmental and climate expertise builds a bridge between the CP’s numbers and the board’s disclosures:

• Climate risk and scenario narratives can be framed so they are internally consistent with JORC assumptions (pit limits, strip ratios, processing routes, closure schedules and closure costs).
• Environmental approvals, water allocations, land access and community agreements can be stress-tested under different climate futures to see whether they threaten “reasonable prospects for eventual economic extraction” across parts of the Resource. [1]
• The Sustainability Report, Operating and Financial Review (OFR) and JORC Public Reports can be checked for alignment so they tell a joined-up story – one that meets ASIC and ASX expectations and avoids greenwashing risk.

Looking ahead, a refreshed JORC Code is unlikely to step back from these linkages; if anything, CPs may be expected to be clearer on how climate and nature risks intersect with their estimates and with long-term closure strategies.

7. Five practical ways we can support a Competent Person

In practice, collaboration between a CP and IEMA – Integrating Sustainability, Business & Community environmental/sustainability team tends to fall into five workstreams.

1. ESG materiality and stakeholder mapping for JORC Table 1

• Identify ESG issues that are material in JORC terms – approvals, water, biodiversity, Indigenous rights, local employment, closure, social transition.
• Distil this into focused Table 1 commentary and supporting documentation, avoiding vague or boilerplate text.

2. Approvals and permitting as a “modifying factor”

• Map the approvals pathway, key conditions, likely timeframes and dependencies for the project.
• Work with the CP to reflect this accurately in Ore Reserve classification, especially where approvals or land access materially constrain mine design or schedule.

3. Climate and nature risk integration

• Build a bridge between resource/reserve estimates and climate disclosures: production, emissions, nature impacts and physical risk exposure.
• Align assumptions with the new Corporations Act regime, ASIC RG 280 and emerging AASB sustainability standards, including scenario analysis requirements. [8]

4. Social performance and mine closure planning

• Use IEMA – Integrating Sustainability, Business & Community in stakeholder engagement and to support impact assessment methods to strengthen Social Impact Assessments, community agreements and progressive closure strategies.
• Ensure the JORC report clearly explains social and closure modifying factors in terms compatible with ICMM closure and social performance expectations. [10]

5. Governance, assurance and liability awareness

• Help CPs and boards understand how JORC Public Reports interact with forward-looking statements guidance (ASIC INFO 214) and climate disclosure liability settings. [4]
• Support stronger documentation, internal review and cross-checks so the CP can demonstrate they have taken “reasonable steps” – a key defence under both the JORC Code and the Corporations Act, as Livesley’s analysis underscores. [5]

Each of these workstreams becomes even more important as the revised JORC Code crystallises and expectations on cross-document consistency – especially around closure, climate and ESG – rise.

8. From “add-on” to strategic advantage

For many years, ESG, approvals, closure and climate reporting sat on the periphery of the CP’s world – something handled by the environmental team, the sustainability manager or the lawyer.

That era is over.

Today, JORC reports, Equator Principles due diligence, ICMM commitments, closure expectations and mandatory climate disclosures are tightly coupled. When they don’t line up, the CP, the board and the company all wear the risk.

As the next JORC Code comes into force – almost certainly with more explicit ESG, closure and risk language – that coupling will only get tighter. CPs who treat ESG and closure as optional extras will be exposed; those who build structured environmental and sustainability capability around their work will be better protected and better positioned.

Working with IEMA – Integrating Sustainability, Business & Community , a CP can:

• strengthen the credibility and defensibility of JORC sign-offs;
• improve alignment with financiers, ICMM members and ESG investors;
• and turn ESG and closure integration from a compliance headache into a strategic advantage.

If you’re a Competent Person, project director or board member grappling with these overlaps – particularly in lithium, critical minerals or other scrutiny-heavy commodities – the question is no longer if you should integrate ESG and closure into your JORC narrative, but how.

That’s the conversation we’re keen to have – and the space where we can help you build a reporting approach that is JORC-compliant, finance-ready and future-proofed against the next evolution of the Code.

References

1. Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (JORC Code 2012), JORC https://www.jorc.org/docs/JORC_code_2012.pdf?utm_source=chatgpt.com
2. The Equator Principles – About https://equator-principles.com/about-the-equator-principles/?utm_source=chatgpt.com
3. ICMM – Our Mining Principles https://www.icmm.com/en-gb/our-principles?utm_source=chatgpt.com
4. ASIC – Mining and resources: Forward-looking statements (INFO 214) https://asic.gov.au/regulatory-resources/takeovers/mining-and-resources-forward-looking-statements/?utm_source=chatgpt.com
5. Kym Livesley – Liability of Competent Person for JORC Reports (AusIMM Bulletin) https://www.jorc.org/docs/liability_of_cp_for_JORC_reports-livesley.pdf?utm_source=chatgpt.com
6. Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024 (Cth) – Bills Digest, Parliament of Australia https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/bd/bd2324a/24bd068?utm_source=chatgpt.com
7. Australian Sustainability Reporting Legislation and Standards Guide – KPMG https://assets.kpmg.com/content/dam/kpmgsites/au/pdf/2024/australian-sustainability-reporting-legislation-standards-guide.pdf.coredownload.inline.pdf?utm_source=chatgpt.com
8. Dentons – ASIC finalises its guidance RG 280 for climate-related financial disclosures https://www.dentons.com/en/insights/articles/2025/april/4/asic-finalises-its-guidance-rg-280-for-climate-related-financial-disclosures?utm_source=chatgpt.com
9. Treasury – Climate-Related Financial Disclosure (Exposure Draft Explanatory Memorandum) https://treasury.gov.au/sites/default/files/2024-01/c2024-466491-exposure-draft-em.pdf?utm_source=chatgpt.com
10. ICMM – Sustainable Development Framework: ICMM Principles (via Transparency Lab) https://www.transparencylab.org/Documentation/Industry-Related%20Actors/Industry%20Initiatives-%20Protocols-%20Standards/International%20Council%20on%20Mining%20and%20Metals_/ICMM%20Principles_2015.pdf?utm_source=chatgpt.com

By Andrew Hutton

In today’s mining landscape, closure planning isn’t a box-ticking exercise. It’s a strategic, regulated, stakeholder-driven process that spans the full life of a mine. While many organisations rely on site-specific closure plans, there’s a foundational layer that often goes missing: a corporate-level Mine Closure Standard that is fit for purpose.

Not generic. Not templated. And certainly not borrowed from someone else’s operations.

A true Mine Closure Standard must reflect the unique nature of a company’s portfolio, risk profile, stakeholder expectations, jurisdictional footprint, and ESG commitments. And crucially, it needs to be more than an internal policy – it needs to be supported by the tools that help people on the ground do the work. That’s where the Recipe Book comes in.

What Is a Fit-for-Purpose Closure Standard?

A Mine Closure Standard is a corporate protocol or directive that articulates:

• The company’s position on closure
• The minimum required elements for every closure plan
• Governance, review, and sign-off expectations
• Linkages with financial provisioning, permitting, ESG, and operations

But a fit-for-purpose standard goes further. It:

• Adapts to different types of sites (greenfield, operational, legacy, high-risk, low-risk)
• Reflects the jurisdictions you operate in
• Scales with your internal capabilities and maturity
• Clearly distinguishes between mandatory corporate expectations and site-level flexibility

The best standards are written with both executives and site planners in mind. They bridge high-level commitments with practical application and are continually updated and reviewed as the company and industry get more experience with mine closure.

Why One Size Doesn’t Fit All

No two mining companies are the same. Some are global enterprises, listed and operate in multiple countries and jurisdictions whilst at the other end the other might only have a single operation. Even within a single company, closure liabilities, environmental context, land use pressures, and community expectations vary significantly. That’s why adopting a generic or templated approach to closure standards can create real risk:

• Plans that meet the letter of the law, but not the intent
• Misalignment between operational teams and corporate strategy
• Missed opportunities for progressive closure or relinquishment
• Surprise liabilities at the end of mine life

A fit-for-purpose standard gives internal teams clarity. It tells them what success looks like, what must be done, and what can be tailored.

What Belongs in a Fit-for-Purpose Mine Closure Standard?

A strong standard sets out:

1. Purpose and Applicability

• Who the standard applies to (e.g. all managed assets)
• How it integrates with the company’s life of mine and ESG frameworks

2. Guiding Principles

• Closure is integrated from inception
• Progressive rehabilitation and risk reduction are core
• Engagement is continuous and inclusive

3. Minimum Requirements for Plans

• Closure objectives and post mining land use scenarios
• Risk assessments and materiality reviews
• Closure criteria and monitoring frameworks
• Cost estimation and provisioning methodology

4. Governance and Sign-off

• Approval gates across the study phases (concept, PFS, FS, operations)
• Closure maturity models and triggers for updates
• Delegations of authority

5. Interface with Other Systems

• Environmental management
• Permitting and compliance
• Finance and corporate reporting

This standard becomes the backbone of closure governance across the business.

The Role of a “Closure Recipe Book”

A key insight: the standard and the plan are not enough. Site teams need a bridge between the two.

The Recipe Book is that bridge. It is a separate but companion document — an addendum, attachment, or operational guide that walks closure practitioners through the process.

It includes:

• A detailed Work Breakdown Structure (WBS)
• Templates, checklists, and tools for developing closure plans
• Guidance for building accuracy and completeness across project stages

It sets out what should be considered at each step of closure planning, from concept study through pre-feasibility and feasibility. Not everything is mandatory, but nothing should be ignored. That’s where the “if not, why not” principle comes in:

• Every checklist item must be considered
• If it’s excluded, a rationale must be provided

This principle ensures transparency and defensibility, especially in regulatory and stakeholder engagement contexts.

Approval Gates: A Managed Process

A fit-for-purpose standard and recipe book build approval gates into the closure planning process. These checkpoints align with broader project development and financing processes:

• Concept to PFS: Is closure risk identified? Are viable land use options defined?
• PFS to FS: Are closure objectives and criteria developed? Is costing reliable?
• FS to Operations: Has closure been integrated into scheduling and budgeting?
• Operations to Closure: Are relinquishment pathways and stakeholder expectations aligned?

These gates enforce discipline, encourage early planning, and ensure funding is progressively locked in.

Visualising the Work Breakdown Structure (WBS)

To help guide closure planning practically, the Recipe Book should include a WBS broken into thematic elements. A simplified version of the key aspects is listed below:

1. Closure Context and Objectives

• Final Land Use Scenarios
• Closure Vision and Goals
• Regulatory and Legal Framework
• Obligations Register

2. Baseline Data and Studies

• Environmental Baseline (soil, water, air)
• Social and Cultural Context
• Closure Knowledge Gaps

3. Closure Design and Implementation

• Rehabilitation Design and Landform Modelling
• Water Management and Voids
• Decommissioning of Infrastructure

4. Risk and Cost Management

• Closure Risk Assessment
• Financial Provisioning
• Contingency Planning

5. Monitoring, Evaluation, and Relinquishment

• Completion Criteria
• Monitoring and Maintenance Plans
• Relinquishment and Handover Process

6. Stakeholder Engagement and Social Transition

• Community Engagement Strategy
• Traditional Owner Involvement
• Social Transition and Economic Legacy

Each of these components is layered across study phases, building in rigour and reducing risk as you move toward closure.

Moving Beyond High-Level Frameworks

The ICMM Integrated Closure Good Practice Guide is an excellent starting point. It provides principles and a maturity model. But it does not offer the detailed, site-ready tools that practitioners need to deliver closure plans that are costed, integrated, and defensible.

That’s why internal standards and recipe books are essential. They turn policy into practice.

Why It Matters

Getting closure right is no longer optional. Investors, regulators, Traditional Owners, and communities are all watching.

A fit-for-purpose closure standard:

• Avoids surprise liabilities
• Builds trust through transparency
• Protects reputational value
• Enhances relinquishment success
• Aligns closure to ESG and decarbonisation goals

But it must be backed by clear tools, trained practitioners, and governance that ensures closure is not left until the end.

Because closure isn’t just the last chapter of a mine. It’s the beginning of what comes next.

Andrew Hutton is Managing Director of IEMA, a project management & environmental management consultancy specialising in mine closure, rehabilitation, and legacy land use solutions. He has worked across Australia and internationally helping companies design and implement fit-for-purpose closure governance frameworks.

By the IEMA – Integrating Sustainability, Business & Community

A complex industrial closure was approaching the hard part, proving it would remain safe, stable, and compliant in an environment where climate change may move the goal posts in the long term future. IEMA – Integrating Sustainability, Business & Community was brought in to answer the question regulators, investors, and communities are all asking: Will this plan still work in 2050?

The brief

Stress-test a full closure plan end to end against plausible climate futures. Translate the findings into concrete actions that shorten the road to sign-off and reduce surprises after handover.

What we did

• Followed the evidence, not the vibe. We assessed risks under IPCC RCP 2.6, 4.5, 8.5 to 2050, aligned to national sustainability reporting expectations.
• Broke down silos. Hydrology, geotech, ecology, climate science, and socio-economics were integrated, because landforms, water, and community impacts don’t behave in isolation.
• Tested what matters. We looked for climate assumptions inside designs and models, covers, caps, retention basins, seals, water balances, flood modelling, not just mentioned in the narrative.
• Rated controls the way auditors do. Likelihood × consequence across environmental, social, operational, financial, and reputational dimensions, with clear evidence trails.

What we found

• 19 material risks surfaced: 11 physical (stability, potential subsidence/sinkholes, erosion, surface–groundwater interactions, retained infrastructure) and 8 transition (regulatory shifts, disclosure, reputation, residual-risk governance).
• The pattern: Many controls were in progress or untested. The work had started, but assurance and climate scenario integration weren’t yet bulletproof.

Commercial impact: Untested controls and ambiguous residual risk are what delay relinquishment. Fixing them brings timelines forward and reduces cost-of-waiting.

The 10 recommendations that changed the trajectory

Here’s where the assessment turned into momentum. We translated risk into ten concrete recommendations, design tweaks, modelling upgrades, and governance shifts, that hard-wired climate futures into the closure program and removed the roadblocks to sign-off. In short: practical steps, clear owners, measurable outcome

1. Bake climate futures into design specs (RCP 2.6/4.5/8.5) for covers, caps, drainage, storage.
2. Stand up post-execution monitoring & maintenance with KPIs, triggers, and a realistic budget.
3. Lock corporate–project alignment on required scenarios and disclosures.
4. Define a residual-risk framework (ownership, funding, monitoring, reporting).
5. Re-run flood modelling on the final landform under RCP 4.5/8.5 to validate basin sizing and spillways.
6. Couple the water balance (surface + groundwater) for post-closure conditions with climate inputs.
7. Resolve heritage infrastructure pathways to remove safety/liability ambiguity.
8. Inform seal designs with hydrogeology that reflects future groundwater behaviour.
9. Adopt climate-ready revegetation (species mix, establishment, success criteria, adaptive management).
10. Institutionalise regulatory horizon-scanning between corporate and site teams.

Results that matter to decision-makers

For decision-makers, the outcomes are clear: residual risk needs to be acceptable across all climate scenarios; climate futures are required to be embedded as traceable design inputs and validated against extremes; governance needs to be audit-ready with defined roles, artefacts, and decision trails that build regulator and investor confidence.

When to reopen the file (so you don’t get caught out)

There is a need to reopen the assessment whenever the ground shifts, think changes to IPCC scenario assumptions or national reporting rules; updates to closure methodology, final landform, or land use; modifications to water infrastructure or its performance; heightened sensitivity of nearby community assets; or revised corporate risk appetite and disclosure expectations.

The takeaway

If your closure case hinges on “we think this will hold,” expect delays. If it demonstrates how it holds across plausible futures, with evidence in the specs, budgets, and governance, approvals get simpler, and handover gets faster.

Considering a closure in 2025?

IEMA – Integrating Sustainability, Business & Community helps asset owners prove climate resilience, compress approval timelines, and de-risk handover with a practical, evidence-first playbook. If you want your next regulator meeting to start with “we’ve already tested that,” let’s talk.

By Andrew Hutton (based on work by Will Mitry and Erin Littlewood presented at the 2025 AusIMM LOM Conference, Brisbane.

In an era of rising environmental expectations, regulatory scrutiny, and climate uncertainty, mine closure is no longer a back-end activity. It is a forward-thinking process that must embed resilience, accountability, and nature-positive outcomes from the outset. At the forefront of this transformation are spatial data systems, practical technologies that integrate geographic, environmental, and operational data into intelligent frameworks to support better closure decisions.

That’s why two (2) new spatial intelligence platforms, IMERCS and EcoScenario, developed by staff at IEMA – Integrating Sustainability, Business & Community are gaining momentum. Both are built in Australia, field-tested on operational sites, and developed by mining and closure professionals for mining and closure professionals. Remember “we have walked in your shoes”. Together, they offer a new standard for closure compliance, resilience, and biodiversity performance.

The Shift: Why Spatial Intelligence Matters to mine closure planning

Traditional mine closure systems often rely on disparate data sources, manual workflows, and regional climate assumptions. These legacy approaches struggle to:

• Track evolving closure obligations
• Capture and retain institutional knowledge
• Assess future climate and biodiversity risks
• Demonstrate compliance and performance to regulators

Spatial data systems overcome these limitations by:

• Centralising structured and unstructured environmental data
• Embedding GIS, AI, and automation into operational workflows
• Enabling high-resolution, site-specific modelling
• Supporting transparent, real-time reporting and audit readiness

IMERCS: An Intelligence System for Closure Compliance

IMERCS (Integrated Mining, Environmental, Rehabilitation and Closure System), developed by IEMA in partnership with Whitehaven Coal, is a modular, cloud-based platform built on:

• AWS Cloud Infrastructure – Scalable, secure, and globally deployable
• ESRI ArcGIS – For spatial data integration and visualisation
• OpenAI APIs – To enable AI-driven document interrogation and regulatory reasoning
• FME (Feature Manipulation Engine) – For data automation, transformation, and ingestion across systems

It integrates management plan obligations with execution records, using spatial intelligence, automated workflows, and AI agents to support mine closure and rehabilitation. IMERCS operates on a Plan-Do-Check-Act cycle. IMERCS offers a suite of 13+ configurable modules that can be tailored to site needs. These include:

• Environmental Monitoring: Tracks surface water, groundwater, dust, flora and fauna parameters spatially and temporally
• Rehabilitation Planning and Tracking: Links design with actual performance through drone surveys, NDVI analysis, and milestone tracking
• ePTW (electronic Permit-to-Work): Integrated with spatial constraints and biodiversity overlays
• Cultural Heritage and Subsidence Management: Maps sensitive areas and ensures protection during closure activities
• Closure Cost Estimation: Uses spatial metrics and schedule data to refine provision forecasts
• Regulatory Reporting: Generates automated reports aligned with State and Federal regulations

A standout feature is the AI toolkit embedded in IMERCS:

• IMERCS GPT: Parses management plans, execution records, and survey data to surface compliance status, overdue actions, and misalignments.
• Audit AI: Assists in regulatory audits by extracting and comparing obligation fulfillment across time.
• Regulator GPT: Crosswalks internal documentation with regulatory frameworks to highlight gaps or inconsistencies.
• RehabEye AI (in development): Uses machine learning on drone imagery to assess erosion, vegetation cover, and landform stability.

At Narrabri Coal Operations, IMERCS processed 100+ digital ePTWs without incident, delivered >95% rehab success in key zones, and impressed regulators with its audit readiness.

EcoScenario: Designing for Nature-Positive Closure

Presented at Life of Mine 2025, EcoScenario is IEMA’s GIS-based closure simulation platform. It lets planners model landform and biodiversity performance under future climate conditions, using real site data, not regional proxies. The platform is also being developed to integrate the requirements of mandatory climate reporting into closure planning and can be supported by a detailed climate change risk assessment tailored to site-specific exposures.

EcoScenario is a GIS-based platform that:

• Operates at a 5m x 5m grid resolution for terrain, habitat, and climate inputs
• Utilises IPCC RCP Scenarios (2.6, 4.5, 8.5) to simulate possible climate futures
• Integrates species movement models, fire/flood risk overlays, and hydrological algorithms
• Provides interactive visualisation layers for stakeholder engagement and adaptive design

Core Applications

• Biodiversity Offsets and Connectivity: Models future species corridors, habitat recovery, and edge effects
• Landform Evolution: Simulates erosion, slope stability, and drainage performance under extreme events
• Climate Risk Assessment: Evaluates exposure to cyclones, fire weather, drought stress, and inundation
• Stakeholder Planning: Produces interactive maps and scenario narratives for Traditional Owners, regulators, and communities

Case Studies:

The power of spatial intelligence lies not just in its technical sophistication, but in its practical impact on the ground. IMERCS and EcoScenario have been deployed at active mine sites across diverse geographies and operational contexts, where they are helping closure teams move from static plans to adaptive, data-driven strategies.

The following case studies demonstrate how these platforms can be used to:

• Translate complex closure objectives into spatially targeted actions
• Anticipate environmental risks under future climate scenarios
• Improve regulator confidence through transparent, auditable data
• Deliver measurable ecological outcomes that go beyond compliance

These examples reflect the evolving role of closure professionals—not just as stewards of compliance, but as strategic designers of post-mining landscapes

Hunter Valley, NSW

EcoScenario helped reimagine the post-mining land use from low-productivity grazing to a 570-hectare native woodland corridor, increasing habitat connectivity by 20% and aligning with local biodiversity targets.

North Queensland

Under cyclonic rainfall simulations, EcoScenario identified vulnerabilities in legacy drainage design. Redesign efforts, guided by platform outputs, ensured tailings dam resilience under 1-in-200-year rainfall events

Lessons from the Field: What Makes These Systems Work?

1. Site-Specific Data Over Regional Proxies

Both IMERCS and EcoScenario anchor their intelligence in on-site monitoring and survey data—enabling precise, confident decision-making.

2. Embedded into Operational Workflows

IMERCS integrates seamlessly with daily site operations, connecting rehabilitation teams, planners, and environmental specialists. EcoScenario feeds directly into closure visioning, risk assessments, and community consultation tools.

3. Scalable and Modular Architecture

IMERCS adapts across different operations—from open-cut coal to metalliferous mines—with a plug-and-play module framework. EcoScenario can be calibrated for any terrain, landform objective, or regulatory jurisdiction.

4. AI and Automation

From GPT-powered audits to drone-based landform analytics, the platforms minimise manual effort, maximise insight, and accelerate response times.

Looking Ahead: The Spatial Data Advantage

As mining companies face growing expectations from investors, regulators, communities, and nature itself, the ability to demonstrate closure outcomes will be key to maintaining social license.

Spatial data systems offer:

• Data-driven compliance tracking and audit readiness
• Nature-positive design that restores ecosystems, not just landform
• Risk visibility for climate adaptation and liability management
• Stakeholder transparency to build trust and accountability

Closing Thoughts: Turning Risk into Readiness

Mine closure is no longer the final chapter; it’s a live process unfolding over decades. The most effective practitioners will be those who can turn complexity into clarity, using tools that speak the language of both regulators and ecosystems.

IMERCS and EcoScenario aren’t just technologies, they’re strategies. They’ve been built with real closure constraints in mind, tested on operational sites, and designed to evolve as the expectations do.

If you’re in the closure game, now is the time to upgrade your toolkit—not just to meet obligations, but to lead the transition to transparent, resilient, nature-positive mining.

Want to see how these tools can work at your site?

Erin Littlewood – Principal Consultant, IEMA [email protected]

Will Mitry – Associate Consultant, IEMA [email protected]

By Andrew Hutton – Managing Director, IEMA

In the world of mining, extraction is only half the story. The other half – often less glamorous but just as critical – is what happens when the digging stops and how we can contemplate the transition of mine sites to a beneficial reuse that generates employment and supports the regional economies surrounding it.

Across New South Wales, a quiet transformation is underway. Mines are maturing, leases are winding down, and the industry is shifting from boom-and-bust to something more measured: legacy management, rehabilitation, and ultimately, relinquishment.

But if you’ve ever tried navigating the maze of mining lease sign-off in NSW, you’ll know it’s not just a matter of ticking boxes and walking away. Nor should it be.

The Missing Piece? Evidence

At the heart of the process is evidence, not intent, not effort, but cold, hard proof squarely based on a firm base of a solid and robust risk assessment.

In our experience, the NSW Resources Regulator wants to see that every risk has been controlled, every contour restored, and every patch of land returned to a safe, stable, and sustainable state. That means having a robust Rehabilitation Management Plan, documented works, and a rigorous level of verification.

This is where Inspection and Test Plans (ITPs) come into their own. Too often treated as back-office admin, they’re actually the backbone of the entire process. ITPs show how each rehabilitation activity was executed, assessed, and verified. They create the traceability regulators need to say “yes.”

Without structured, consistent records management, it’s impossible to demonstrate compliance confidently. Strong projects are now building their Relinquishment Assurance Reports (RARs) off carefully curated evidence chains supported by ITP completion data—not guesswork.

It’s Also Intelligent Use of Spatial Tech

Gone are the days when relinquishment was tracked in folders and memory sticks. Today, spatial data systems are driving decision-making, visualising what areas are ready for submission, overlaying verification data, and identifying gaps.

Smart operators are using GIS platforms to:

• Map completion criteria against real-time landform data
• Identify high-risk zones like tailings facilities
• Track forward works with geospatial accuracy
• Collect evidence spatially
• Use AI to generate workflows and match site obligations

This spatial intelligence isn’t just a visual tool – it’s a strategic asset. It helps teams prioritise work, engage with regulators using evidence, and communicate progress with stakeholders.

It’s a Project and a Strategy

Too often, companies treat relinquishment as the final checkbox on a closure plan. In reality, it’s a standalone project – with its own scope, resources, and risks. It’s big, the dollars are material – treat it like it’s a $50M project, not a rehab job. Establish governance, processes and IPRs. Move along the project pathway of Concept, PFS and Feasibility – and give yourself plenty of time to pivot whilst you have budget, cashflow, kit and people on site.

The most forward-thinking operators are treating relinquishment as a strategic opportunity. They’re using spatial analysis to map areas for early sign-off and getting them through the process ahead of time. Using the processes to build credibility with stakeholders is key. They’re integrating post-mining land use into their plans. They’re even lining up rezoning applications and new approvals alongside ESF2 submissions to unlock future land value and direct the relinquishment of the site towards a known beneficial reuse – which narrows the breadth of “what ifs” and options.

It’s about transitioning an asset, not just closing a liability.

Regulator Engagement Matters

One of the most underappreciated aspects of the process? Genuine Dialogue.

The best outcomes come when operators engage early and transparently with the regulator – presenting draft RARs, discussing land use transitions, and clarifying long-term residual risk management strategies.

These conversations aren’t about box-ticking—they’re about building alignment. When done well, they remove ambiguity, build confidence, and streamline the ESF2 process.

The Future of Mine Closure Is Professionalised

We’re entering an era where closure and relinquishment are treated with the same rigor as development and operations. It’s now a specialty and it requires project managers who can move across all technical issues and challenges. Subject Matter Experts (SMEs) are essential, but it’s much more than designing a cap, reviewing a landform, modelling water, or engaging with community—it’s about meshing it all together and managing risk.

That means:

• Project-managed relinquishment pathways
• Project governance and processes
• Detailed and dynamic risk assessments
• Dedicated specialists in spatial, rehab, risk, and land use
• Robust ITPs and digital evidence systems
• Transparent reporting and regulator engagement

It’s no longer enough to “rehab and hope.” Companies need to verify and validate – and they need to prove it with systems that hold up under scrutiny.

As more NSW operators edge closer to end-of-mine life, the conversation is shifting from “how do we comply?” to “how do we exit well?”

That’s not just a compliance challenge – it’s a reputational and strategic opportunity. And for those who get it right, relinquishment doesn’t mark the end, nor does it need to be made hard and drag on. Holding costs for mining leases are material, and care and maintenance does not mean no costs. It marks the handover to what comes next, whether that’s conservation, community benefit, or commercial redevelopment.

Andrew Hutton is Managing Director of IEMA, an environmental and closure advisory firm based in regional NSW. He has nearly 30 years’ experience in mine closure strategy, regulatory approvals, and stakeholder engagement.

As New South Wales inevitably confronts the question of what becomes of our former mine sites is no longer academic. Across the Hunter and other regions, vast tracts of land previously dedicated to extraction are now nearing or at the end of their operational life. What happens next will define not just landscapes, but regional economies, investment pipelines, and community futures.

The good news? NSW is well-positioned to lead the nation in defining what successful post-mining land use looks like.

While mine closure has historically been treated as a compliance task focused on stabilising slopes, replanting vegetation, and ticking regulatory boxes, it is increasingly being recognised as an opportunity to reshape regions for the better. But realising that opportunity requires a shift in mindset, backed by a coherent policy framework and coordination across agencies and stakeholders.

From my experience advising on closure projects across Australia and internationally, I believe NSW’s path forward hinges on five strategic imperatives.

1. Address the Residual Risk Barrier
2. Define Post Mining Land Use at the start, not the end
3. Coordinate the maze of Government Approvals
4. Build on the strategic momentum already underway
5. Learn from best practice across Australia and beyond.

1. Address the Residual Risk Barrier
The most persistent challenge in repurposing former mining land is the issue of residual risk. Even when a site is rehabilitated to meet regulatory requirements, uncertainty about long-term liabilities, such as tailings facilities, large dams, water quality in final voids, underground subsidence, or contamination. They can stall land handover indefinitely. This ambiguity deters both regulators and private investors.

NSW urgently needs a clear, proportionate framework to assess and manage these risks and, where appropriate, enable risk transfer mechanisms. Without this, many sites will remain in limbo, with potential unrealised.

2. Define Post-Mining Land Use at the Start, Not the End
A second, and often overlooked, challenge is the lack of early consensus on future land use. Too often, rehabilitation efforts are designed around technical parameters rather than a concrete vision for how land will be used post-mining. Is the goal agricultural productivity? Renewable energy generation? Biodiversity offsets? Community infrastructure?

Agreeing on this at the outset or during the operational phase of mining allows closure criteria to be tailored to real-world outcomes, streamlines approvals, and gives future users, whether developers, councils or the community, greater certainty. By achieving early approval for post mining land use enables the mining to partner with the developer and the “goal-posts” on hazards and risk are clearly defined. A pathway to approval certainty also makes investment attraction much easier.

3. Coordinate the Maze of Government Approvals
The complexity of the post-mining regulatory environment is well known. In NSW, responsibilities for closure touch at least a half-dozen agencies from Resources and Planning to the EPA and Water. With no single authority responsible for coordination, delays, duplication, and inconsistent advice are inevitable.

There is a strong case for a coordinating body perhaps a dedicated taskforce within a single Department with a clear remit to lead on post-mining land transition. This could include establishing a closure strategy review process at key planning and environmental assessment stages.

4. Build on Strategic Momentum Already Underway
NSW isn’t starting from scratch. The last 3-5 years has seen a material change in thinking and a real alignment to starting to strategically think about the post mining world. Not just by the miners, but by local governments, communities, think-tanks, Universities, now the wider community. For example, the Hunter Regional Plan 2041 explicitly addresses post-mining land use, highlighting the role of former mine sites in supporting energy transition and industrial innovation.

Meanwhile, the Hunter Joint Organisation (HJO) has developed a $20 million proposal to deliver:

• Place-based mine closure strategies
• A regional audit of mining lands and infrastructure
  \Master plans for legacy sites in Singleton, Muswellbrook, and Lake Macquarie

This local-regional alignment with state planning signals a shift in how mine closure is approached, not just as environmental remediation, but as part of long-term economic development.

5. Learn from Best Practice Across Australia and Beyond
WA and Queensland offer useful templates. In WA, closure planning must now include an agreed post-mining land use, while Queensland’s residual risk payment scheme (whilst not without its challenges) aims to offe a transparent way to manage liabilities after relinquishment. Canada and Germany also offer structured models for verification, transition governance, and post-closure funding.

NSW can adapt these lessons, but also improve upon them by ensuring local governments, mining companies and private developers are part of the planning conversation from the outset.

Post-mining land use is not just about safe closure; it’s about successful transition. NSW has the vision, the groundwork, and the regional leadership to become the benchmark in this space. What’s needed now is execution.

With the federal election behind us, Australia stands at an important crossroads for environmental reform and climate policy. Over the past term, we saw the Government attempt a bold overhaul of environmental laws and climate frameworks – many of which faced roadblocks in Parliament. As the newly re-elected Government settles in, the direction it takes now will have a lasting impact on the country’s climate commitments, biodiversity outcomes, and transition to renewable energy.

While details remain to be seen, now is a key time for businesses, industry leaders and environmental practitioners to stay engaged and contribute to consultations as these policies evolve.

Where Are We Headed?

Here are the major themes and expectations shaping the road ahead:

• Climate Targets: The Government is holding the course on its net zero by 2050 ambition and 2030 emissions reduction target (43% below 2005 levels). The Climate Change Authority will guide the setting of a 2035 target, as required under existing law.
• Renewable Energy Push: Building on the Powering Australia Plan, the target remains for renewables to provide 82% of the National Electricity Market by 2030. The Government has pledged a further $8 billion in investment via the Clean Energy Finance Corporation to accelerate the shift to low-emissions technology – firmly opposing nuclear as an alternative.
• Nature Positive Reforms – Still in Play?: After ambitious reforms to the Environment Protection and Biodiversity Conservation (EPBC) Act stalled during Labor’s last term, it’s unclear how far the next wave of environmental reforms will go. That said, Prime Minister Albanese has confirmed that reform is still on the agenda, albeit in a revised form. Importantly, the commitment to biodiversity protection remains, supported by a $262 million pledge over five years to meet the ’30 by 30′ conservation target – protecting 30% of Australia’s land and marine areas by 2030.

A Look Back: Progress and Setbacks

In 2022, the Government outlined its Nature Positive Plan – the most significant proposed revamp of federal environmental laws since the EPBC Act came into effect over two decades ago. The reforms were based on Professor Graeme Samuel AC’s independent review and promised to reshape environmental governance, impact assessment, and biodiversity protection.

Only a fraction of this agenda was implemented:

• Nature Repair Market: Launched on 1 March 2025, this world-first legislated biodiversity credit scheme allows landholders and organisations to earn and trade biodiversity certificates by undertaking verified conservation and restoration activities.
• Water Trigger Expansion: Reforms extended the ‘water trigger’ under the EPBC Act to apply to all unconventional gas projects, strengthening protections for vital water systems.

Other key components – like the proposed creation of Environment Protection Australia and Environment Information Australia – were introduced to Parliament but ultimately shelved in early 2025 due to lack of Senate support.

Looking Forward: What Should We Expect?

Although the full legislative reform agenda remains uncertain, the outcome of the election appears to have strengthened Labor’s Senate position, which could open the door for further environmental legislation.

For now, we can expect:

• Continued momentum on renewable energy and emissions reduction;
• Selective engagement with environmental law reform, likely in consultation with states, industry, and environmental groups;
• Increased funding and focus on biodiversity outcomes through programs like the Nature Repair Market and 30 by 30 initiatives.

Why It Matters

The decisions made in the next few months will shape how Australia manages its natural assets, responds to climate risk, and positions itself in a decarbonising global economy. For businesses, there’s a real opportunity – and responsibility – to align with these shifts. Staying informed, participating in consultations, and preparing for regulatory changes will be key.

#Sustainability #NaturePositive #ClimatePolicy #EnvironmentalReform #Australia2030 #Biodiversity #NetZero #EnvironmentalLaw

The Joint Ore Reserves Committee (JORC) has released its draft 2024 Code for public consultation, setting the stage for a step-change in the way Australia’s mining and resources industry communicates project viability and value.

This isn’t just a technical update—it’s a fundamental realignment with the modern expectations of investors, regulators, financiers, and communities. The proposed changes embed Environmental, Social and Governance (ESG) considerations, mine closure planning, and the structured use of multidisciplinary specialists into the core of public reporting for Exploration Results, Mineral Resources, and Ore Reserves.

Gone are the days when modifying factors could be treated as a footnote. The draft JORC Code signals that a project’s success is not just defined by geology and economics, but also by its social licence, environmental footprint, regulatory credibility, and long-term legacy.

Key Updates in the Draft JORC Code (2024)
1. Mandatory ESG Considerations in Public Reporting

The most prominent update is the introduction of mandatory ESG evaluation in all stages of reporting. ESG is now positioned as a core modifying factor—placing the onus on Competent Persons (CPs) to either directly assess, or transparently acknowledge, the ESG risks and opportunities that influence project outcomes.

What this means in practice:

• Environmental: Assessment of biodiversity impacts, water security, tailings and waste management, land disturbance, climate-related risks (e.g. flooding or bushfire), greenhouse gas emissions, and rehabilitation obligations.
• Social: Consideration of local and Indigenous community expectations, cultural heritage protections, landholder access, workforce capacity, housing impacts, and the project’s social licence to operate.
• Governance: Transparency regarding permitting pathways, compliance status, regulatory uncertainty, land tenure, and alignment with company governance structures and ESG performance frameworks.

Importantly, the Code does not expect every CP to be an ESG expert—but it does expect CPs to understand when ESG risks are material, and to engage recognised Specialists to fill those knowledge gaps. These ESG aspects will need to be explicitly described, not just assumed.

2. Mine Closure Is a Core Part of Reserve Evaluation

Another pivotal change is the formal integration of mine closure planning and liabilities into the Reserve estimation process. The Code makes clear that closure is not a distant event—it is a present-day risk that must be modelled and costed.

Competent Persons will now need to:

• Demonstrate that closure costs (progressive and final) have been quantified and factored into financial modelling
• Identify whether closure plans are approved, under development, or contested
• Account for the feasibility of relinquishment and any long-term monitoring obligations
• Assess how post-mining land uses align with community and regulatory expectations
• Consider whether residual risk could materially alter project viability, either technically or reputationally

Closure planning is no longer optional. It must now be aligned with life-of-mine scheduling, project valuation, and the narrative presented to markets.

3. Specialist Input is Mandatory, Not Just Preferred

The draft Code introduces an explicit requirement: if the Competent Person lacks competence in an area material to the project’s outcome, a named and qualified Specialist must be engaged, and their input clearly documented in the Public Report.

This includes (but is not limited to):

• ESG
• Tailings and water management
• Geotechnical risk
• Heritage and community engagement
• Closure planning
• Hydrogeology or groundwater modelling

This promotes transparency, prevents unqualified commentary, and ensures that assumptions are properly interrogated. The use of Specialists must be scoped, sourced, and declared—in other words, integrated into the reporting framework, not appended as an afterthought.

IEMA’s Role: Helping You Adapt and Thrive

At IEMA, we see this new Code as a welcome evolution, but not one that needs to be over complicated or adding multiple layers to the process. We’ve long believed that credible projects require more than strong geology—they demand strong governance, sound closure planning, and a clear understanding of community and environmental risk.

With decades of experience across exploration, operations, approvals, closure, and post-mining land use, our team offers more than technical input—we offer strategic perspective built on real-world project delivery.

We don’t just advise. We have walked in your shoes.

How We Help Clients Navigate the Draft JORC Code

• Integrated Risk Assessment We use structured frameworks to assess ESG, regulatory, and reputational risks early—helping you identify what matters most to Reserve classification, and ensuring modifying factors are fully substantiated.
• Closure Planning & Liability Management Our experts deliver costed closure plans, final landform concepts, progressive rehab strategies, and relinquishment pathways. We support mining clients in transforming closure from a compliance cost into a strategic advantage.
• Specialist Input & Validation From biodiversity and hydrogeology to tailings risk and heritage, we provide recognised Specialists who work closely with our team to support your Competent Persons. This collaborative model ensures your public reports are defensible and JORC-compliant—technically, socially, and environmentally.
• Strategic Reporting & Communications We help clients align internal studies, stakeholder strategies, and JORC reporting obligations into a single, cohesive narrative—reducing risk and improving investor confidence.
• Training, Mentoring & Peer Review Need to uplift capability within your team? We provide internal mentoring, technical peer review, and CP support to help organisations adapt to the Code’s expectations and embed them in business-as-usual.

Whilst the Code is in Draft with the public submissions being considered by the JORC committee, there is a real opportunity to get on the front foot and start to have conversations around what this means for your projects. Don’t wait till it drops and get in front of the curve on this issue.