An analysis of actual cost data for surface mine rehabilitation projects in South Africa and comparison with guideline values published by the Department of Mineral Resources
Cornelissen, Hermanus Stephanus
In 2004, the Department of Minerals and Energy (DME, predecessor to the current Department of Mineral Resources - DMR) published a guideline to calculate the amount that a mining right holder would require for financial provision at mine closure. This research report reviews the guideline, specifically focussing on the “rules-based approach” for determining the quantum of financial provision. Some authors have recorded the misapplication of this guideline in practice and their research supports a conclusion that the guideline does not provide adequately for the real costs of mine closure. This research report makes a comparison between the DME guideline master rates for mine closure costs and actual tendered prices for those same elements of mine closure in the period from 2009 – 2016. The analysis of the actual tender prices for the various master- and component rates in comparison with the DME guideline rates delivered mixed results. While the actual tender values exceeded the guideline master rates in most cases, there were notable exceptions where the actual tender results lagged the master rates. The data obtained from the actual tender prices for mine rehabilitation projects by a third party suggests that the use of CPI to escalate mine rehabilitation costs was very quickly overtaken in reality by higher annual costs and rate increases for most of the DME guideline master rates that relate to surface mining. It means that the DME guideline master rates were not reflective of actual rehabilitation costs by the time that the use of the DME guideline was superseded by the publication of new regulations by the Department of Environmental Affairs in November 2017. Whilst no perfectly linear and distinct relationship could be deduced, the results broadly support the findings of several authors that the actual costs to rehabilitate a mine are much more than the DME guideline document would lead a mine to provide for. The application of a rules-based approach remains an exercise mired in controversy and with many potential inaccuracies. The new NEMA regulations for financial provision completely negate the need for a guideline and relevant State Departments and mining companies alike are consequently dependant on third parties to prepare closure cost estimates.
A research report submitted to the Faculty of Engineering, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Science,
Cornelissen, Hermanus Stephanus, (2018) An analysis of actual cost data for surface mine rehabilitation projects in South African and comparison with guideline values published by the Department of Mineral Resources, University of the Witwatersrand, Johannesburg, https://hdl.handle.net/10539/26592