Planning for artisanal and small-scale mining during EIA: Exploring the potential

This review considers the potential to better plan for artisanal and small-scale mining (ASM) during the Environmental Impact Assessment (EIA) phase of new major mine developments. We contrast and contextualise the parallel development of comprehensive mine closure regulation in South Africa with the resultant lack of progress in actual rehabilitation of its large and growing negative mining legacy. We discuss socio-economic conditions around the mine and the current tendency/flaw in governance that ignores the extensive ASM activities that exist. The ramifications of omitting the known large cumulative impact of ASM compromises efforts to undertake large-scale mine closure effectively both in theory and practice. This leaves some large-scale mine rehabilitation and closure plans unachievable due to cessation attracting ASM activity, consequently ‘re-opening’ the mine. We discuss the EIA process as an existing legal mechanism to generate wider consultation for post-mine ASM activity options, and to formally recognise and incorporate ASM as a known impact to plan for. Governance obligations for mining companies and policymakers should directly cater for ASM, with the focus directed towards mitigating negative consequences and maximising local socio-economic development benefits that the sector can create, managed through EIA processes.