British Columbia Mine Reclamation Symposium

Custodial transfer of reclaimed mines : barriers and opportunities McKenna, Gord; Straker, Justin; O’Kane, Mike 2016

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202   CUSTODIAL TRANSFER OF RECLAIMED MINES:  BARRIERS AND OPPORTUNITIES   G. McKenna 1 J. Straker 2 M. O’Kane 3   1 Principal, Geotechnical Engineer, BGC Engineering Inc, Vancouver, Canada.  2 Principal, Soil Scientist, Forest Ecologist, Integral Ecology Group, Duncan, Canada.  3 President, Geotechnical Engineer, O’Kane Consultants Inc, Calgary, Canada.   ABSTRACT  Mines aim to be temporary users of the land. Environmental impact statements and permit applications typically indicate most or all of the disturbed land will be reclaimed in a timely manner to the satisfaction of the regulator, then returned to the state or another land owner. The land is to be safe and useful for local communities. Accordingly, the ultimate reclamation goal for most sites is to discharge their liabilities and relinquish the land, fulfilling their commitment to society.  For a variety of reasons, such land relinquishment is extremely rare. More often the land remains unreclaimed or partially reclaimed and under the control of the mine owner. Furthermore, the mines and their shareholders maintain the liability for their sites and require cash flows from their operating mines to support the closed ones. Commonly, mines are simply abandoned to the state by the bankrupt owner. There is seldom adequate bonding to cover reclamation and maintenance costs and taxpayers assume the liability and control of the property. Plans for post-mining land uses are seldom fulfilled.  There is an important opportunity for innovation to allow all stakeholders (mining companies, regulators, local communities) to work collaboratively to make orderly custodial transfer a reality. This paper highlights shortcomings in present approaches, presents an ideal, then discusses barriers, opportunities, and indicates “bright lights” where barriers have been overcome.   KEY WORDS: Mine reclamation, certification, financial assurance, cost, landform and cover system design, sustainable mining, liability, environment    INTRODUCTION  Despite the best intentions, tremendous investment, and pervasive ingenuity, only an extremely small percentage of mine sites have been fully reclaimed and transitioned to post-mining land 203  use. For most of history, mines were simply abandoned once the ores were exhausted. More recently, most mines promise and almost all jurisdictions require progressive reclamation. However, in reality most closed mines are only partially reclaimed, few have received regulatory signoff (a.k.a. bond release, certification, custodial transfer), and access to reclaimed portions of mine sites is generally restricted. One might reasonably argue that “It’s not reclaimed until we can use the land.” With a few notable exceptions, examined below, mining remains a terminal rather than temporary use of the land (McKenna 2002).   The authors have conducted several informal inquiries into successful regulatory signoff and custodial transfer of mined land in recent years, and have consistently found very few examples, despite this being the primary reclamation goal of most mining operations. There are many barriers, but there are also many opportunities. Most opportunities involve close collaboration; setting simple, clear, firm, realistic goals; focusing efforts on executing a single evolving mine plan; then working together over the decades to execute, monitor and adjust. Simple in theory, and while mines are successful at some elements, the industry as a whole is not living up to both internal and external expectations.  As part of sustainable mining, all stakeholders (mining companies, regulators, local communities including aboriginal communities) have a collective duty to collaborate to ensure that mines are temporary users of the land and to create reclaimed landscapes that provide positive land uses for future generations (MAC 2008). While perhaps the onus is on the mining company to lead and fund such efforts, success can only be achieved where there is strong collaboration of all interested parties. Closure will often include some requirements for long-term care across the land (some extensive, some intensive), but the site’s end land uses promised in the closure plan need to be provided in a timely manner.  This paper explores the barriers and opportunities to successful custodial transfer of reclaimed mines. Building on with an ideal, it explores barriers and opportunities and provides some examples of success (or “bright lights” after Kotter and Rathgeber (2006)).     BACKGROUND  Mine reclamation got its start in the 1960s (eg USDOI 1967). Over the past 50 years, there has been a shift in emphasis from reclamation to more holistic closure as noted in an analysis of the reclamation literature by Hockley and Hockley (2015). As described in this paper, there is an opportunity for another shift: a change to an emphasis on true collaboration with communities throughout the life of a mine to jointly create useful reclaimed landscapes. It starts with shared expectations.  Consultation versus true collaboration Consultation on reclamation used to often mean an ad in the local newspaper, an evening open house with donuts and coffee, a few company representatives, a sign-in sheet for visitors, some 204  posters and a presentation and chance for questions, and perhaps a comment card for interested parties to provide written feedback. Typically, reclamation plans were presented and defended. Interest was often low, except in the case of imminent mine closure.   Forward-thinking mining companies have long worked closely with stakeholders on socioeconomic, environmental, and reclamation issues. Larger mines often have a separate department for regulatory and external communication.  In Canada, several Supreme Court of Canada rulings have outlined the duty to consult with First Nations INAC (2013) provides a concise summary. Revised guidelines (INAC 2011) provide direction to federal officials. More recently, in its “Tsilhqot’in Ruling” the Supreme Court of Canada (2014) further outlines the requirements for consultation with First Nations (see Coates and Newman 2014 for a discussion). Elements of these documents can be adopted as part of a wider collaboration strategy.  Court rulings and federal guidelines on consultation notwithstanding, it is in everyone’s best interest to collaborate on mining projects, especially with respect to the creation of useful reclaimed landscapes. Abbott and McKenna (2012) provide an imperative and a framework for such work. Swanson et al (2011) provide a case history of a truly collaborative model involving joint-decision making by a mine, its regulators, community stakeholders, and First Nations communities regarding selenium management that provides a useful example for broader collaboration regarding mine reclamation and custodial transfer.   Setting clear goals The reasons for the near lack of fully reclaimed mines can perhaps be traced back to a fundamental misunderstanding of the overarching reclamation goal. People may think that mining’s promise of temporary use of the land is similar to renting an apartment – the property is loaned (with compensation) to the mine for use for a set period of time, then it will be returned in the shape it was rented out (perhaps with a bit of wear and tear), there is a damage deposit to cover the costs of any needed repairs, that the landlord will inspect the property from time to time, and the renter will fix any damage before leaving. At the end of the lease, the renter and the landlord go through the property together, agree on how to pay for any residual damage, and the renter is responsible to pay for any uncovered damages. The landlord can then rent the property to the next user. This might be also thought of as a restoration model – the land will be restored to its original condition in a timely manner.  But mining and mine reclamation, even done well, typically return landscapes that will usually differ significantly from that which existed before mining. Replacing the original topography, bedrock, and ecosystems will typically be a half to two dozen new reclaimed mining landforms (waste rock dumps, tailings dams and deposits, pit lakes, all connected by a new surface water drainage system with a new water chemistry). In most cases, there will be roads and paths to support long-term monitoring. Often active water treatment with its attendant infrastructure will be required forever. The mined land may be reclaimed to recreation and wildlife habitat or to 205  industrial or agricultural land uses (McKenna et al 2015). Communities often view the lofty aspirations of the miners as commitments to future outcomes but are long forgotten by mine staff (McKenna 2002). Lack of a shared and evolving vision for the closure landscape, especially if communities are expecting restoration rather than reclamation, is likely one of the root causes for disappointment and the lack of signoff.    The Mining cycle – theory vs reality Unfortunately, mine reclamation is traditionally considered the last stage of mining. INAC (2010) provides a typical example of the mining cycle:  • Mineral exploration • Mineral deposit appraisal (and permitting) • Mine construction • Mineral production • Mine closure and reclamation  Numerous international agencies provide similar frameworks, generally largely developed for metal mines but also adaptable to smaller operations (such as rock quarries, sand and gravel pits), and to strip mining with more progressive reclamation (many coal and oil sands mines).   In reality, the notion of distinct stages is often misleading – mines may be doing concurrent exploration during production, construction for expansion during operations, there may be temporary closures followed by restarts, and progressive reclamation may even begin before production. At multi-pit operations, notably most coal and oil sands mines and many multi-pit metal mines, all five stages continue concurrently through an annual mine planning cycle. The life of such mines is usually many decades; some continue over a century. Plans are continually updated in response to commodity prices, new orebody data, new technology (developed by the mine or elsewhere), environmental performance, and changing regulatory and stakeholder constraints and preferences. Mine plans are complex and ever changing. The simplistic view of leaving reclamation and closure activities until the end lead many people to view such activities as best put aside until later. Opportunities are lost.  The closure planning terminology trap The requirement for closure planning largely started in Ontario in the 1990s (OMNDM 1996) is now featured in most jurisdictions (An et al 2013). Although well intentioned, the “closure” terminology may be generating more confusion than clarity (Robertson et al 1998). Many miners don’t see the need to seriously plan for a “closure” that may be decades away, others suppose reclamation can start after operations have ceased, and that custodial transfer is best left until the site reclamation is fully complete. Some feel the royalties paid to governments should cover the closure costs.  206  It is perhaps ironic that creation of future land uses, receiving regulatory signoff, and provisions for the substantial socioeconomic impacts of the cessation of operations are secondary impacts and often not top of mind during operations. Effective consultation regarding closure often is left until the mine is in its final years or months. Closure often comes as a shock to the community – partly due to the inherent optimism of miners and mining communities, but often due to a sudden closure resulting from a drop in commodity prices or a major accident at the mine (McKenna 2002). Even after closure, there is generally optimism that the mine will re-open, or failing that, that there will be significant economic activity for reclamation or in the post-mining land uses for people who remain nearby.  Thus the terminology of “closure planning” can be a trap – instead of waiting for closure, there should be a focus on progressive reclamation (and regulatory signoff) during the life of the mine with a focus on transitioning areas of the mine to post-mining land uses developed with the community and cared for by a willing custodian. New terminology is indicated. It starts with integrated mine planning.   AN IDEAL  It is useful to set out an ideal for successful reclamation and custodial transfer as a framework for uncovering barriers and opportunities (in the following section). The following is updated from McKenna (2002). Today, an ideal program would follow the following path:  • The mine, regulators, local communities (including aboriginal communities) start a truly collaborative approach during the exploration stage that continues through all stages, even beyond custodial transfer. A high level of trust between all parties is earned and maintained throughout. Commitments are tracked publicly and attached to the property. • A comprehensive all-encompassing mine plan (of which land-use / closure planning is but one lens) is completed prior to start up, is executed over the life of the mine, and remains on schedule. The plan evolves with changing conditions, but the process is systematic with no sudden changes or surprises. All have input and are kept apprised of changes (see Figure 1). • The land uses, goals, and design objectives are developed collaboratively. They are modest, achievable, measurable, comprehensive, documented, and understood clearly by all collaborating parties. Design criteria that support the objectives are developed by the mine and approved by regulators. A reclamation design basis memorandum (DBM) document that contains this information is developed and reviewed / updated annually. The integrated mine plan stewards to this document. • Risks are managed through true adaptive management, which is largely based on the geotechnical observational method where risks are identified in advance, contingencies developed and costed in full, and the monitoring program supports timely identification of any performance deficiencies which are remediated as they arise. 207  • Rather than a traditional environmental impact assessment, the pre-mining environmental investigation is focused on supporting a DBM, providing the needed information and models for environmental and risk management. The landscape performance monitoring continues throughout mining and reclamation, providing the foundation for adaptive management. • A parallel socioeconomic assessment is conducted and this aspect of the mine plan is continually updated. Steps to ameliorate the socioeconomic impact of mine closure are included in the plan and start even before mining begins.  • Based on the mine plan, the mine posts a bond or other form of accessible financial assurance to cover the full and real direct and indirect cost of reclamation, tailings and water management, monitoring, and long-term maintenance prior to the start of construction and based upon third-party contractor rates. Such a bond may be required for advanced exploration ahead of mining. There may need to be a short phased ramp-up period before full financial assurance where the regulator shares some of reclamation risk on behalf of society. In this event, the regulator would set aside the corresponding amount of unencumbered financial assurance. An annual third-party audit by an accredited financial firm is performed. • From the earliest days, there is a steady level of progressive / concurrent reclamation, including all aspects of reclamation such as resloping, coversoiling, revegetation, creeks and river establishment, monitoring and maintenance. Low variation in levels and types of annual activities allows a steady and experienced reclamation workforce and consistent budgets. Costs are monitored and used to update the posted financial assurance. Errors made during mining (such as overdumping) are corrected right away. • Reclaimed land is certified progressively by a team with members from all parties. After a few start-up years, there are equal amounts of land being disturbed, reclaimed, and certified every year. The work, while still requiring innovation, creativity, and flair becomes a routine part of the mine’s annual operating cycle. At closure the last disturbed land is reclaimed and certified promptly.  • Reclamation is indistinguishable from the operation, with large mining equipment handling much of the reclamation work as part of its normal operation. • Research is carried out in advance of mining, or provides answers for reclamation and landform design activities well in advance of being required. • Long-term monitoring or maintenance is planned for and agreed to by all parties and executed in a timely and economic manner with minimal impact on the land and its users. • Mechanisms are in place to allow timely and progressive custodial transfer of the land along with residual liability, allowing reduction in the level of posted financial assurance with time. • The resulting landscape is useful and fits into (and supports) the local ecosystems and economy.  • All parties are accepting and proud of the accomplishments in creating a landscape useful to all. 208   Figure 1. Ideally there is just one plan, the integrated mine plan. The closure plan, the reclamation plan, the short range plan, the long range plan, the tailings plans are but lenses on the one integrated mine plan. Furthermore, all interested parties should have input into and keep abreast of the mine plan, share a common vision and shared responsibility for its successful outcome. BARRIERS AND OPPORTUNITIES  Table 1 provides a list of barriers to successful reclamation custodial transfer and offers opportunities to overcome these barriers, ordered to follow the ideal above.  Table 1. Barriers and opportunities Barrier Opportunity Comment / Bright Lights Many mines have limited collaborations with local communities and adopt an announce-and-defend strategy A true collaborative approach can be initiated by any party and can start simple (an informal coffee meeting between two or more people). Start with trust and relationship building. See Figure 2. Abbott and McKenna (2012) describe this approach as part of sustainable mining. Many new mines are adopting a more collaborative approach as part of their operating / permitting strategy. The courts are looking for this. Consultation on reclamation often left until the mine is approaching closure Over the course of a mine’s life, people move out of positions every few years Look to establish a process that accommodates changing personnel in all parties.  Establish a public commitment register stewarded collaboratively where all commitments are laid out clearly and reviewed periodically. Large mines have typically adopted such a register.  See an example of a commitment register by Adani Mining Pty (2014). Many or most of the decisions regarding land use, reclamation, and mine closure are made before Collaboration during the mineral deposit appraisal / permitting phase is critical to allow valuable input into the plan. See McKenna et al (2015). 209  Barrier Opportunity Comment / Bright Lights production even starts, and most are irreversible. Optimistic, ill-defined, undocumented land uses and performance goals and objectives result in different interpretations and ultimately disappointment. Use of a DBM approach to set hierarchical set of land uses, goals, design objectives, and design criteria. Mines are starting to use a DBM approach for closure planning. See Russell et al (2010). Moving to a clear set of goals may mean re-negotiating previous commitments (better now than after mine closure). See Cassie and McKenna (2016). Lack of buy-in for objectives and goals by regulators and local communities Joint development and stewardship See Swanson et al (2011). Land uses, goals, and objective change over the years and decades Accept that changes are inevitable and even desirable. Build flexibility into the process. Recognize that changes to reclaimed land are difficult but there may be flexibility for land yet to be reclaimed. Good monitoring, progressive evaluation and regulatory signoff on reclaimed land is an excellent checkpoint to evaluate goals and objectives vs performance. Adjacent mines develop closure plans with little consideration of regional issues Just about all mines operate in mining regions, and there are also cumulative effects of other resource industries in the area that deserve consideration. Development of regional closure plans is indicated. Closure plans for mining regions is explored by McGreevy et al (2013). Mines carry half a dozen or more plans concurrently, each somewhat at odds with the other. Mines have the opportunity to invest in a single integrated mine plan, with production, tailings, reclamation, and closure plans acting as lenses on the single plan. Regulators can work towards being able to regulate a more fluid plan than large periodic submissions that will be out-of-date before being submitted. Instead of a thousand-page closure plan and dozens or hundreds of supplementary information questions, perhaps good discussion, a few real, stamped engineering drawings, and a brief narrative shared annually would be more useful. See Abbott and McKenna (2012) and An et al (2013) for more information. Development of clear, unambiguous goals is onerous and reduces flexibility Invest in modest goals, then steward closely. Give and take by all parties will be part of the architecture of the plan. See MEND (2012), Cassie and McKenna (2016). Aesthetics rarely considered in mine reclamation but important to communities. There are simple and low cost methods to incorporate aesthetics into mine reclamation. Involving landscape architects for this and other aspects of mine reclamation is a largely untapped opportunity See McKenna et al (2011). Adaptive management as currently practiced has been largely unsuccessful in most applications. Adapting ‘true adaptive management’ based on the geotechnical observational approach is more powerful and builds on a successful framework for earthworks. See CEMA (2012) for more discussion of this approach. 210  Barrier Opportunity Comment / Bright Lights Pre-mining environmental impact assessments take years, cost millions of dollars, and provide little benefit to managing environmental impacts or on mine planning / landform design. Revisit the EIA process, redesign it to focus on elements that are useful, make it a part of the overall mine life such that it carries on seamlessly throughout the life of the mine and into the after-mining period. Requires a local regulatory reset. See Abbott and McKenna (2012). Levels of bonding tend to be much lower than required for closure. Re-engineer the financial assurance system to reflect real activities, real costs, and to ensure availability of resources as needed. Development of a database of mine closure costs based on actual case histories is indicated. There are dozens of systems of reclamation bonding, most of which provide inadequate protection for taxpayers. Likewise, there are many papers and reports calling for reform. See USDA (2004).  Financial assurance is often unavailable when needed. Full reclamation bonding at mine opening often unaffordable by mines Financial assurance often based on mining out of the entire resource and fails to address premature closure. Some mines have little available area for progressive reclamation as most areas (waste rock dumps, tailings ponds) are active through most of the mine life. Reclaim small areas early, look for opportunity for test reclamation areas, design waste rock dumps and tailings for progressive reclamation. Track design methods, costs, and performance closely. Syncrude Canada reclaimed some areas prior to mine operations. Some mines reclaim the lower slopes of waste rock dumps and tailings ponds during construction. Communities and other stakeholders excluded from reclamation certification Take an inclusive and staged approach to signing off on closure plans, landform design, reclamation plans, monitoring programs, and ultimately certification. All parties can take part in the process. See Abbott and McKenna (2012), Mikalson (1995). Reclamation research is not commercialized or comes too late. It is used as an excuse not to complete reclamation. Research needs to be carried out in advance as much as practical and used more for optimization rather than providing answers. Design conservatively and use research to inform future designs. A formal technology transfer program for reclamation research is needed for any funded research. See McKenna et al (2011). The US Office of Surface Mining Reclamation and Enforcement and the US Bureau of Reclamation both have reclamation technology transfer programs. Monitoring is sporadic, focused only on compliance. Monitoring is integral to design, construction, reclamation and operation of the reclaimed landscape and can be a central unifying theme for all these activities. See Fair et at (2014). The Province of Saskatchewan has a new system for managing reclamation monitoring and liability that is a model for other jurisdictions. Long-term monitoring and maintenance falter at closure Little land is certified as reclaimed. Access to users is prohibited. There is a major opportunity to provide access to reclaimed land in advance of signoff.  Instead of all or nothing signoff after mining and reclamation and completed, progressive reclamation and progressive certification would bring more certainty Alberta is exploring a system of progressive certification (AER 2014). Alaska has developed and implemented a pragmatic system and made reclamation certification and bond release routine. See Chambers (2005). TransAlta, the Alberta Mines fail to receive release of bond money / financial assurance for reclaimed land  211  Barrier Opportunity Comment / Bright Lights and less drama to the process. regulator, and local farmers have an enviable record for progressive reclamation and certification for the coal strip mines west of Edmonton. See Mikalson (1995).   Figure 2. Consultation begins with sitting down and discussing goals and aspirations. These kinds of meetings help to build and maintain trust. It’s not about open houses and donuts. It’s not about pushing out the message, or getting a signature on in the guestbook, or demonstrating compliance. It is about long term relationships that span decades. It’s about true collaboration. It’s about making things happen that all can take pride in. Don’t wait until you have engineering drawings (“They already had a plan before they even talked to me.”). Collaboration can begin tomorrow.   CONCLUDING NOTES  Despite the barriers faced by mines and their local communities and regulators, there are plenty of opportunities for improvement and bright lights that demonstrate success is achievable through real collaboration, hard work, and a reset of some aspects of the current system of regulation and practice. Developing reasonable goals, and stewarding collaboratively through the decades of a mine life is critical to success to allow mines and their communities to meet their commitment of temporary use of the land, to sustainable mining, and to providing useful post-mining landscapes and land uses acceptable to all.    ACKNOWLEDGEMENTS  212  Thanks to the many miners, regulators, and community members who shared their sites, insights, and experience over the years, and to Derrill Shuttleworth who illustrates our papers and projects helping to build shared visions.   REFERENCES   Abbott RM, McKenna GT. 2012. Sustainable mining now. turning ideas and ideals into reality. Mine Closure 2012. Brisbane. Australian Centre for Geomechanics. p771-781. Adani Mining. 2014. North Galilee Basin Rail Project Final Commitment Register. Additional information to the environment impact statement. Adani Mining Pty Ltd. Brisbane. 15p. ecce9f-9abb-4fb3-b595-99db3c87948d/roject_final_committment_register.pdf? MOD=AJPERES. Retrieved 2016-09-05. AER (Alberta Energy Regulator). 2014. Q&A Reclamation and Remediation. abandonment-and-reclamation/qa-reclamation-remediation. Updated 2014-04-24. Retrieved 2016-09-05. An R, McKenna G, Scordo E, McGreevy J. 2013. Toward Effective Closure Planning. From Progressive Reclamation to Sustainable Mining. Tailings and Mine Waste 2013 Conference, Banff. University of Alberta Geotechnical Centre, Edmonton. Cassie J and McKenna G. 2016. Mine Closure Planning, Design and Implementation: from Hand-Waving to Reality. First International Congress on Planning for Closure of Mining Operations. Planning for Closure 2016. November 20-22, 2016. Santiago, Chile. Gecamin. CEMA (Cumulative Environmental Management Association). 2012. Oil Sands End Pit Lakes Guidance Document. CEMA. Fort McMurray. 1v Chambers DM. 2005. Alaska Large Mine Reclamation Bonding – 2005. 2006 Billings Land Reclamation Symposium, June 5-8, 2006, Billings, MT. 5p. Coates K and Newman D. 2014. Tsilhqot’in ruling brings Canada to the table. Globe and Mail newspaper article. September 11, 2014. tsilhqotin-brings-canada-to-the-table/article 20521526/. Accessed 2016-09-05. Fair JM, Pollard J and McKenna GT. 2014. Reclaimed closure landscapes: the importance and benefits of operations maintenance and monitoring. 38th Annual British Columbia Mine Reclamation Symposium. September 2014. Prince George, BC. BC Technical and Research Committee on Reclamation. p88-97. Hockley DE and Hockley LC. 2015. Some histories of mine closure, the idea. Mine Closure 2015. Vancouver. Australian Centre for Geomechanics. Perth. 9p.  213  INAC (Indigenous and Northern Affairs Canada). 2010. Table 1: The Risks and Activities of the Mining Cycle. INAC (Government of Canada) Website. 1100100023642/1100100023643. Retrieved 2016-09-05.  INAC (Indigenous and Northern Affairs Canada). 2011. Summary of input from aboriginal communities and organizations on consultation and accommodation. Government of Canada Website. Retrieved 2016-09-06. INAC (Indigenous and Northern Affairs Canada). 2013. Government of Canada and the duty to consult. Government of Canada Website. Retrieved 2016-09-06. Kotter J and Rathgeber H. 2006. Our Iceberg Is Melting: Changing and Succeeding Under Any Conditions. Penguin Group USA. 89p. MAC (The Mining Association of Canada). 2008. Towards Sustainable Mining (TSM) Mine Closure Framework. The Mining Association of Canada. Ottawa. documents/TSM_Mine_Closure_Framework.pdf. Retrieved 2016-09-06. McGreevy J, McKenna G, An R, Scordo E. 2013. Regional mine closure plans – the next improvement in closure planning. Tailings and Mine Waste 2013 Conference. Banff. Nov 3-6. University of Alberta Geotechnical Centre, Edmonton. McKenna G, Abbott R, Nahir M, O’Kane M, Seto J, and Straker J. 2015. Post mine land uses for northern mines. The Northern Latitudes Mining Reclamation Workshop: Reclaiming the North. September 1, 2015. Juneau. PowerPoint presentation. 26p.  McKenna G, O’Kane M, Qualizza C. 2011. Tools for bringing mine reclamation research to commercial implementation. Tailings and Mine Waste 2011 Conference, Vancouver, Nov 6 to 9. 11p McKenna G, Scordo E, Shuttleworth D, Straker J, Purdy B, and Buchko J. 2011. Aesthetics for mine closure. Mine Closure 2011 Conference. Volume 1. Lake Louise, Canada. Australian Centre for Geomechanics. Perth. v1:603-612. McKenna GT. 2002. Landscape engineering and sustainable mine reclamation. PhD Thesis, Department of Civil and Environmental Engineering, University of Alberta, Edmonton. 660p. MEND. 2012. Cold Regions Cover System Design Technical Guidance Document. MEND Report 1.61.5c. Consultant’s report prepared by O’Kane Consultants for Mine Environment Neutral Drainage Program. July 2012. 177p. Mikalson DA. 1995. Principles and practices of sustainable development -- with TransAlta examples. In: R. Singhal (Editor), Mine Planning and Equipment Selection. A.A. Balkema, Calgary, pp. 737-745. MNDM (Ontario Ministry of Northern Development and Mines). 1996. Rehabilitation of mines: Guidelines for proponents, Ontario Ministry of Northern Development and Mines, Sudbury. 1v. 214  Robertson AM, Devenny DW and Shaw SC. 1998. Post mining sustainable use plans versus closure plans, Mine Reclamation and Remediation: BC Mine Reclamation Symposium. British Columbia Technical and Research Committee on Reclamation, Penticton, BC, pp. 95-109. Russell B, McKenna G, Leblanc M, Wells PS, Anderson HB. 2010. Design and construction of the reclamation surface for the first oil sands tailings pond. Mine Closure 2010, Vina del Mar, Chile. Australia Centre for Geomechanics, Perth. 13p. Supreme Court of Canada. 2014. Tsilhqot’in Nation v. British Columbia, 2014 SCC 44, [2014] 2 .C.R. 256, Date: 20140626, Docket: 34986 Swanson S, Abbott R, Funk W, Kirk L, McKenna G, Ohlendorf H, Sandy T. 2011. Building stakeholder engagement in sustainable solutions- the strategic advisory panel on selenium management. Mine Closure 2011 Symposium. Lake Louise, Canada. Australian Centre for Geomechanics. v2:189-196. USDA. 2004. Training guide for reclamation bond estimation and administration. For Mineral Plans of Operation authorized and administered under 36 CFR 228A. USDA Forest Service. 136p. April 2004. USDOI (United States Department of the Interior), 1967. Surface mining and our environment: a special report to the nation. United States Department of the Interior, Washington, 124p.     


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