The Brazilian Mining Code defines mining as the set of operations required for the industrial exploitation of a mineral deposit, which includes mining and processing. In order to obtain a Mining Permit, such operations should be presented in an Economic Exploitation Plan (EEP) which should demonstrate the technical and economic feasibility of mining a deposit. Since 2002, the inclusion of a mine closure plan in the EEP has been a requirement, as the NRM-20. This study investigated the applicability of this requirement's inclusion in the EEP from proposals presented to DNPM. Thirty EEPs were analyzed after the publication of the NRM. Although it is a requirement of NRM-20, this study demonstrates that no one of the studied mines had a closure plan included in the EEP, or thereafter, as an update. And, that those EEPs were approved and the mining permit granted. Even with no closure plans included, 14 EEPs presented some closure cost for economic analysis. In these, the Estimated Closure Cost (ECC) had greatly dispersed values. On the other hand, in 16 EEPs there was no cost estimate associated with mine closure. This study highlights the lack of government guidelines for the evaluation of EEPs focused on a mine closure plan. And, that the mining companies fail to consider the hiring of consultants for closure plan design as a mine closure cost.
Mine closure; economic exploitation plan; NRM-20
