Emphasizing Environmental Management and Monitoring - Mining and the Environment: From Ore to Metal - page 460

Balancing Costs and Benefi ts

Mitigation measures should
aim to ensure that the residual
impact is 'as low as reasonably
practicable'.

As for most aspects of life, mitigation measures need to balance costs and benei ts. As
potential signii cant impacts are identii ed, mitigation measures should aim to ensure
that the residual impact is 'as low as reasonably practicable'. Determining what is reason-
ably practicable is something that the EIA team cannot achieve in isolation. Factors such
as technical feasibility, constructability, and operability are all relevant, and design input
on these issues is a necessity. The second key consideration is cost. In dei ning 'as low as
reasonably practical' for an impact/mitigation measure, the proportionality of cost to ben-
ei t should be given due consideration. Sometimes mitigation measures can save money to
the project proponent, but they always improve project acceptance by the public and by
approval authorities. Of course i nancing must always match legal obligations. Statutory
emissions standards must be met irrespective of the costs involved.
If mine development relies on external i nancing, related loan covenants usually spec-
ify, as a minimum, that the EAP shall be implemented on an agreed schedule with an
agreed budget. The EAP itself is often an integrated part of the environmental mine per-
mit, and stated environmental management and monitoring actions become mandatory
requirements.

Financing must always match
legal obligations.

Focusing on the Top Ten Impacts

An EAP allocating equal attention to all predicted impacts is poorly designed. The top 10
or so impacts should capture most of the mitigation efforts, in terms of study detail and
budget allocation. This is not to say that some other signii cant impacts do not need miti-
gation, but that efforts should be concentrated where most needed.
There is nothing more difi cult to predict than the future. Even the best-designed min-
ing projects cannot plan for each adjustment which is made during the project implemen-
tation. Mitigation measures should be sufi ciently l exible to cope with changes during the
project implementation. This usually means that there is inbuilt capacity to accommodate
conditions beyond those predicted in the EIA. Flexibility also means contingency funds to
i nance emergencies or unforeseen changes in priorities.
Table 10.1 illustrates a commonly used summary of mitigation measures in matrix form.
For each signii cant impact, the matrix details the proposed mitigation measures, manage-
ment location, estimated costs, management schedule, and assigns responsibility. If supported

Efforts should be concentrated
where most needed.

TABLE 10.1
Key Elements of an Environmental Management Matrix - For each signifi cant impact, the matrix details
proposed mitigation measures, management location, estimated costs, management schedule, and assigns responsibility

Impact Measure Location Cost Schedule Responsibility

List impacts
according to
impacted
environmental
resources - air,
land, water, fauna
and fl ora, and
people

Describe
proposed
measures -
mitigation for
negative,
enhancement
for positive
impacts

Specify
mitigation
location
(e.g. effl uent
outfall, or specifi c
community)

Provide allocated
annual budget

Defi ne duration
and frequency
of management
actions
(e.g. quarterly,
continuously)

Defi ne
institutional
responsibilities -
within the
company
and external
authorities