Not just another cost: Queensland’s new land rehab rules are an opportunity for community engagement

Not just another cost: Queensland’s new land rehab rules are an opportunity for community engagement


Across Australia, communities want to better connect with local mining organisations so they understand what impact operations are having on their lives. For these organisations, this interest represents a golden opportunity to strengthen trust through inclusive, two-way community engagement.

In November 2019, Queensland’s Department of Environment and Science (DES) released the new guidelines on Progressive Rehabilitation and Closure (PRC) plans. It largely focuses on the progressive rehabilitation of mined land to a “stable condition” where the land is safe and structurally stable, does not cause environmental harm and can sustain a post-mining land use.

The guidelines impact all holders of environmental authorities (EAs) issued under a site-specific application relating to a mining lease in Queensland. While technical analysis is still central to proper post-mine land rehabilitation, meaningful consultation and engagement with communities has and continues to be a critical element.

The guidelines state: “Community consultation is a key component of the PRC plan and is intended to ensure that anyone impacted by proposed rehabilitation and closure activities at the site has an opportunity to provide input to the planning process.” A supporting information sheet adds that when developing PRC plans, applicants must “identify, notify and engage” those with “genuine interest” in the rehabilitation outcomes or final land outcomes. “Genuine interest” can include direct impact as well as cultural, heritage, environmental, recreational, land use and health interests.

This creates a wide base of stakeholders for organisations to engage. Doing so requires thoughtful planning and meaningful implementation, and provides mining companies further opportunity to put their commitment to community engagement into practice. Best industry practice looks beyond regulations and towards its intent.

Community engagement should be inclusive and two-way

Rich community engagement enables an exchange between an organisation and the community, facilitating people to work toward a shared goal. When planning your approach, offer every stakeholder a chance to be involved but understand that not all will take up the offer.

There are typically four levels of engagement:

Four levels of engagement: Informed, consulted, involved, engaged.

Mining organisations should seek to get to the highest level of engagement – Level 4. In doing so, organisations need to work through the earlier levels, building cumulatively over time. From our extensive experience in public consultation, we understand that creating a conversation and building community trust requires an authentic two-way process.

Being authentic and deliberate in engagement practices can create shared ownership of the desired outcomes. This comes from the organisation understanding the aspirations of the community in which it operates, then working together to create collective outcomes and plans.

Nous put this approach into action recently when reviewing the implementation of six Indigenous Land Use Agreements (ILUAs) between a large mining company and traditional owner groups. We worked with the mining company and traditional owner groups to transition consultation up to Level 3 (Involved) and Level 4 (Engaged). This approach strengthened the parties’ relationships with each other and created mutually beneficial outcomes. Over an 11-month review, a forum of the company and all seven groups was held twice; this had not happened at all in the previous five years.

There is no one size that fits all

Engagement needs to be purposeful, nuanced and drive outcomes of mutual benefit, while also balancing research and depth across activities.

The Nous Consultation Reach and Participation Matrix considers the trade-off between the scale of community reach against the activeness of participation.

Nous Consultation Reach and Participation Matrix

Even with the most generous plan, it is not feasible to fully engage all stakeholders in depth (nor do all stakeholders want this). An organisation’s community engagement approach needs to reflect the quadrant of the matrix it believes is most suitable:

  • High reach, low active: Achieving broad reach, these activities should highlight issues without in-depth coverage. They are often low- to mid-cost, depending on channels and duration. This engagement sits at Levels 1 and 2.
  • High reach, high active: These activities can ensure the community is well informed across diverse and complex issues. They usually take longer and run at a higher cost. This covers engagement at Levels 2, 3 and 4.
  • Low reach, high active: This type of engagement is best for well informed, select groups to detail issues. Due to the highly active nature of stakeholders, activities can be time- and cost-intensive. This covers engagement at Level 4.
  • Low reach, low active: This minimalist approach is unlikely to achieve significant community buy-in and may not meet statutory obligations.

Nous used this matrix in our recent work with a Queensland resources company. Nous partnered with the organisation to develop a regional economic partnership agreement with the community in the Surat Basin region. We designed an engagement approach, including different levels of reach and participation, to match community needs. The engagement was the foundation for the partnership agreement, which may never have been achieved without a thoughtful plan.

Getting community engagement right can be fruitful. The Queensland Government has indicated it will be a critical consideration when assessing PRC applications. Perhaps more importantly, purposeful engagement up front and over time will ensure communities have a voice and understand the process. This helps build and maintain community trust, ultimately protecting the social license to operate.

Get in touch to discuss how your organisation can help you strengthen community trust as you embark on your PRC plan.

Written by Prins Ralston and Rachael Cronin during their time as Nous Principals. Contributing to this article were Emma WhiteCraig Knox Lyttle and Maree Wilson.

Published on 27 February 2020.